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Policy Advocacy 
The ILRC commented on USCIS policy guidance regarding Safe Address and Special Procedures for Persons Protected by 8 USC 1367. ILRC commends USCIS for this guidance and provides suggestions for further strengthening the guidance.
The Immigrant Legal Resource Center (ILRC) builds a democratic society that values diversity and the rights of all people. Through the ILRC’s policy and advocacy efforts, we promote a vision of racial justice that advances the rights of all immigrants, including those who have had contact with the criminal legal system.
The ILRC is dedicated to the long-term goal of dismantling systems undergirded in racial inequities and investing in the power of local communities to organize and create solutions. To achieve our goals, we focus on disrupting the arrest to deportation pipeline that has led to expansive over-policing and immigration enforcement and has contributed to the mass incarceration and exile of Black people and people of color in the United States.
This work is carried out through policy advocacy and implementation at the local, state, and federal level; cultural change work that amplifies a counternarrative to mass criminalization; deep coalition building efforts and collaborative work particularly with directly impacted individuals; and capacity building efforts that equip system stakeholders and impacted communities with the tools to create change that works towards a shared vision of justice for all people
The ILRC is dedicated to the long-term goal of dismantling systems undergirded in racial inequities and investing in the power of local communities to organize and create solutions. To achieve our goals, we focus on disrupting the arrest to deportation pipeline that has led to expansive over-policing and immigration enforcement and has contributed to the mass incarceration and exile of Black people and people of color in the United States.
This work is carried out through policy advocacy and implementation at the local, state, and federal level; cultural change work that amplifies a counternarrative to mass criminalization; deep coalition building efforts and collaborative work particularly with directly impacted individuals; and capacity building efforts that equip system stakeholders and impacted communities with the tools to create change that works towards a shared vision of justice for all people
In June 2023, the California Dignity Not Detention Coalition passed a budget initiative in California called HEAL (Healthy Economies Adapting to Last). HEAL dedicates 5 million dollars to incentivize California localities to divest from immigration detention by providing them funding to invest in new industries and jobs. HEAL presents a new tool in our advocacy toolbox to close detention centers once and for all. This community FAQ breaks down Dignity not Detention’s newest initiative.
In the Spring of 2023, the ILRC surveyed partner organizations and immigration practioners to get a sense of how the Biden Administration’s enforcement priorities were impacting interior enforcement. Unsurprisingly, our analysis of the data showed that federal guidance does not prevent ICE from targeting and detaining people who do not meet agency priorities.
The Immigrant Legal Resource Center submitted this letter on June 16, 2023, to thank USCIS for the many changes that have already been made to the USCIS Policy Manual and to provide further recommendations for changes to the Policy Manual that USCIS can immediately implement to increase access to immigration benefits and reduce backlogs. The letter provides suggestions that include ongoing recommendations from prior letters and engagements as well as new ones.
On April 19, 2023, the ILRC sent a letter to USCIS commending the agency on several changes to the USCIS Policy Manual and practices. The letter acknowledges the agency’s updates to civil surgeon signatures on Form I-693, the inclusion of additional gender markers on forms, clarifications on filing deadlines, and the flexibility for special immigrant juvenile applicants to file Form I-360 in person if they are in danger of aging out of eligibility. These changes are welcome improvements to existing guidance and practices and the ILRC encourage USCIS to continue to make further changes to improve the applicant experience and efficient use of agency resources.
On March 22, 2023, the ILRC sent a letter to USCIS acknowledging the implementation of biometrics flexibilities for domestic benefits applicants who live in remote areas. The ILRC commended the agency on its provision of flexibilities to ensure that all domestic applicants could continue with their benefits applications regardless of physical location in the United States. The ILRC further urged USCIS to expand these flexibilities to applicants abroad and highlighted the negative effects that consulate closures abroad have had on U and T visa applicants attempting to complete their biometrics abroad.
On March 8, ILRC responded to a request for input from the Office of Information and Regulatory Affairs (OIRA) on how to broaden public engagement with the public in the federal regulatory process. ILRC suggested that OIRA partner with community organizations to ensure that information is shared in the most effective way possible, including written materials and trainings. ILRC also made several process suggestions that OIRA can implement to reduce barriers to public participation.
On March 8, ILRC provided comments on the USCIS proposed fee rule. In the comment, ILRC commended agency actions codifying fee exemptions. Additionally, ILRC requested that USCIS codify fee waiver eligibility standards and raise the income threshold for fee waivers. We also requested that fee increases be reduced for applications for lawful permanent residence, work authorization and family petitions, among others. Finally, the comment provides requested changes to various USCIS forms that are open for comment in conjunction with the proposed fee rule.