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AILA's Comments on DHS/INS Regulations and Memos
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2005 - 2004
2005 - 2004
AILA's Comments on Proposed Documentary Requirements for Travel within Western Hemisphere
(43 KB - 11/4/2005)
AILA submits comments on the joint notice by DOS and CBP advising of the documents required for travel within the western hemisphere pursuant to Section 7209 of the
Intelligence Reform and Terrorism Prevention Act of 2004
. AILA Doc. No. 05110463.
AILA's Comment on USCIS Electronic Filing Information Collections
(69 KB - 2/15/2006)
AILA comments on USCIS proposed information collections that would be part of an electronic filing and adjudication initiative. AILA Doc. No. 06021561.
AILA's Comments on DHS Notice Expanding Second Phase of US-VISIT
(82 KB - 10/13/2005)
AILA provides comments on the testing of radio frequency identification (RFID) technology at the land ports to automatically document the exits and any subsequent re-entries of nonimmigrant travelers. Thanks to Kathleen Walker, Ed Rios and Diane Butler for their fine work on these comments. AILA Doc. No. 05101364.
AILA's Comments on Proposed O and P Regulation
(31 KB - 6/21/2005)
AILA comments on the USCIS proposed rule that would require that O and P petitions be filed between six and twelve months prior to need. The comment was prepared on AILA's behalf by Jonathan Ginsburg. AILA Doc. No. 05062161
AILA's Comments on Proposed Changes to the H-2B Program
(72 KB - 4/19/2005)
AILA comments on the proposed regulations by the Departments of Labor and Homeland Security to modify the current H-2B program. AILA Doc. No. 05041960.
AILA Comments on Request for Evidence Regulation
(205 KB - 1/31/2005)
AILA opposes summary denials and reduction in time to respond to requests for evidence. Comment prepared by Naomi Schorr, Chair, Dagmar Butte, Roseanne Mayer, Kelly McCown, Kathleen Moccio, Kirsten Schlenger, Nathan Waxman, Crystal Williams, and Stephen Yale-Loehr. AILA Doc. No. 05013161.
AILA Comments on Fee Increases for MTRs and Appeals
(1/5/2005)
AILA opposes the increases in fees unless the AAO is included in the backlog reduction plan, USCIS withdraws its current Request for Evidence policy, and unless and until USCIS provides a mechanism to waive fees or to refund fees where the appeal or motion is required to correct an obvious USCIS error.
AILA's Comments on the Interim Rule to Expand US-VISIT to the 50 Busiest Land Ports of Entry
(48 KB - 11/8/2004)
AILA comments on the continued need for public awareness outreach; clarification of the waiver for failure to comply with departure requirements; treatment of multiple entry I-94s, laser visa holders, and Canadians; the need for accurate databases; and that the rule should afford access to counsel. AILA Doc. No. 04110868.
AILA/AILF Comments on the DHS/DOJ Joint Proposed Rule Regarding Execution of Removal Orders
(8/19/2004)
AILA and AILF oppose the DHS/DOJ joint proposed regulations to remove the requirement that acceptance by a country is not required for removal to that country, and that "country" does not require the existence or functionality of a government.
AILA Comments on USCIS Fee Increase Rule
(3/3/2004)
AILA criticizes the shifting of expenses that should come from appropriated funds to the fee system, questions the appropriateness of a fee increase at a time of deteriorated service, and challenges the specific cost items that poorly-served applicants are being asked to pay.
AILA's Comments on the US VISIT Interim Regulations
(2/5/2004)
AILA comments on the virtual absence of public awareness outreach, the severity of the consequences of failure to comply with departure requirements, that the rule should clarify that pending extension of stay and change of status applications provide authorized stay, and that the rule should afford access to counsel and proof of departure compliance.
AILA's Comments on the Interim Rule Suspending NSEERS' Re-Registration Requirements
(2/2/2004)
AILA applauds DHS for suspending the re-registration requirements of Special Registration, but expresses concerns about the continuing and new aspects of the program.