Category: Rulemaking

Spring 2021 newsletter now available

Want to get the latest news from the Harvard Immigration and Refugee Clinical Program? Check out our Spring 2021 newsletter here. In this newsletter, we have updates on policy advocacy and litigation efforts, student and staff achievements, case victories, and more. If you would like to sign up to receive our newsletter via email, you can…
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Public comments submitted on proposed biometrics regulation

On October 13, our Program submitted a comment on the proposed rule regarding the collection and use of biometrics by the U.S. Citizenship and Immigration Services. This rule would greatly expand the current information collection powers of the Department of Homeland Security, thereby creating a database that could easily be abused by DHS and other…
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Public comments submitted on proposed rules on appellate procedures

On September 25, the Harvard Immigration and Refugee Clinical Program and the HLS Immigration Project (“HIP) submitted a public comment opposing a proposed rule which would alter the handling of appeals to the Board of Immigration Appeals (“BIA”) and, ultimately, undermine the rights of immigrants. The proposed rule would enact a number of troubling changes, including…
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Urgent: submit your comments on new asylum rule today

The Trump administration has proposed yet another new rule that will be detrimental to the asylum system if it goes into effect. In this rule, the Department of Justice and Department of Homeland Security declare that any individual coming from or passing through countries with COVID-19 cases will be barred from asylum and withholding of removal protection. …
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HIRC submits comments on proposed EOIR fee increases

On March 30th, the Harvard Immigration and Refugee Clinical Program (HIRC) submitted comments opposing the proposed rule of the Executive Office for Immigration Review (EOIR) that would increase filing fees charged for certain EOIR forms. HIRC argues that these fee increases are excessive and unjust, and could ultimately deny many immigrants access to justice. In…
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HIRC submits comments on proposed regulations on asylum

The Harvard Immigration and Refugee Clinical Program (HIRC) recently submitted comments urging the Department of Homeland Security and the Department of Justice to withdraw their proposed amendments on asylum procedures and bars to asylum, which jeopardize the lives and safety of countless refugees. The proposed rules would add seven categorical bars to asylum, including to…
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HIP submits comment on proposed expansion of social media surveillance of immigrant applicants

On November 4th, the Policy Team of the Harvard Law School Immigration Project (HIP), in partnership with the Harvard Immigration and Refugee Clinic (HIRC), submitted a public comment opposing DHS’ proposal to ask for social media handles and identifiers in a range of immigration-related forms, including applications for naturalization (Form N-400), lawful permanent resident status…
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HIRC submits comments on expedited removal

On September 23, the Harvard Immigration and Refugee Clinical Program (HIRC) submitted comments on on the Department of Homeland Security (DHS) proposal of “Designating Aliens for Expedited Removal.” In the comments, HIRC urged DHS to halt the expansion of expedited removal because of serious issues with the system, writing “…multiple reports document DHS officers’ failure…
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HIRC submits comments on proposed rule on public charge

On December 10, HIRC submitted comments on the “Inadmissibility on Public Charge Grounds” proposed rule. HIRC strongly opposes this proposal for three main reasons: (1) the proposal would create a chilling effect, (2) the proposal creates barriers to immigrants’ self-sufficiency, and (3) the proposal fails to acknowledge the contributions of immigrants, unnecessarily penalizing those who speak limited…
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HIRC & HIP submit comments on proposed removal of fee waiver

On November 27, HIRC and the HLS Immigration Project (HIP) submitted comments on U.S. Citizenship and Immigration Services’ proposed change to the I-912 Form to remove the means-tested benefit as an eligibility option. Not only will this proposed change create superfluous work for USCIS, but it will also contribute to the many hardships facing asylees.…
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