Rulemaking

We regularly submits comments to the Federal Register in order to address new regulations that affect immigrants in the U.S. These comments are often created in partnership with the HLS Immigration Project‘s policy team. Here are some recent initiatives:

Comments on Motions to Reopen and Reconsider (12/20)
We submitted comments on a proposed rule that would encourage immigration judges to discretionarily-deny applications where immigrants might otherwise qualify for relief. 

Comments on Good Cause for Continuance in Immigration Proceedings (12/20)
We submitted comments opposing a proposed rule that would limit immigration judges’ authority to grant continuances.

Comments on Procedures for Asylum and Withholding of Removal (10/20)
Our program, in partnership with the HLS Immigration Project, submitted comments on a proposed rule regarding accelerated application submission and adjudication timelines. 

Comments on Biometrics Regulations (10/20)
We submitted comments on a proposed rule regarding the collection and use of biometrics by the U.S. Citizenship and Immigration Services. The Harvard Law School Cyberlaw Clinic assisted with the drafting of this comment.  

Comments on Appellate Procedures (9/20)
Our program partnered with the HLS Immigration Project to submit comments on a proposed rule that would alter the handling of appeals to the Board of Immigration Appeals.

Comments on Nonrefoulment (8/20)
We submitted comments on a proposed rule that would violate U.S. nonrefoulment obligations.

Comments on Changes to I-589 Form (8/20)
Our program submitted comments in opposition to proposed changes to the I-589 form (Application for Asylum and for Withholding of Removal).

Comments on Security Bars and Processing (8/20)
Our program submitted comments expressing opposition to a proposed ban on asylum grants in light of COVID-19.

Comments on Asylum Regulations (7/20)
Our program, in collaboration with the HLS Immigration Project, submitted comments on proposed regulations to asylum issued by the U.S. Department of Homeland Security and the U.S. Department of Justice.

Comments on CDC Rule (4/20)
We submitted comments on a proposed rule by the Center for Disease Control (CDC), which would restrict the entry of individuals from certain foreign countries into the United States.

Comments on Fee Increases (3/20)
We submitted comments on EOIR’s proposed fee increases.

Comments on Asylum Regulations (1/20)
We submitted comments urging the Department of Homeland Security and Department of Justice to withdraw proposed amendments on procedures and bars to asylum.

Comments on USCIS Fee Increases (12/19)
Our program, in collaboration with the HLS Immigration Project, submitted comments on proposed increases to USCIS fees.

Comments on Social Media Surveillance (11/19)
Our program, in collaboration with the HLS Immigration Project, submitted comments on the DHS proposal to collect social media information on immigration and travel forms.

Comments on “Inadmissibility on Public Charge” (12/18)
We submitted comments on the proposed change to the public charge regulation.

Comments on “Request for Fee Waiver” (11/18)
Our program, in collaboration with Greater Boston Legal Services (GBLS) and the HLS Immigration Project (HIP), submitted comments on proposals regarding the changes to the USCIS I-912 form.

Comments on Family Detention (11/18)
Our program, in collaboration with Greater Boston Legal Services (GBLS) and the HLS Immigration Project (HIP), submitted comments on proposals regarding the detention of immigrant children.

Comments on Flores v. Reno (11/18)
Our program, in collaboration with Greater Boston Legal Services (GBLS) and the HLS Immigration Project (HIP), submitted comments on proposals regarding the end of the Flores v. Reno settlement.

Recent News

On October 13, our Program submitted a comment on the proposed rule regarding the collection and use of biometrics by
On September 25, the Harvard Immigration and Refugee Clinical Program and the HLS Immigration Project ("HIP) submitted a public comment
The Trump administration has proposed yet another new rule that will be detrimental to the asylum system if it goes