Organizations Support Suspension of Aspect of Special Registration

December 18, 2003

The Honorable Tom Ridge
U.S. Department of Homeland Security
Washington, D.C. 20528

The Honorable Asa Hutchinson
Under Secretary for Border & Transportation Security
U.S. Department of Homeland Security
Washington, D.C. 20528

Dear Secretary Ridge and Under Secretary Hutchinson:

The undersigned organizations write to express our support for the recent suspension of one aspect of the Special Registration Program (the National Security Entry-Exit Registration System or "NSEERS"). While a step in the right direction, this program should be terminated in its entirety.

The special registration program was deeply flawed at its start, both in concept and implementation, and remains deeply flawed today, even with the recently announced suspension of the one-year and thirty-day re-registration requirements. Registration at the border, departure controls, and a "case-by-case" imposition of registration requirements (at DHS's discretion) continue, with notification for the latter initiative given "in a manner reasonably calculated to reach the alien" to include, surprisingly, notice by publication in the Federal Register. Furthermore, these changes do not address the plight of the more than 13,000 already placed in removal proceedings, those who have been refused admission, and others who have been denied benefits because they did not properly register or because our government did not properly note their registration.

Special Registration has failed to advance our national security or improve efficiency within our immigration system, and has been plagued with problems including the following:

  • Outreach and Education Efforts Not Undertaken: The Department of Homeland Security (DHS), like the Justice Department before it, has not undertaken any outreach efforts to educate impacted individuals about program requirements. Continued inaction in this area is especially troubling given that the publicity about the recent change leaves the impression that the entire program has been halted, even though key requirements remain.
  • Inconsistent Implementation: Special Registration has been plagued with inconsistent implementation. In many cases, immigration authorities failed to tell these immigrants of the re-registration and other requirements when they initially registered. Such failure can lead to deportation. Furthermore, we have been receiving reports that DHS officials do not properly understand the program changes recently announced and are giving out incorrect information. If government officials do not understand these changes, how can the agency expect people to understand their continuing obligations?
  • Disproportionate Consequences for People Who Re-register Late: Given such confusion, some people have registered or re-registered late. We have received reports that these people have been detained. Such action is not the best use of our detention facilities and, in many cases, is highly unjust. We fear that others will not understand their continuing obligations given the confusion surrounding the recent program changes, and will face negative consequences.

Special Registration has made immigrant communities nationwide feel besieged, harmed our relationships with foreign governments, and wasted precious resources. In fact, the DHS has estimated that the recently announced changes will allow the agency to reallocate almost 62,000 work hours, a calculation that suggests the degree of efforts that could have been targeted to a more effective program.

The many implementation problems, the questionable use of detention and other resources, concerns with the continuing requirements, and the broad-based view that this program has undermined, not enhanced, our nation's security, argue persuasively for its termination. Such a gesture by this Administration would be a much needed positive signal to not only the communities directly impacted by the program, but all newcomer communities.

Our government needs to initiate investigations and surveillance based on individual suspicion. Our scarce federal dollars need to be spent on what works, and works well to make our nation safer. The Special Registration program does not meet these criteria.


National Organizations

Alliance of Iranian Americans
American-Arab Anti-Discrimination Committee (ADC)
American Civil Liberties Union
American Immigration Lawyers Association
American Muslim Voice
Arab American Community Coalition (AACC) Seattle, WA
Arab American Institute (AAI)
Asian Pacific American Labor Alliance, AFL-CIO
CATA (Farmworkers Support Committee)
The Center for Constitutional Rights
Church World Service Immigration and Refugee Program
CLINIC (Catholic Legal Immigration Network, Inc.)
For Our Grandchildren -- A Social Security Education Project
Immigrant Legal Resource Center
Immigration and Refugee Services of America
Islamic Circle of North America (ICNA Relief)
Japanese American Citizens League (JACL)
Labor Council for Latin American Advancement (LCLAA)
Lawyers' Committee for Civil Rights
Lesbian and Gay Immigration Rights Task Force (NYC)
Lutheran Immigration and Refugee Service
MALDEF (Mexican American Legal Defense and Educational Fund)
Muslim Public Affairs Council
NAKASEC, National Korean American Service & Education Consortium
National Asian Pacific American Legal Consortium (NAPALC)
National Council of La Raza (NCLR)
National Council of Pakistani Americans (NCPA)
National Federation of Filipino American Associations
National Immigration Forum
National Iranian American Council
National Lawyers Guild
Nationalities Service Center in Philadelphia, PA
Organization of Chinese Americans
Pakistani American Public Affairs Committee (PAKPAC)
People for the American Way
Presbyterian Church (USA) Washington Office
Sikh Mediawatch and Resource Task Force (SMART)
Solidarity USA
U.S. Committee for Refugees
World Relief

Regional/Local Organizations

ACLU of Southern California
Alivio Medical Center, Chicago, IL
American Arab Anti-Discrimination Committee, Los Angeles and Orange County Chapter (ADC LA/OC Chapter)
Arab-American Development Corp., Philadelphia Metro region, PA
Arab Community Center for Economic and Social Services, Dearborn, MI
Asian American Community Service Association, Inc., Tulsa, OK
Asian American Legal Defense and Education Fund
Asian Law Alliance, San Jose, CA
Asian Law Caucus, San Francisco, CA
Asian Pacific American Legal Center of Southern California Los Angeles, CA
The Association of the Bar of the City of New York
Borderwatch, Tucson, AZ
Cabrini Immigrant Services, New York, NY
CAIR NY (Council on American-Islamic Relations, NY Chapter)
CASA of Maryland, Inc., Takoma Park, MD
Catholic Charities of Dallas, Inc., Dallas, TX
Central American Refugee Center CARECEN-N.Y., Hempstead, NY
Central American Resource Center, Los Angeles, CA
Center for Gender & Refugee Studies, U.C. Hastings College of the Law, San Francisco, CA
Center for New North Carolinians of University of North Carolina, Greensboro, NC
Centro Comunitario Hispano-Americano, Brevard, NC
Centro Salvadoreno, Hempstead, NY
Community Comprehensive Social Services, Hallandale, FL
Community Refugee and Immigration Services, Columbus, OH
Council on American-Islamic Relations - Arizona (CAIR-AZ)
Council on American-Islamic Relations - Southern California (CAIR-LA)
East Bay Asian Local Development Corporation, Oakland, CA
El Pueblo, Inc., Raleigh, NC
Florence Immigrant and Refugee Rights Project, Florence, AZ
Florida Immigrant Advocacy Center, Miami, FL
Golden Vision Foundation, York, PA
Greater Boston Civil Rights Coalition, Boston, MA
Hate Free Zone of Washington, Seattle, WA
Heartland Alliance for Human Needs and Human Rights, Chicago, IL
High Country Amigos, Inc., Boone, NC
The Human Rights, Education and Law Project [HELP], Newark, NJ
Idaho Office for Refugees, Boise, ID
Illinois Coalition for Immigrant and Refugee Rights, Chicago, IL
Immigrant Legal Advocacy Project, Portland, ME
Interfaith Refugee and Immigration Ministries of Illinois, Chicago, IL
Iranian Community Resource and Service Center, San Jose, CA
Irish Immigration Center, Boston, MA
JUNTOS, Philadelphia, PA
Kealakehe Ahupua'a 2020, Inc., Kailua-Kona, HI
Korean American Resource and Cultural Center, Chicago, IL
Korean Resource Center, Los Angeles, CA
L.A. County Bar Association, Immigration Section, Los Angeles, CA
Lahore Foundation, Inc., Rockville, MD
Lawyers' Committee for Civil Rights under Law of the Boston Bar Association, Boston, MA.
Lutheran Settlement House of Philadelphia, PA
Midwest Immigrant and Human Rights Center, Chicago, IL
Minnesota Advocates for Human Rights, Minneapolis, MN
Na Loio - Immigrant Rights and Public Interest Legal Center, Honolulu, HI
National Lawyers Guild, Bay Area Chapter
Nationalities Service Center of Philadelphia, Philadelphia, PA
Network for Immigrant Justice/Community Alliance of Lane County, Eugene, OR
Network of Arab-American Professionals of New York (NAAP-NY)
New Jersey Immigration Policy Network, Newark, NJ
New York Immigration Coalition, New York, NY
New York Taxi Workers Alliance, New York, NY
The North Carolina Justice and Community Development Center, Raleigh, NC
Northwest Immigrant Rights Project, Granger, WA
Northwest Immigrant Rights Project, Seattle, WA
Pennsylvania Immigration Resource Center, York, PA
Political Asylum/Immigration Representation Project, Boston, MA
Political Asylum Project of Austin - Austin, TX
Refugee & Immigration Service, Diocese of Jefferson City, Jefferson City, MO
Rural Organizing Project, Scappoose, OR
South Asian Committee on Human Rights, Boston, MA
South Asian Network (SAN), Los Angeles, CA
South Texas Immigration Council Inc., Brownsville, TX
VIVE: An Organization for World Refugees of Buffalo, NY
Voces de la Frontera Workers' Center, Milwaukee, WI
Washington Defender Association's Immigration Project, Seattle, WA
Young Korean American Service and Education Center (YKASEC), Flushing, NY

cc: Robert Bonner
Michael Garcia
Stewart Verdery
Dan Sutherland
Clark Kent Ervin


Cite as AILA Doc. No. 03122316.