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Administrator2
01-04-2016, 11:29 AM
As promised, here are the suggestion for initial comments on AC21/EAD for I140 regulation.

This is just first set of comments questioning the process of this rule making and the reason why EAD and AP for I140 is not part of this regulation. Our goal is to have an honest process to include EAD and AP for I140 to this regulation. Your active participation will determine if EAD and AP for I140 is included in this regulation.

Here is the link to the documents with suggestion for comments:
https://www.dropbox.com/s/wko640hmdcmiabg/CommentsForRegulationUSCIS20150008.pdf?dl=0

Here are the steps to submit your comments:
1.) Go to the page for submitting comments for this regulation:
Regulations.gov (http://www.regulations.gov/#!submitComment;D=USCIS-2015-0008-0001)

2.) Click on 'Choose files' button to upload the PDF file.

3.) Enter you First Name and Last Name.

4.) If you want to provide your contact information then check the box that says "I want to provide my contact information" and enter appropriate information.

5.) Click 'Continue' and then submit your comments.


Thank you,

LogicalImmigrant
01-04-2016, 11:37 AM
Thank you.

hil3182
01-04-2016, 11:42 AM
Done.

Please submit comments fearlessly. If you do not stand up for yourself - there is no shortage of interests out there willing to exploit and take advantage of you.

sundeepreddym
01-04-2016, 11:50 AM
Admin - I posted comments. Your Comment Tracking Number: 1k0-8n74-4h66.

Others - It is NOT the time to sit on the side lines and look for messages from other sources who say posting this comment is waste of time/ unwise or some other baloney reasons.

If we don't fight for our desires, no one else will. IV is the only group which is actually on the ground advocating for us. We all WANT the system to behave in 21st century manner. The reality is the system is still old school, boots on the ground is the only PLAY.

hil3182
01-04-2016, 11:53 AM
I have received several private messages about the FBI strategy.

People need to understand that the only way we can expect to receive "portable work authorization" is to get the people acting in bad faith - out of the rule making process. The only way to accomplish this is with a huge volume of comments pointing out this irregularity and asking for an FBI investigation.

greenappletx
01-04-2016, 11:58 AM
Hi,
It's a good documentation but unless I missed, i don't see asking them to give us EAD +AP , though we are questioning or showing WH/USCIS memo but not asking what we needed, do you think we need to include (give us EAD+AP till GC is received) this as well? Thanks

hil3182
01-04-2016, 12:00 PM
Hi,
It's a good documentation but unless I missed, i don't see asking them to give us EAD +AP , though we are questioning or showing WH/USCIS memo but not asking what we needed, do you think we need to include (give us EAD+AP till GC is received) this as well? Thanks

More technical comments will follow later. We first need to make sure any subsequent comments that we do send in (or anybody else might be sending in) will be considered fairly - something that will not happen with the current dispensation.

LogicalImmigrant
01-04-2016, 12:13 PM
Pass this information to your buddies as well and create awareness. Even if there is a 1% hope for changes to the rule after the comments period, let fight for it.

longwait4gc
01-04-2016, 12:14 PM
I have received several private messages about the FBI strategy.

People need to understand that the only way we can expect to receive "portable work authorization" is to get the people acting in bad faith - out of the rule making process. The only way to accomplish this is with a huge volume of comments pointing out this irregularity and asking for an FBI investigation.

Uploaded the doc: 1k0-8n74-r439

If there are lot of duplicate comments wont they deduplicate them, using software or manually? Should we try to reprhase the document and submit comments?

hil3182
01-04-2016, 12:15 PM
Still getting bombed by messages asking mostly the same questions, so let me re-iterate:

1. This is just the first round of comments. More technical comments will follow.
2. If we do not point out irregularities, the very people who watered down the rule will be evaluating comments and no matter how brilliantly you craft your comments, you cannot expect anything positive. The only way we are going to get unrestricted I140-EAD - as the President promised - out of this rule is to expose compromised people in DHS and get them OUT of the rule making process. The most effective way to get them OUT of the rule making process is to ask for the FBI to investigate - very real irregularities that occurred.

It is very important that you please submit these comments as your own.

greenappletx
01-04-2016, 12:17 PM
Done, Uploaded and asked my colleagues/friends to do the same. Thanks IV

hil3182
01-04-2016, 12:34 PM
Uploaded the doc: 1k0-8n74-r439

If there are lot of duplicate comments wont they deduplicate them, using software or manually? Should we try to reprhase the document and submit comments?

When they de-duplicate the comments, they will read it as 1000's of people asking for an FBI investigation into the process.

greenappletx
01-04-2016, 12:39 PM
Still getting bombed by messages asking mostly the same questions, so let me re-iterate:

1. This is just the first round of comments. More technical comments will follow.
2. If we do not point out irregularities, the very people who watered down the rule will be evaluating comments and no matter how brilliantly you craft your comments, you cannot expect anything positive. The only way we are going to get unrestricted I140-EAD - as the President promised - out of this rule is to expose compromised people in DHS and get them OUT of the rule making process. The most effective way to get them OUT of the rule making process is to ask for the FBI to investigate - very real irregularities that occurred.

It is very important that you please submit these comments as your own.





Hi Hil,
What was changed between IV meeting with WH immigration team and now? As Vikram Desai and many indicated that EAD+AP is a done deal but why USCIS made a U turn? The employers & lawyers lobby worked very well compared to us? Thanks

bennyd20
01-04-2016, 12:54 PM
Your Comment Tracking Number: 1k0-8n75-gkly

Thank you IV team.

abcdgc
01-04-2016, 01:01 PM
Hi Hil,
What was changed between IV meeting with WH immigration team and now? As Vikram Desai and many indicated that EAD+AP is a done deal but why USCIS made a U turn? The employers & lawyers lobby worked very well compared to us? Thanks

Can you not read through the comments? Read again here
https://www.dropbox.com/s/wko640hmdcmiabg/CommentsForRegulationUSCIS20150008.pdf?dl=0

What has happened is that opponents used unethical and illegal methods. People need to go to jail over this. That is what IV is asking us to highlight. Is that wrong?

If someone used corrupt method to change the regulation, is that the fault of those stuck in the backlogs? Or is that the fault of that corrupt person?

foia
01-04-2016, 01:13 PM
Can you not read through the comments? Read again here
https://www.dropbox.com/s/wko640hmdcmiabg/CommentsForRegulationUSCIS20150008.pdf?dl=0

What has happened is that opponents used unethical and illegal methods. People need to go to jail over this. That is what IV is asking us to highlight. Is that wrong?

If someone used corrupt method to change the regulation, is that the fault of those stuck in the backlogs? Or is that the fault of that corrupt person?

I respect the action item of admin and myself uploaded the document around 50 times. Had a question, will they care if we point it out in comments... or Should someone/IV report it to FBI directly??? I am sure IV has sufficient proof to back it up...

abcdgc
01-04-2016, 01:17 PM
I respect the action item of admin and myself uploaded the document around 50 times. Had a question, will they care if we point it out in comments... or Should someone/IV report it to FBI directly??? I am sure IV has sufficient proof to back it up...

There is sufficient proof in this document.

https://www.dropbox.com/s/wko640hmdcmiabg/CommentsForRegulationUSCIS20150008.pdf?dl=0


I read it 2 times before posting it. This is really bad that Obama Administration did this. I could not attend the call. Reading through this document it makes me angry that someone is playing games with us.

hil3182
01-04-2016, 01:23 PM
Hi Hil,
What was changed between IV meeting with WH immigration team and now? As Vikram Desai and many indicated that EAD+AP is a done deal but why USCIS made a U turn? The employers & lawyers lobby worked very well compared to us? Thanks

We have been working on this rule since early-mid 2014. We explained the problem to people in the administration, they understood the problem and they committed to providing "Portable Work Authorization" in the EO.

Everything was fine until the middle of the year (as witnessed by the memo we leaked).

We believe that towards the middle of the year, probably thanks to a very large number of I140-EAD inquiries to a very large Immigration Law firm, companies finally woke up towards the implications of this.

We think that in desperation they had THE heaviest hitter in the Immigration Law lobbying space quit what we think was a high six figure job (600-800K a year) - to take a job at DHS with the explicit purpose of killing this regulation. The person I am referring to is a former Immigration Lawyer turned lobbyist for the U.S. Chamber of commerce. This person is the crème de la crème of the lobbying world. When that lobbyist was in the employ of the U.S. Chamber of Commerce, the lobbying coalition that we loosely describe as "The Companies" would never have dreamed of signing off any legislation or regulation without this persons sign-off. Conversely, this persons sign off on a proposal would signify that the broader coalition of "The Companies" has signed off on the proposal. This was one heavy hitter who quit a very highly compensated (and high-profile) at the U.S. Chamber of Commerce to join the DHS at the level of a mid level bureaucrat.

We know for a fact that this person, did not "cool off" for two years after their U.S. Chamber of commerce job before taking up employment at DHS. We believe that in their haste to contain the I140-EAD, companies might have made other mistakes that an FBI investigation will uncover - like making promises of future employment to staffers who will be seeking employment when the Obama Administration demits office.


As I said earlier, our ONLY shot at getting "Portable Work Authorization" out of this, is to shine a spotlight on the irregularity and get this person and all other compromised people out of any position of responsibility having to do with this rule. As far as we can see calling for an FBI investigation is the only and most effective way of doing this.

As soon as this person joined DHS, we saw the writing on the wall. We had subsequent meetings in the WH where we repeatedly and insistently warned them about what was happening. They repeated assured us that this was not happening - we do not know if this was ignorance or malice. Aman went to DHS Ombudsman's conference (with a fever) in a last ditch effort to roll this back - which you saw on that video.



Personally, this is very upsetting. Like the rest of you, I had high hopes around this rule and watching this lobbyist ruin years of hard work - right at the very end pisses me off like you wouldn't believe. As I said on the call, we have a great organization, great "ground game", great leadership - everybody in the Senate, House and Administration knows about about us and our issues. However, unless we can fix the money problem and hire our own lobbyists to play this dirty game, it will be exceptionally difficult to move legislation and more upsetting - this shit will happen again and again and again and again - regardless of how much work we put into anything.



Me and I am sure I speak for most active volunteers are all fucking pissed off at this. We have been robbed of something much more precious than money - we have been robbed of opportunity and our future - Over a million people have been robbed so 2-3 people can get cushy jobs in 2017. The companies and immigration lawyers have made it very clear that they absolutely do not want you to be free. They want you to be stuck in the H1-B cycle so you can work for cheap and line their pockets.

d.kiran
01-04-2016, 01:34 PM
Thank you for the informative post. I was on a flight and could not join the call. I think it would be an understatement to say that I understand IV's feelings after working on this for close to two years, but I think we can at least guess the frustration you might have.

We are all here to support you and hopefully this inspires people to take more active part (including myself).

Are there any discussions happening with the administration on this very flagrant violation of President Obama's executive order? Will White House put any pressure here ?

hil3182
01-04-2016, 01:39 PM
Are there any discussions happening with the administration on this very flagrant violation of President Obama's executive order? Will White House put any pressure here ?

If there are enough comments calling for an FBI investigation, they might. This is ultimately our only hope.

If people don't submit comments calling for an FBI investigation, these very same people that watered down the regulation will continue to write the regulation. You can't do the same thing twice and expect different results.

Eadfor I140
01-04-2016, 02:00 PM
Thanks IV for the initiative. We are questioning the ethics of the rule making process & the rule that is out come of the rule making process.

You guys nail down the questions everyone on this forum had. I did submit the comments. I belive my fellow forum members & their friends will submit comments.

Aother important question is to get support from other american workers for our cause.
Do we have strategy ?

Toadie
01-04-2016, 02:31 PM
...

Me and I am sure I speak for most active volunteers are all fucking pissed off at this. We have been robbed of something much more precious than money - we have been robbed of opportunity and our future - Over a million people have been robbed so 2-3 people can get cushy jobs in 2017. The companies and immigration lawyers have made it very clear that they absolutely do not want you to be free. They want you to be stuck in the H1-B cycle so you can work for cheap and line their pockets.

You said it Hil. Blood was boiling since the VisaGate. This regulation just added to misery. It shows WE<<<<<<<<<<<THEM ! No matter what we do (or don't), we're being shown and driven. There is no doubt that someone has been playing us, paid for by the "Nexus", since the days of VisaGate. I am all for an FBI investigation, but then again, who knows what worms crawl out of that can. We've felt tremors of VisaGate litigation, and this one could be one of those.

Highly disappointed. Obama's first election was founded on Immigration and after 8 years, if this is what is being shoved down our throats, what hopes can one have in future? I would have to start loving my kid more now and lobby him to get me a green card !

DMX17
01-04-2016, 02:49 PM
Great points in the write up and thanks Hil for the honest outburst. Those who were relying on this rule had the worst end to 2015 and, like me, just don’t know who to blame for this pile of shit.

We, immigrants acting for ourselves, cannot expect the same people who screwed this regulation to read our nicely worded comments and change the regulation as we have no jobs to offer to them in 2017 or ever. We are not being given to chance in the first place!

As detailed in comments, an EAD/AP is the only thing that achieves the stated goals of the EO.

Now to the burning questions (already addressed but sharing my thoughts):

Q1: “Should I really reference FBI in my comments?”
As there is strong smell of wrong behavior, it is only fair to ask for this. You have nothing to lose thanks to the bogus rule unless you are satisfied with the 60 day grace period on H1 or an eternal life time of H-1B. I don’t care about this.

Q2: “Why speak about this in comments?”
It is a powerful way to get the anger across to the people (the VB lawsuit people must support this ;)). Keep in mind that the FBI part is not the only comment we are presenting and it is one of the many good arguments we are making. Also, we are asking USCIS/Administration to share the details of how this came about. If enough comments are made to this effect, they are likely to provide a response in the next step of rule making process.

The most ridiculous question one can ask IV is “Can we not talk to President again”? Answer see Q2 above.

I will paraphrase and create my own versions (two for my family).

messengerofgod
01-04-2016, 02:50 PM
We have been working on this rule since early-mid 2014. We explained the problem to people in the administration, they understood the problem and they committed to providing "Portable Work Authorization" in the EO.

Everything was fine until the middle of the year (as witnessed by the memo we leaked).

We believe that towards the middle of the year, probably thanks to a very large number of I140-EAD inquiries to a very large Immigration Law firm, companies finally woke up towards the implications of this.

We think that in desperation they had THE heaviest hitter in the Immigration Law lobbying space quit what we think was a high six figure job (600-800K a year) - to take a job at DHS with the explicit purpose of killing this regulation. The person I am referring to is a former Immigration Lawyer turned lobbyist for the U.S. Chamber of commerce. This person is the crème de la crème of the lobbying world. When that lobbyist was in the employ of the U.S. Chamber of Commerce, the lobbying coalition that we loosely describe as "The Companies" would never have dreamed of signing off any legislation or regulation without this persons sign-off. Conversely, this persons sign off on a proposal would signify that the broader coalition of "The Companies" has signed off on the proposal. This was one heavy hitter who quit a very highly compensated (and high-profile) at the U.S. Chamber of Commerce to join the DHS at the level of a mid level bureaucrat.

We know for a fact that this person, did not "cool off" for two years after their U.S. Chamber of commerce job before taking up employment at DHS. We believe that in their haste to contain the I140-EAD, companies might have made other mistakes that an FBI investigation will uncover - like making promises of future employment to staffers who will be seeking employment when the Obama Administration demits office.


As I said earlier, our ONLY shot at getting "Portable Work Authorization" out of this, is to shine a spotlight on the irregularity and get this person and all other compromised people out of any position of responsibility having to do with this rule. As far as we can see calling for an FBI investigation is the only and most effective way of doing this.

As soon as this person joined DHS, we saw the writing on the wall. We had subsequent meetings in the WH where we repeatedly and insistently warned them about what was happening. They repeated assured us that this was not happening - we do not know if this was ignorance or malice. Aman went to DHS Ombudsman's conference (with a fever) in a last ditch effort to roll this back - which you saw on that video.



Personally, this is very upsetting. Like the rest of you, I had high hopes around this rule and watching this lobbyist ruin years of hard work - right at the very end pisses me off like you wouldn't believe. As I said on the call, we have a great organization, great "ground game", great leadership - everybody in the Senate, House and Administration knows about about us and our issues. However, unless we can fix the money problem and hire our own lobbyists to play this dirty game, it will be exceptionally difficult to move legislation and more upsetting - this shit will happen again and again and again and again - regardless of how much work we put into anything.



Me and I am sure I speak for most active volunteers are all fucking pissed off at this. We have been robbed of something much more precious than money - we have been robbed of opportunity and our future - Over a million people have been robbed so 2-3 people can get cushy jobs in 2017. The companies and immigration lawyers have made it very clear that they absolutely do not want you to be free. They want you to be stuck in the H1-B cycle so you can work for cheap and line their pockets.


Thank you for all your hard work, yesterday's call the the above informative post. I have highlighted in RED what I think is the most important action item for people - apart from submitting IV comments.

During the call, you said something about the transportation bill that I didn't quite get - can you go over it again?

xs2sharad
01-04-2016, 02:56 PM
Guys if we dont speak now and dont show we have a back bone when we will show it.

If IV comes up with some NEWS we are here in 1000's lets be united and make it one effort as those more than 1 Million people speak together the Administration will listen. Atleast I would be able to say to myself that we spoke up rather than sipped a coffee at work and blamed some other person.

sidhupande
01-04-2016, 02:58 PM
Hi All,

The comments that we submit to on regulations.gov, do they need to be unique comments. Do they use any checks to filter out similar comments? I have submitted few comments that do not look identical.

bims_patel
01-04-2016, 03:24 PM
Done, comment tracking #1k0-8n78-ar59. Requesting all others to do the same!

Admins: Please keep us posted for the next round of comments.

Tarang
01-04-2016, 03:28 PM
Hil,

Is Sep vb reversal also directly/indirectly linked to this lobbyist?

Is IV planning a rally or other event to show our frustration on this rule to WH?

np5337
01-04-2016, 03:31 PM
As promised, here are the suggestion for initial comments on AC21/EAD for I140 regulation.

This is just first set of comments questioning the process of this rule making and the reason why EAD and AP for I140 is not part of this regulation. Our goal is to have an honest process to include EAD and AP for I140 to this regulation. Your active participation will determine if EAD and AP for I140 is included in this regulation.

Here is the link to the documents with suggestion for comments:
https://www.dropbox.com/s/wko640hmdcmiabg/CommentsForRegulationUSCIS20150008.pdf?dl=0

Here are the steps to submit your comments:
1.) Go to the page for submitting comments for this regulation:
Regulations.gov (http://www.regulations.gov/#!submitComment;D=USCIS-2015-0008-0001)

2.) Click on 'Choose files' button to upload the PDF file.

3.) Enter you First Name and Last Name.

4.) If you want to provide your contact information then check the box that says "I want to provide my contact information" and enter appropriate information.

5.) Click 'Continue' and then submit your comments.


Thank you,

Can not download document from dropbox. page can not be displayed error.

nvedia
01-04-2016, 03:41 PM
Can not download document from dropbox. page can not be displayed error.

works for me

prince_nagi@yahoo.com
01-04-2016, 03:44 PM
We have been working on this rule since early-mid 2014. We explained the problem to people in the administration, they understood the problem and they committed to providing "Portable Work Authorization" in the EO.

Everything was fine until the middle of the year (as witnessed by the memo we leaked).

We believe that towards the middle of the year, probably thanks to a very large number of I140-EAD inquiries to a very large Immigration Law firm, companies finally woke up towards the implications of this.

We think that in desperation they had THE heaviest hitter in the Immigration Law lobbying space quit what we think was a high six figure job (600-800K a year) - to take a job at DHS with the explicit purpose of killing this regulation. The person I am referring to is a former Immigration Lawyer turned lobbyist for the U.S. Chamber of commerce. This person is the crème de la crème of the lobbying world. When that lobbyist was in the employ of the U.S. Chamber of Commerce, the lobbying coalition that we loosely describe as "The Companies" would never have dreamed of signing off any legislation or regulation without this persons sign-off. Conversely, this persons sign off on a proposal would signify that the broader coalition of "The Companies" has signed off on the proposal. This was one heavy hitter who quit a very highly compensated (and high-profile) at the U.S. Chamber of Commerce to join the DHS at the level of a mid level bureaucrat.

We know for a fact that this person, did not "cool off" for two years after their U.S. Chamber of commerce job before taking up employment at DHS. We believe that in their haste to contain the I140-EAD, companies might have made other mistakes that an FBI investigation will uncover - like making promises of future employment to staffers who will be seeking employment when the Obama Administration demits office.


As I said earlier, our ONLY shot at getting "Portable Work Authorization" out of this, is to shine a spotlight on the irregularity and get this person and all other compromised people out of any position of responsibility having to do with this rule. As far as we can see calling for an FBI investigation is the only and most effective way of doing this.

As soon as this person joined DHS, we saw the writing on the wall. We had subsequent meetings in the WH where we repeatedly and insistently warned them about what was happening. They repeated assured us that this was not happening - we do not know if this was ignorance or malice. Aman went to DHS Ombudsman's conference (with a fever) in a last ditch effort to roll this back - which you saw on that video.



Personally, this is very upsetting. Like the rest of you, I had high hopes around this rule and watching this lobbyist ruin years of hard work - right at the very end pisses me off like you wouldn't believe. As I said on the call, we have a great organization, great "ground game", great leadership - everybody in the Senate, House and Administration knows about about us and our issues. However, unless we can fix the money problem and hire our own lobbyists to play this dirty game, it will be exceptionally difficult to move legislation and more upsetting - this shit will happen again and again and again and again - regardless of how much work we put into anything.



Me and I am sure I speak for most active volunteers are all fucking pissed off at this. We have been robbed of something much more precious than money - we have been robbed of opportunity and our future - Over a million people have been robbed so 2-3 people can get cushy jobs in 2017. The companies and immigration lawyers have made it very clear that they absolutely do not want you to be free. They want you to be stuck in the H1-B cycle so you can work for cheap and line their pockets.

Do we need to hand over this doc the local congressman or there is a different format that needs to be given

Let me know, i can work this in AZ

gcadv15
01-04-2016, 03:59 PM
I am directly affected by this rule as an employee currently in USA on a H1B visa. This rule makes the immigration process and H1B renewal even more difficult instead of improving it. This can only be a result of insincerity or incompetence. Since USCIS staff has demonstrated competence in drafting other rules this rule appears to be an deliberate, insincere and deceitful work of some people at USCIS.
Please consider the suggestions of people who are directly affected by this regulation as not considering them would following an unfair rule making process.

Your Comment Tracking Number: 1k0-8n78-tuee

stocks123
01-04-2016, 04:09 PM
I am not sure if we can directly report to FBI using the website

https://tips.fbi.gov/

in addition to posting the comments in reginfo website.

Posting a bunch of same comments will trigger some inquiry.

dhakaldoo
01-04-2016, 04:13 PM
Comment submitted with tracking no.
1k0-8n79-exia

krish2005
01-04-2016, 04:14 PM
Cannot say a word against your emotional post Hil. Definitely this rule has just been sold to the filthy money eating mongrels..

Can IV not go for a press release ? I believe with Aman's deliverance some media coverage by IV will get more action against these heartless devils that advocated this rule.

Sorry for the harsh words. I have been stuck in this muck for more than 10 years with no respite coming.

Krishna

We have been working on this rule since early-mid 2014. We explained the problem to people in the administration, they understood the problem and they committed to providing "Portable Work Authorization" in the EO.

Everything was fine until the middle of the year (as witnessed by the memo we leaked).

We believe that towards the middle of the year, probably thanks to a very large number of I140-EAD inquiries to a very large Immigration Law firm, companies finally woke up towards the implications of this.

We think that in desperation they had THE heaviest hitter in the Immigration Law lobbying space quit what we think was a high six figure job (600-800K a year) - to take a job at DHS with the explicit purpose of killing this regulation. The person I am referring to is a former Immigration Lawyer turned lobbyist for the U.S. Chamber of commerce. This person is the crème de la crème of the lobbying world. When that lobbyist was in the employ of the U.S. Chamber of Commerce, the lobbying coalition that we loosely describe as "The Companies" would never have dreamed of signing off any legislation or regulation without this persons sign-off. Conversely, this persons sign off on a proposal would signify that the broader coalition of "The Companies" has signed off on the proposal. This was one heavy hitter who quit a very highly compensated (and high-profile) at the U.S. Chamber of Commerce to join the DHS at the level of a mid level bureaucrat.

We know for a fact that this person, did not "cool off" for two years after their U.S. Chamber of commerce job before taking up employment at DHS. We believe that in their haste to contain the I140-EAD, companies might have made other mistakes that an FBI investigation will uncover - like making promises of future employment to staffers who will be seeking employment when the Obama Administration demits office.


As I said earlier, our ONLY shot at getting "Portable Work Authorization" out of this, is to shine a spotlight on the irregularity and get this person and all other compromised people out of any position of responsibility having to do with this rule. As far as we can see calling for an FBI investigation is the only and most effective way of doing this.

As soon as this person joined DHS, we saw the writing on the wall. We had subsequent meetings in the WH where we repeatedly and insistently warned them about what was happening. They repeated assured us that this was not happening - we do not know if this was ignorance or malice. Aman went to DHS Ombudsman's conference (with a fever) in a last ditch effort to roll this back - which you saw on that video.



Personally, this is very upsetting. Like the rest of you, I had high hopes around this rule and watching this lobbyist ruin years of hard work - right at the very end pisses me off like you wouldn't believe. As I said on the call, we have a great organization, great "ground game", great leadership - everybody in the Senate, House and Administration knows about about us and our issues. However, unless we can fix the money problem and hire our own lobbyists to play this dirty game, it will be exceptionally difficult to move legislation and more upsetting - this shit will happen again and again and again and again - regardless of how much work we put into anything.



Me and I am sure I speak for most active volunteers are all fucking pissed off at this. We have been robbed of something much more precious than money - we have been robbed of opportunity and our future - Over a million people have been robbed so 2-3 people can get cushy jobs in 2017. The companies and immigration lawyers have made it very clear that they absolutely do not want you to be free. They want you to be stuck in the H1-B cycle so you can work for cheap and line their pockets.

gcadv15
01-04-2016, 04:23 PM
Even the anti-immigration crowd would be interested to know about possible corruption at USCIS. They do have a loud voice and may be heard. Do we try to share this message with them or could that backfire?

pankajkchhabra
01-04-2016, 04:30 PM
I just posted the comments. I really appreciate IV for putting it together. I was also expecting EAD+AP.
Your Comment Tracking Number: 1k0-8n79-za5z

chintakk
01-04-2016, 04:36 PM
Done, here is mine ..1k0-8n79-k3g5

sidhupande
01-04-2016, 04:48 PM
* This count refers to the total comment/submissions received on this document, as of 11:59 PM yesterday. Note: Agencies review all submissions, however some agencies may choose to redact, or withhold, certain submissions (or portions thereof) such as those containing private or proprietary information, inappropriate language, or duplicate/near duplicate examples of a mass-mail campaign. This can result in discrepancies between this count and those displayed when conducting searches on the Public Submission document type. For specific information about an agency’s public submission policy, refer to its website or the Federal Register document.

RandomizedPrecision
01-04-2016, 05:00 PM
Even the anti-immigration crowd would be interested to know about possible corruption at USCIS. They do have a loud voice and may be heard. Do we try to share this message with them or could that backfire?
I sent it to the Tipline at Breitbart as well as Fox last night.. The Enemy of your Enemy is your friend :)

I didn't have access to the write-up from IV - so I typed up stuff myself and sent it - Not sure if they would look at it but maybe if lot more people write to them they will consider it. After all they post all kindsa rubbish without thinking - this might be the best piece of journalism they come across anytime soon.

deepujohn76@gmail.com
01-04-2016, 05:18 PM
Posted comments.. Will tell family and friends
Your Comment Tracking Number: 1k0-8n79-m4yf

goldengate001
01-04-2016, 05:41 PM
My tracking number 1k0-8n7a-6ff7

palciparum
01-04-2016, 05:59 PM
We have been working on this rule since early-mid 2014. We explained the problem to people in the administration, they understood the problem and they committed to providing "Portable Work Authorization" in the EO.

Everything was fine until the middle of the year (as witnessed by the memo we leaked).

We believe that towards the middle of the year, probably thanks to a very large number of I140-EAD inquiries to a very large Immigration Law firm, companies finally woke up towards the implications of this.

We think that in desperation they had THE heaviest hitter in the Immigration Law lobbying space quit what we think was a high six figure job (600-800K a year) - to take a job at DHS with the explicit purpose of killing this regulation. The person I am referring to is a former Immigration Lawyer turned lobbyist for the U.S. Chamber of commerce. This person is the crème de la crème of the lobbying world. When that lobbyist was in the employ of the U.S. Chamber of Commerce, the lobbying coalition that we loosely describe as "The Companies" would never have dreamed of signing off any legislation or regulation without this persons sign-off. Conversely, this persons sign off on a proposal would signify that the broader coalition of "The Companies" has signed off on the proposal. This was one heavy hitter who quit a very highly compensated (and high-profile) at the U.S. Chamber of Commerce to join the DHS at the level of a mid level bureaucrat.

We know for a fact that this person, did not "cool off" for two years after their U.S. Chamber of commerce job before taking up employment at DHS. We believe that in their haste to contain the I140-EAD, companies might have made other mistakes that an FBI investigation will uncover - like making promises of future employment to staffers who will be seeking employment when the Obama Administration demits office.


As I said earlier, our ONLY shot at getting "Portable Work Authorization" out of this, is to shine a spotlight on the irregularity and get this person and all other compromised people out of any position of responsibility having to do with this rule. As far as we can see calling for an FBI investigation is the only and most effective way of doing this.

As soon as this person joined DHS, we saw the writing on the wall. We had subsequent meetings in the WH where we repeatedly and insistently warned them about what was happening. They repeated assured us that this was not happening - we do not know if this was ignorance or malice. Aman went to DHS Ombudsman's conference (with a fever) in a last ditch effort to roll this back - which you saw on that video.



Personally, this is very upsetting. Like the rest of you, I had high hopes around this rule and watching this lobbyist ruin years of hard work - right at the very end pisses me off like you wouldn't believe. As I said on the call, we have a great organization, great "ground game", great leadership - everybody in the Senate, House and Administration knows about about us and our issues. However, unless we can fix the money problem and hire our own lobbyists to play this dirty game, it will be exceptionally difficult to move legislation and more upsetting - this shit will happen again and again and again and again - regardless of how much work we put into anything.



Me and I am sure I speak for most active volunteers are all fucking pissed off at this. We have been robbed of something much more precious than money - we have been robbed of opportunity and our future - Over a million people have been robbed so 2-3 people can get cushy jobs in 2017. The companies and immigration lawyers have made it very clear that they absolutely do not want you to be free. They want you to be stuck in the H1-B cycle so you can work for cheap and line their pockets.

In addition to sending comments, attaching IV letter and asking for FBI enquiry, should we take IV letter to our Senators and Congressman too to highlight what's going on? Will that help?

essell
01-04-2016, 06:07 PM
Done posting on regulation.gov !!!!!!!!!

My Comment Tracking Number is 1k0-8n77-evps

HumHongeKaamyaab
01-04-2016, 06:20 PM
I am not posting my posting number. Here is my post WORD TO WORD and I also attached Aman's PDF document for added burn. I am pissed off and so should you - honestly I dont give a F*** anymore and if some single as***** took this away from us..I want his head on a platter:
These are my comments that I posted earlier today..and I will post atleast 10 more coments to increase the volume...you do the same....

"I completely REJECT this rule in its current form and would like to request an official FBI enquiry into why everything that was discussed and rediscussed with the LEGAL imigrant community was removed from the final rule based on hiring lobbyists at the DHS inspite of Mr. Obama's Executive Order on Ethics Committments that state that no lobbyist will be appointed for a period of 2 years from the date of their appointment at specific private companies and parties.

The legal immigration community has reason to believe that unethical practices took place behind closed doors to limit and severely restrict legal immigrants' rights from them. The mafia like network that operates behind closed doors needs to be exposed and thus, I call for an immediate FBI enquiry.

The current system has mutated to enslave H1B workers by locking them into one company through a physically and emotionally draining process of having to restart the green card process everytime they want to change jobs, which leads to reduced bargaining power of the H1B employee, leading to reduced wages for these H1B employees and most significantly, the eventual depression of wages for the AMERICAN WORKER. H1B workers stand WITH the American workers NOT against. The corporate greed and lawyer and LOBBYIST's networking power works against a regular person with limited access to money. This is a perversion of the intent of the system and it disgusts me to my core. I am ashamed that I moved to the US when my friends in Canada and Australia mock me for the lack of freedom I have living in supposed 'the land of the free'.

I first came to the US in 2004 to pursue a masters in science degree. I will have to wait until 2025 in the current situation to be able to BE CURRENT with my priority date. Why this 21 year wait for me and my family for following rules and paying taxes LEGALLY??? Why am I being punished for doing the RIGHT THING?

In my current situation, I have had to pass over multiple opportunities with higher wages (Upto 40% increase) and more responsibilities because the hiring firm did not want to go through the hassle of filing PERM and I-140 for me after 6 rounds of interviews!! What if I had an EAD in this situation as was discussed through this rule? I have a masters in science degree and used up my OPT after that. I have been wanting to do an MBA for the last 8 years, but because your rules DO NOT grant an OPT for the same education level, I have been unable to pursue this second master's degree. I cannot wait for H1B after my MBA as school ends in May and H1B starts in October of the next fiscal year creating a gap employers dont want to deal with. What if I had an EAD/Green Card in this situation? I would have earned an MBA and started a company employing AMERICAN workers, paying AMERICAN wages. This example is at the heart of how restrictive the rules are and how they curb an immigrants' ambitions. Please afford us freedom in the form of PORTABILITY and Advanced Parole. In another instance, I had to interface with a client in Canada but could not travel as I do not have a valid visa for re-entry and for which I have to go back to my home country! Ridiculous.

Your rules are regressive and way behind the times compared to the rest of the world. Raise your head and please look at what other countries are doing to make it a compelling case for us immigrants to move there. Your rules are emotionally crushing. Your ways are perverted to feed corporate greed. According to Senate’s lobbying disclosure website, a specific top registered lobbyist for US Chamber of Commerce was related to lobbying or political contributions of over $395 million since 2011. With that standard, this is the top industry registered lobbyist that has lobbied for many years on behalf of companies to push for their agenda which works against the AMERICAN WORKER AND the H1B worker.

1- WE WANT AN FBI EQUIRY INTO THIS MATTER.
2- WE WANT THE AMERICAN PEOPLE TO KNOW THAT WE ARE ABUSED DUE TO THE STATUS QUO WHICH IN TURN HURTS THE AMERICAN WORKER AND LEADS TO DEPRESSED WAGES.
3- WE WANT JOB MOBILITY SO WE CAN LIVE OUR LIVES, BUY HOUSES AND LIVE IN FREEDOM.
4- MAKE THIS RIGHT PER Mr. OBAMA'S OBJECTIVES SET THROUGH EXECUtiVE ACTION.
5- WE WANT ADVANCED PAROLE SO WE CAN TRAVEL FOR WORK INTERNAIONALLY.

Thank you"

HumHongeKaamyaab
01-04-2016, 06:31 PM
How about we send tips to the media to cover this atrocity? I found Fox news' link to contribute a story. IV, Aman, would this be a good idea? Will our story hold up? I am located in Colorado and am seriously thinking of reaching out to the FOX news and in general, the media here. I am very pissed off.

Where can I send story questions, corrections, or news tips? : Help Center - Fox News (http://help.foxnews.com/entries/500736-Where-can-I-send-story-questions-corrections-or-news-tips-)

saviontly
01-04-2016, 07:57 PM
Added my comment 1k0-8n7c-546c

Also tried to educate my friends about the importance of this.

kshan
01-04-2016, 08:31 PM
Tracking Number 1k0-8n7d-50em.

Will urge family and friends.

devenssd
01-04-2016, 09:38 PM
Comment Tracking Number: 1k0-8n7e-1ri6

Will ask my Family and Friends to comment too.

casinoking
01-04-2016, 09:58 PM
Done 1k0-8n7e-74sz

SatnamSingh
01-04-2016, 10:19 PM
--------------------------------------------------------------------------------

* This count refers to the total comment/submissions received on this document, as of 11:59 PM yesterday. Note: Agencies review all submissions, however some agencies may choose to redact, or withhold, certain submissions (or portions thereof) such as those containing private or proprietary information, inappropriate language, or duplicate/near duplicate examples of a mass-mail campaign. This can result in discrepancies between this count and those displayed when conducting searches on the Public Submission document type. For specific information about an agency’s public submission policy, refer to its website or the Federal Register document.

panchi2131
01-04-2016, 10:20 PM
done with the comments !!

nvedia
01-04-2016, 10:59 PM
--------------------------------------------------------------------------------

* This count refers to the total comment/submissions received on this document, as of 11:59 PM yesterday. Note: Agencies review all submissions, however some agencies may choose to redact, or withhold, certain submissions (or portions thereof) such as those containing private or proprietary information, inappropriate language, or duplicate/near duplicate examples of a mass-mail campaign. This can result in discrepancies between this count and those displayed when conducting searches on the Public Submission document type. For specific information about an agency’s public submission policy, refer to its website or the Federal Register document.

Thats a very valid point
That means we should put the comments in our own language and not upload the pdf as described in original post

racoon786
01-04-2016, 11:16 PM
This is just an appalling proposal by USCIS which I oppose in its current state. This proposal helps corporations to retain cheap employees who have no job portability and of course it helps the immigration lawyers who benefit from the cash cow known as H1-B. Why is it so difficult for USICS to give EADs for people who have already been labor market tested with the PERM process and approved for an immigration petition and a vast majority have already been with the same employer for more than 6 years? This proposal and the intent behind it is un-American and very contrary to your USCIS'S own mission statement which reads "USCIS will secure America’s promise as a nation of immigrants by providing accurate and useful information to our customers, granting immigration and citizenship benefits, promoting an awareness and understanding of citizenship, and ensuring the integrity of our immigration system.".

palciparum
01-04-2016, 11:43 PM
Thats a very valid point
That means we should put the comments in our own language and not upload the pdf as described in original post

I guess we can modify letter somewhat, personalize it but keep main and Important contents when posting in comments section so all comments are not identical.

Greenleaf
01-05-2016, 02:23 AM
Hello Admin

I noticed in the regulations.gov site the below :

"* This count refers to the total comment/submissions received on this document, as of 11:59 PM yesterday. Note: Agencies review all submissions, however some agencies may choose to redact, or withhold, certain submissions (or portions thereof) such as those containing private or proprietary information, inappropriate language, or duplicate/near duplicate examples of a mass-mail campaign. This can result in discrepancies between this count and those displayed when conducting searches on the Public Submission document type. For specific information about an agency’s public submission policy, refer to its website or the Federal Register document."

It says "some agencies may choose to redact duplicate/near duplicate examples of a mass-mail campaign." what does that mean? When all of us are posting the same pdf, wont that be considered mass-mail campaign? Please clarify

Also, I have initiated $60, 12 month recurring contribution

laddu0
01-05-2016, 04:55 AM
Dear IV Admins

I attended the call on Sunday 1/3/16. I have following questions.

Can I reuse the comments document posted by Admin or do I need to come up with my own document?

If I reuse the document can I post it on the FBI website link which one of the member mentioned it.

Please advice.

prasadjoglekar
01-05-2016, 07:23 AM
Done, 1k0-8n7o-cqgh.

Made all the points in the doc from admin in my own words.

gaurav77
01-05-2016, 08:44 AM
Done (paraphrased a bit in comments & uploaded doc). Please ask everyone you know to do so in large numbers

1k0-8n7n-lzbf

sac-r-ten
01-05-2016, 08:49 AM
Done. Modified and reworded 2 comments from me and spouse.

hil3182
01-05-2016, 09:17 AM
Folks have been raising valid concerns about duplication comments.

We want to make sure that people short on motivation and time, submit something - so we ask to please submit our comments verbatim at-least once.

Please feel free to customize our comments and submit again - but please make sure you submit ours at-least as often as you submit anything else.

Thank you.

greenappletx
01-05-2016, 10:59 AM
We have been working on this rule since early-mid 2014. We explained the problem to people in the administration, they understood the problem and they committed to providing "Portable Work Authorization" in the EO.

Everything was fine until the middle of the year (as witnessed by the memo we leaked).

We believe that towards the middle of the year, probably thanks to a very large number of I140-EAD inquiries to a very large Immigration Law firm, companies finally woke up towards the implications of this.

We think that in desperation they had THE heaviest hitter in the Immigration Law lobbying space quit what we think was a high six figure job (600-800K a year) - to take a job at DHS with the explicit purpose of killing this regulation. The person I am referring to is a former Immigration Lawyer turned lobbyist for the U.S. Chamber of commerce. This person is the crème de la crème of the lobbying world. When that lobbyist was in the employ of the U.S. Chamber of Commerce, the lobbying coalition that we loosely describe as "The Companies" would never have dreamed of signing off any legislation or regulation without this persons sign-off. Conversely, this persons sign off on a proposal would signify that the broader coalition of "The Companies" has signed off on the proposal. This was one heavy hitter who quit a very highly compensated (and high-profile) at the U.S. Chamber of Commerce to join the DHS at the level of a mid level bureaucrat.

We know for a fact that this person, did not "cool off" for two years after their U.S. Chamber of commerce job before taking up employment at DHS. We believe that in their haste to contain the I140-EAD, companies might have made other mistakes that an FBI investigation will uncover - like making promises of future employment to staffers who will be seeking employment when the Obama Administration demits office.


As I said earlier, our ONLY shot at getting "Portable Work Authorization" out of this, is to shine a spotlight on the irregularity and get this person and all other compromised people out of any position of responsibility having to do with this rule. As far as we can see calling for an FBI investigation is the only and most effective way of doing this.

As soon as this person joined DHS, we saw the writing on the wall. We had subsequent meetings in the WH where we repeatedly and insistently warned them about what was happening. They repeated assured us that this was not happening - we do not know if this was ignorance or malice. Aman went to DHS Ombudsman's conference (with a fever) in a last ditch effort to roll this back - which you saw on that video.



Personally, this is very upsetting. Like the rest of you, I had high hopes around this rule and watching this lobbyist ruin years of hard work - right at the very end pisses me off like you wouldn't believe. As I said on the call, we have a great organization, great "ground game", great leadership - everybody in the Senate, House and Administration knows about about us and our issues. However, unless we can fix the money problem and hire our own lobbyists to play this dirty game, it will be exceptionally difficult to move legislation and more upsetting - this shit will happen again and again and again and again - regardless of how much work we put into anything.



Me and I am sure I speak for most active volunteers are all fucking pissed off at this. We have been robbed of something much more precious than money - we have been robbed of opportunity and our future - Over a million people have been robbed so 2-3 people can get cushy jobs in 2017. The companies and immigration lawyers have made it very clear that they absolutely do not want you to be free. They want you to be stuck in the H1-B cycle so you can work for cheap and line their pockets.



Thanks Hil for ur time and nice explanation. We are with you & IV. Thanks again

gopal008
01-05-2016, 12:06 PM
Will contacting white house help us on this regulation ?

longwait4gc
01-05-2016, 12:32 PM
Folks have been raising valid concerns about duplication comments.

We want to make sure that people short on motivation and time, submit something - so we ask to please submit our comments verbatim at-least once.

Please feel free to customize our comments and submit again - but please make sure you submit ours at-least as often as you submit anything else.

Thank you.

It looks like they are actively deduping it. I dont see any of our comments.
I rephrased the doc in my own words and posted another comment: 1k0-8n7t-gcfx

Can you ask every one to do that?

Toadie
01-05-2016, 01:31 PM
How about we send tips to the media to cover this atrocity? I found Fox news' link to contribute a story. IV, Aman, would this be a good idea? Will our story hold up? I am located in Colorado and am seriously thinking of reaching out to the FOX news and in general, the media here. I am very pissed off.

Where can I send story questions, corrections, or news tips? : Help Center - Fox News (http://help.foxnews.com/entries/500736-Where-can-I-send-story-questions-corrections-or-news-tips-)

Where are you in CO?

HumHongeKaamyaab
01-05-2016, 01:38 PM
Where are you in CO?

I am in Littleton, Colorado. Are you in Colorado as well?

gaurav77
01-05-2016, 01:39 PM
Done (paraphrased a bit in comments & uploaded doc). Please ask everyone you know to do so in large numbers

1k0-8n7n-lzbf


I wanted to check but could not find my comment in the below log (even searched by my name)

Regulations.gov (http://www.regulations.gov/#!docketBrowser;rpp=25;po=0;D=USCIS-2015-0008;dct=PS)

I wonder what is going on, and if they are suppressing comments. Can others who have posted see their comments in the comment log? Please correct me if the above link is wrong.

bob4gc
01-05-2016, 02:16 PM
Besides duplicates, they may just be filtering out with key words. I'm afraid there are considerable no. of comments from desis FOR the regulation. I guess we need to find a way to reach them and educate.

what_if
01-05-2016, 02:16 PM
I think the comments become public at the end of day. Probably, we will see our comments tomorrow.

hil3182
01-05-2016, 02:26 PM
I just did a csv export of all comments. Looks like they have only processed comments received on 12/31 and 01/01.

Please keep commenting questioning the process - notably now a high level industry lobbyist was allowed to write a regulation on the exact issue they were lobbying.

BABUG
01-05-2016, 02:42 PM
I posted around 10 comments from yesterday, Each time a portion of the 6 page document will be on it..;)

Guys, This should not stop us from our follow ups with Reps in support of HR 213.

Tpathrose
01-05-2016, 04:08 PM
This count refers to the total comment/submissions received on this docket, as of 11:59 PM yesterday. Note: Agencies review all submissions, however some agencies may choose to redact, or withhold, certain submissions (or portions thereof) such as those containing private or proprietary information, inappropriate language, or duplicate/near duplicate examples of a mass-mail campaign. This can result in discrepancies between this count and those displayed when conducting searches on the Public Submission document type. For specific information about an agency’s public submission policy, refer to its website or the Federal Register document.

So post things with validpoints

vikidisi
01-05-2016, 04:36 PM
Seeing a lot of momentum - which is fantastic. Keep those comments going.

thokkalohdi
01-05-2016, 05:07 PM
1k0-8n7x-h5wx
attached the pdf... and
added additional comment section as well, just added what i felt... i dont know if that aligns with your strategy.

================================================== ==
President Obama has addressed the nation and promised to resolve the issues for legal immigration by allowing natural career progression via job portability. But this rule doesnot address what President Obama has asked USCIS/DHS to do. In my opinion, both organizations have disregarded executive order, or atleast spoiled the spirit in which White house has created the order in first place by putting riders that would render this rule useless. Although, i try to stay away from these immigration issues as i always believe that Government has to decide them, i am responding because at a honesty and morality level your organization has failed. And in a democratic world, it will become responsibility of people to pick up from there and voice in. To me , it appears as if USCIS/DHS are working for businesses who want to control non-immigrant workers and stop their career progression and are overlooking social aspects of workers who are brought to America with promise of dreams.

6+ years is a long time in life of a non-immigrant worker, a non-immigrant worker also wants to take up better positions in his field, he might want to buy a home or invest in his child's education.Waiting for years together without enjoying a natural life events (buying a home, taking up higher promotion, & investing in childs education etc) and just holding out to get a permanent resident status is a bad situation that a worker does not need to go through. And this is the very reason President asked for reforms in providing "natural career progression" and "job portability".

I sincerely request you to implement what President Obama has ordered DHS/USCIS to implement and not this rule which is in stark contrast to the spirit in which President Obama has made the address to this great nation.

hil3182
01-05-2016, 05:09 PM
1k0-8n7x-h5wx
attached the pdf... and
added additional comment section as well, just added what i felt... i dont know if that aligns with your strategy.

================================================== ==
President Obama has addressed the nation and promised to resolve the issues for legal immigration by allowing natural career progression via job portability. But this rule doesnot address what President Obama has asked USCIS/DHS to do. In my opinion, both organizations have disregarded executive order, or atleast spoiled the spirit in which White house has created the order in first place by putting riders that would render this rule useless. Although, i try to stay away from these immigration issues as i always believe that Government has to decide them, i am responding because at a honesty and morality level your organization has failed. And in a democratic world, it will become responsibility of people to pick up from there and voice in. To me , it appears as if USCIS/DHS are working for businesses who want to control non-immigrant workers and stop their career progression and are overlooking social aspects of workers who are brought to America with promise of dreams.

6+ years is a long time in life of a non-immigrant worker, a non-immigrant worker also wants to take up better positions in his field, he might want to buy a home or invest in his child's education.Waiting for years together without enjoying a natural life events (buying a home, taking up higher promotion, & investing in childs education etc) and just holding out to get a permanent resident status is a bad situation that a worker does not need to go through. And this is the very reason President asked for reforms in providing "natural career progression" and "job portability".

I sincerely request you to implement what President Obama has ordered DHS/USCIS to implement and not this rule which is in stark contrast to the spirit in which President Obama has made the address to this great nation.

Aligns very well. Thank you.

Toadie
01-05-2016, 05:16 PM
I am in Littleton, Colorado. Are you in Colorado as well?

Yes Neighbor. Sent you a PM.

We don't have a CO chapter. Might as well now that we have two of us here lol.

tapanhp
01-05-2016, 05:27 PM
Comment Tracking Number: 1k0-8n77-i7or

________________

Dear Mr. Cummings,

I am a high skilled immigrant worker and WOULD HAVE BEEN directly affected (like approx.1.5 million other folks) by this regulation change. The proposed regulatory change would bring minuscule relief to the EB community and fails to achieve what the Executive Order prescribed.

I understand that this proposed regulatory change was a result of the Nov 2014 Executive Order to fix an archaic immigration system. The executive action promised to address the legal immigration system because it was clear that High Skilled Immigrants in visa backlogs were suffering tremendous personal, professional and financial losses, and were a tool for bad intentioned employers to depress the labor market (adversely affecting the American Skilled Worker)

Job mobility for High Skilled Immigrants with approved I-140 petitions would have negated the personal and professional stresses for such individuals as me, while at the same time boosted the labor market by preventing misuse of the system.

The change of regulation proposed here achieves very little, if anything, for a community languishing in immeasurable stresses. It would be apt to say that the EB community was INVITED FOR A STEAK DINNER AND SERVED A PEANUT instead.

I fail to see how this regulation would help with "Retention of EB–1, EB–2, and EB–3 Immigrant Workers and Program Improvements Affecting High- Skilled Nonimmigrant Workers".

It is with paramount frustration and anguish that I write this comment. I am astounded by the blatant disregard of the plight of the EB immigrant and by the failure of the administration to change status quo. I wonder what conspired between Nov 2014 and now, causing a good intentioned administration that promised change to settle for status quo!

I would like for the administration to

1. Conduct a thorough and transparent investigation into how the policy making process strayed way out of context!

2. Propose a regulatory change that would result in true job mobility or portability for EB immigrants. Options for that would include
 Offering EADs and AP to immigrants with approved I-140 petition  If the DHS is not willing to practice it's authority to issue work permits then it should atleast make the approved I-140 petitions irrevocable (immediately, upon approval) and later allow adjustment of status using the same approved I-140 petition as long as the petitioner is working in a "Same or Similar" job classification at the time of adjustment. (this would offer true portability while the petitioner also pays the H1-B ransom every 3 years)

Thank you (for the past few months during which we started believing our misery was about to end)

DMX17
01-05-2016, 05:31 PM
Seeing a lot of momentum - which is fantastic. Keep those comments going.

I am so annoyed that I plan to spend the whole day Friday (or even weekend) writing so many comments. Some of which will contain profanity.

The only thing that this new rule inspires me to do is make jokes.

Joke of the day (in real life played on immigrants):

Immigrant: People in backlog and endless GC processes need relief so that we can change jobs freely, help economy, create jobs

President: I hereby direct DHS to .......blah blah.....clap clap

DHS: Lucky you, congress passed AC21 law 15 year ago and it was intended for the same purposes you mentioned! DHS has now summarized all of that again so as to make sure that our adjudicators are consistent in approving/denying your case.

Immigrant: Fu$k me.

RandomizedPrecision
01-05-2016, 05:44 PM
I got so riled up after the call with Aman on Sunday that I could not wait for IV's template. So, I put in my comments which coincidently aligned with what IV has in the doc.

Please feel free to re-use re-purpose as needed so that the a$$holes at USCIS don't end up discounting things as duplicates

************************************************** ********************

This is an outrageous rule because it has been watered down and deviated from the original directive of the President's Executive Order. There is absolutely nothing on offer other than lip-service in this rule for the High-Skill Working community who are legally here and have an approved immigrant petition!

President Obama's Immigration Executive Order and the Fact Sheet released by the White House (https://www.whitehouse.gov/the-press-office/2014/11/20/fact-sheet-immigration-accountability-executive-action) explicitly promised these two things (among many others) for the legal community:

1. Providing portable work authorization for high-skilled workers awaiting LPR status and their spouses

2. Ensuring that individuals with lawful status can travel to their countries of origin.

There is absolutely nothing in this rule for folks who have been waiting in decade long lines for their green cards. In fact, it just creates additional burdens for the same individuals making them tether to their employers for years and years.

Here are the changes that should be done to stay true to the President's original intent:

1. Provide immediate Employment Authorization (EAD) for anyone who is waiting in line for a Green Card because of backlogs. These backlogs are unjustly hurting people from a few countries only (China, India, Phillipines, Mexico) and individuals from these countries are stuck in the same jobs without an ability to change employers, start their own businesses, take promotions etc.

2. Completely eliminate the "Compelling Circumstances" clauses. There should be no need to prove that there are any compelling circumstances as these individuals are already stuck in backlogs created by administrative inefficiencies (visa number wastage) and creating backlogs endlessly tying people into one job wasn't the original intent of congress anyway. People who have an approved immigrant petition (I-140) should be immediately allowed to file for Employment Authorization (EAD) without too many hurdles. These individuals have been stuck with the same employer for years with no end in sight to their wait through the backlogs for greencards.

I do support some of the regulations \ clarifications in here (I-140 ownership by the immigrant, 60 day grace period in case of job loss, I-140 portability even in case of withdrawal) but I would like to state these there are current practices that are just being formally codified. So in that sense, these are nothing new - These were long overdue codifications of the processes that USCIS already practiced and hopefully they will eliminate any inconsistencies in the future.

USCIS/ DHS should realize that it is incredibly short-sighted to infer that an ability to take a new job due to a (visa transfer) + (refile of PERM) + (refile of I-140) + (same or similar clarification) is not the same as having an Employment Authorization. In fact equating the two just indicates that people who drafted this rule are either incredibly naive or really sinister in their intentions. Asking prospective employers for visa transfers and restarting the immigration process instantly puts a lot of job opportunities out of the reach of candidates while having an EAD creates minimal burden on both the new employer and the employee and thereby makes the candidate more desirable. Forcing legal immigrants to go through the process again just creates an endless stream of revenue for the legal firms and most importantly suppresses wages and hurts the american worker because immigrants continue to be exploited like slaves with no freedom.

I would like to know the names and affiliations of the USCIS/DHS officials who were involved in drafting this proposal because this reeks of corporate corruption at the highest scale where lobbyist-turned-administrators muddy up administrative fixes to keep their prior\future masters happy. I would request the FBI (Federal Bureau of Investigation) to investigate this case as this is a perfect example where few corrupt and morally void people in power at USCIS/DHS are maligning the name of the entire organization whose purpose it should be to serve the homeland, be just to immigrants and the american citizenry.

Why do undocumented individuals get Employment Authorization cards (a case that the Government and Agency hopes to defend successfully in the Supreme Court) while legal immigrants have to continue to file and re-file their papers while getting stuck in a non-immigrant visa without any Employment Authorization. It is absolutely corrupt and outrageous to ask legal immigrants for "Compelling Circumstances" while the bar is set different for undocumented individuals. By the same yardstick, legal Immigrants should simply be granted their EAD if there is backlog for greencards without any need for compelling circumstances.

I am hoping that the administration looks at the comments and makes appropriate fixes to this rule asap. It is still not late to do the right thing!

Toadie
01-05-2016, 06:11 PM
"Land of the free and the home of the brave!". That was the first thing that came to my mind after reading this unjustification to the word "Reform". How can this be Land of the Free when freedome is being made to choke for the people who want to call it Home of the Brave? I am sure my disappointment in this namesake regulation, that keeps the chains attached to my feet, would not harm even an ounce of greatness this country has.

We have a great leader of the nation, President Obama, who has time and time again shown interest in what really needs to be done. His action on immigration relief to highly skilled immigrant community, in the form of Executive Order, was put in the works of DHS/USCIS factory. After so many months of work, if this is what has been the product of that Executive Order, I seriously question the integrity, credibility, cohesion, allegiance to the EO and honesty of the process overall.

It is beyond the doubts that lobbyists from employer and lawyer communities, who want these highly skilled immigrants be treated as modern day educated slaves, have had their influence in wording of the regulation. A complete U turn on the word "Relief", as it was laid out by Mr. President.

I strongly suggest an investigation by authorities in the entire end to end process of putting this regulation in place. All meeting minutes, discussion recordings, travel charged, electronic conversation and current/future employment changes of persons invovled needs to be investigated.

There is no relief and this regulation is just unacceptable in its current form that encourages slavery and puts families in stress. Lives of us immigrants are still human lives I hope. There is such a great disappointment in the community that it is beyond belief.

We need Advance Parole, No EAD revocation, No EAD renewal after just 180 days, No Compelling Circumstances nonsense, I-140 should belong to the petitioner.

skachraj
01-05-2016, 08:03 PM
Comment Tracking Number: 1k0-8n80-awx2.

Thank you very much IV team!

Eadfor I140
01-05-2016, 08:06 PM
I got so riled up after the call with Aman on Sunday that I could not wait for IV's template. So, I put in my comments which coincidently aligned with what IV has in the doc.

Please feel free to re-use re-purpose as needed so that the a$$holes at USCIS don't end up discounting things as duplicates

************************************************** ********************


I am hoping that the administration looks at the comments and makes appropriate fixes to this rule asap. It is still not late to do the right thing!

"O thus be it ever, when freemen shall stand
Between their loved homes and the war's desolation.
Blest with vict'ry and peace, may the Heav'n rescued land
Praise the Power that hath made and preserved us a nation!
Then conquer we must, when our cause it is just,
And this be our motto: 'In God is our trust.'
And the star-spangled banner in triumph shall wave
O'er the land of the free and the home of the brave!"


Guys we pay taxes & pay for the immigration machine. We are the largest customer of USCIS.
Why someone will let their paying customer go?

So you may just want to say loud these Civil War period lyrics

When our land is illumined with Liberty's smile,
If a foe from within strike a blow at her glory,
Down, down with the traitor that dares to defile
The flag of her stars and the page of her story!
By the millions unchained who our birthright have gained, We will keep her bright blazon forever unstained!
And the Star-Spangled Banner in triumph shall wave
While the land of the free is the home of the brave.

javelin768
01-05-2016, 09:05 PM
Done. This is frustrating! :mad::mad::mad:

Tracking number - 1k0-8n81-un5f

GC2022
01-05-2016, 09:39 PM
Couple of years back when i have not heard of Immigration voice, I was very frustrated with the immigration system in the country and decided to write to President obama. His office responded back asking me to write to then USCIS director Alejander mayorkas.

I wrote to Mayorkas and explained to him i need to start a company and would like to know how this can be done. I know i was being naive then, But i really felt they could help me because president obama announced that he is going to make it easier for immigrant entrepreneurs to start companies.

USCIS opened a case and gave me a ticket number. I followed up couple of times and case was closed suggesting that there are statuatory limitations and cannot do much to help me.


I bring this up because i would like to propose if we can write to Jeh Johnson. and let him know of the potentially illegal , clearly unethical and counter productive rule they are about to bring in. If nothing happens, atleast we will have a ticket documented that this was raised as a concern ?

Admin/ others , can you please suggest if this is a bad idea or can i proceed ? If you think this is a good idea, can we do it enmasse?

right2niru
01-05-2016, 10:24 PM
Submitted and here is my tracking # 1k0-8n83-hm2l

puneet2k5
01-05-2016, 10:44 PM
Well, I am not 100% sure if asking for FBI investigation in comments section would help greatly as these comments would be read and judged by the very own people who drafted the rule .So, we should definitely demand for FBI investigation through all possible channels.

hil3182
01-05-2016, 11:03 PM
Admin/ others , can you please suggest if this is a bad idea or can i proceed ? If you think this is a good idea, can we do it enmasse?

Everybody from DHS Secretary on down knows what is going on - including the fact that what happened with this regulation is extremely irregular. The chalta hai attitude isn't limited to the Indian bureaucracy.

By far the most powerful use of your time is to repeatedly and mercilessly point out these irregularities, ask embarrassing questions and demand an FBI investigation in your comments to the regulation.

They are legally obligated to answer all reasonable questions raised in the comments. So long as your refrain from using profanity and keep your comments reasonable - they are legally obligated to respond to your questions.

IV has been dealing with these people for almost a decade now - there is a deep institutional memory about where their pressure points are - take it as a matter of faith, these regulatory comments are hitting a nerve. There is a reason a few weeks ago the companies had their chuddis in a twist about too many negative comments on OPT rule.

It wouldn't surprise me if the lobbyist (and the people in DHS we think they essentially bribed with employment offers) are having sleepless nights about where this is headed. All offers of employment that might have been made are in all probably not happening at this time because the optics of it would be so bad - not to mention it might invite an FBI investigation.

If you have already submitted our comments, and have the time and motivation to compose your own - please continue to compose stinging and creative comments, pointing out the irregularities and demanding a FBI probe.

stocks123
01-05-2016, 11:21 PM
Looks like xxxx Amy is the immigration lawyer who joined DHS.

US Chamber Immigration Director Leaving For DHS - Law360 (http://www.law360.com/articles/696599/us-chambe)...

HumHongeKaamyaab
01-05-2016, 11:51 PM
Looks like xxxx Amy is the immigration lawyer who joined DHS.

US Chamber Immigration Director Leaving For DHS - Law360 (http://www.law360.com/articles/696599/us-chambe)...

Looks like this is her...

https://www.uschamber.com/amy-m-nice

GC2022
01-06-2016, 12:38 AM
Not so nice.

I have named her in my comment. asked for an FBI investigation. I ahave decided to post one comment every day. I have posted 2 comments so far.

I have also decided to write to The president and Jeh johnson and leon rodriguez.

I donot know what will come off it, but i feel i have to give it a shot.

mallina
01-06-2016, 12:46 AM
Not knowing the politics behind the scene on this rule, I may be naive in thinking that this might not have happened without the consent of the leadership. Its just hard to digest that someone had the ability to sidetrack the agenda of the President. And even if someone was able to, Where is the leadership from the President here ? After all, folks have been asking about basic freedom and level playing field for abiding by the rules all the time.

Hate to see the Administration's attitude and silence over VBGate and this regulation. They might be thinking folks here do not have the ability to vote and so it might not even matter what they do to this community, but they should realize that in the process they have lost the trust and people will make it count when they, their children and families do get the ability to vote. They might be able to delay our ability to get an EAD but in due time they cannot stop it. It will probably be in few years if not today and likewise a GC and citizenship. A whole community will certainly remember how classic this backstabbing was.

Just some thoughts...

RandomizedPrecision
01-06-2016, 01:06 AM
Looks like this is her...

https://www.uschamber.com/amy-m-nice


I don't know if it is her or not that derailed this rule (and I don't care anymore). I put in another comment calling her out. Who the fuck cares - implementing this rule is as good as not having anything in the first place.

************************************

This rule should be immediately rectified with the following changes:

1. Drop the compelling reasons clause for folks who have an approved I-140 and grant them immediate EAD without any need to redo their PERM or I-140 with new employers. People waiting in endless greencard backlogs should be a compelling reason in itself. After all undocumented immigrants do not have to do any of this dance - so if the statue can be interpreted to apply to undocumented and if DHS and the White House is confident of defending that in the Supreme Court then it should be applied to legal immigrants as well.

2. There should be no need to redo the PERM and I-140 incase of job changes. This process unduly discriminates against immigrants by making them undesirable to prospective employers. It keeps them stuck to their current employers, suppresses wages and harms the american worker in the process by allowing unscrupulous employers to exploit immigrants who cannot switch jobs without finding another employer who would be willing to redo their visa, refile their PERM and start the immigration process all over again.

3. Grant Advanced Parole and EAD to anyone waiting in a green card backlog.

The following were the intentions and directives of the President as listed in the fact sheet:

1. Providing portable work authorization for high-skilled workers awaiting LPR status and their spouses
2. Ensuring that individuals with lawful status can travel to their countries of origin.

None of this has been accomplished in this rule. Instead USCIS \ DHS is just regurgitating current practices and is a year late in framing up this rule. It is either extreme incompetence or complete corruption at the highest levels.This rule offers nothing to legal immigrants and will just continue to keep them as indentured slaves tethered to their current employers.

I would like to how how the process has deviated so much from the President's original intention and directive. Specifically, please explain who was involved in the framing of the rule, who had inputs into this and what caused it to deviate from what the White House directed the agency to do.

I would also like to know if Amy M. Nice, who recently joined DHS from the US Chamber of Commerce had anything to do with the framing of the rule. If so, please explain why the agency and administration allowed a former lobbyist that protected the interest of US Corporations and spent hours lobbying the agencies was allowed to frame a rule that affected the individuals, their families and the american people? How did the agency ensure that the rule was kept true to the President's original intention despite involvement of former lobbyists with preset agendas.

Were there other individuals like her who were involved in drafting the rule? Was any conflict of interest (current or future) taken into account?

Please stop playing these games and letting a few bad apples at USCIS \ DHS malign the entire organization. This rule is neither fair nor inclusive and does nothing to prevent exploitation of legal immigrants, does NOT provide portable work authorization and DOES Not allow for travel to their countries of origin (Advance Parole).

I was overjoyed when the president and the White House laid out their fact sheet last year in Nov 2015. The Agency is a year late to drafting this rule and has produced this almost 200 page document that regurgitates current practices and just puts more burdens in individuals and their families sentencing them to continuous exploitation and servitude.

Please make the changes that I have proposed in these comments - without them this rule is of no use to the millions of people stuck in greencard backlogs and the exploitation of legal immigrant individuals and their families will continue endlessly.

testingtimes
01-06-2016, 02:15 AM
Your Comment Tracking Number: 1k0-8n87-ho7h.

nvedia
01-06-2016, 04:25 AM
Your Comment Tracking Number: 1k0-8n89-ewp2

nvedia
01-06-2016, 04:28 AM
3,223 Comments Received

Only 383 published so far

what_if
01-06-2016, 08:06 AM
I was trying to search for my comment and thought I would search for the word "lobby" in the search results to see if our comments are being curated inappropriately. To my surprise, I could see only 2 search results came up with the word "lobby" and this did not include my comment. I don't want to be the person who cried "wolf" but this does not look right.

prasadjoglekar
01-06-2016, 08:12 AM
The USCIS seems to be suppressing 90% of the posted comments, and not making them visible to the public. This is for the #1 most popular rule on regulations.gov.

As a comparison, the agencies for #2 and #3 most popular rules on regulations.gov are suppressing only 10% of their comments.

nvedia
01-06-2016, 08:15 AM
The USCIS seems to be suppressing 90% of the posted comments, and not making them visible to the public. This is for the #1 most popular rule on regulations.gov.

As a comparison, the agencies for #2 and #3 most popular rules on regulations.gov are suppressing only 10% of their comments.

How are you sure USCIS is suppressing it ? Is it because of mass-mail campaign or some other reason ?

Its still not late, we should make sure that our comments are visible and find the reason behind the comments which did not appear

nvedia
01-06-2016, 08:17 AM
Not able to edit my previous post but here is my comment

Your Comment Tracking Number: 1k0-8n89-ewp2

After this rule, promise as per Obama has not been delivered. I sincerely request FBI investigation into the matter about the whole rule making process as its a complete deviation from the Executive Action.
We are stuck in the same job for long years because of having to extend H1B every year because of this.
I believe there should be some regard and respect for the money given to Economy as we have worked for so many years
Its not helping the economy, and it gives employers ability to discriminate by not hiring Americans over. Its anti-Americans as Employers only look for low supressing wages and exploit immigrants
I still believe there are people who care in DHS/USCIS and would take appropriate action as they have family too

gaurav77
01-06-2016, 08:35 AM
I was trying to search for my comment and thought I would search for the word "lobby" in the search results to see if our comments are being curated inappropriately. To my surprise, I could see only 2 search results came up with the word "lobby" and this did not include my comment. I don't want to be the person who cried "wolf" but this does not look right.

I did a search for "FBI", nothing shows in the publicly visible comments. Whats going on? They seem to be actively suppressing comments that are pointing to irregularities.

I request IV core's take on this.

BABUG
01-06-2016, 08:37 AM
Everybody from DHS Secretary on down knows what is going on - including the fact that what happened with this regulation is extremely irregular. The chalta hai attitude isn't limited to the Indian bureaucracy.

By far the most powerful use of your time is to repeatedly and mercilessly point out these irregularities, ask embarrassing questions and demand an FBI investigation in your comments to the regulation.

They are legally obligated to answer all reasonable questions raised in the comments. So long as your refrain from using profanity and keep your comments reasonable - they are legally obligated to respond to your questions.

IV has been dealing with these people for almost a decade now - there is a deep institutional memory about where their pressure points are - take it as a matter of faith, these regulatory comments are hitting a nerve. There is a reason a few weeks ago the companies had their chuddis in a twist about too many negative comments on OPT rule.

It wouldn't surprise me if the lobbyist (and the people in DHS we think they essentially bribed with employment offers) are having sleepless nights about where this is headed. All offers of employment that might have been made are in all probably not happening at this time because the optics of it would be so bad - not to mention it might invite an FBI investigation.

If you have already submitted our comments, and have the time and motivation to compose your own - please continue to compose stinging and creative comments, pointing out the irregularities and demanding a FBI probe.


You may submit comments, identified by DHS Docket No. USCIS-2015-0008, by one of the following methods:
Federal eRulemaking Portal: You may submit comments to USCIS by visiting Regulations.gov (http://www.regulations.gov). Follow the instructions for submitting comments.
Email: You may submit comments directly to USCIS by emailing them to: USCISFRComment@dhs.gov. Please include DHS Docket No. USCIS-2015-0008 in the subject line of the message.
Mail: You may submit comments directly to USCIS by mailing them to: Laura Dawkins, Chief, Regulatory Coordination Division, Office of Policy and Strategy, U.S. Citizenship and Immigration Services, Department of Homeland Security, 20 Massachusetts Avenue NW., Washington, DC 20529. This mailing address may be used for paper, disk, or CD-ROM submissions. To ensure proper handling, please reference DHS Docket No. USCIS-2015-0008 on your correspondence.
Hand Delivery/Courier: You may submit comments directly to USCIS by hand delivery or courier to: Laura Dawkins, Chief, Regulatory Coordination Division, Office of Policy and Strategy, U.S. Citizenship and Immigration Services, Department of Homeland Security, 20 Massachusetts Avenue NW., Washington, DC 20529. The contact telephone number is (202) 272-8377. To ensure proper handling, please reference DHS Docket No. USCIS-2015-0008 on your delivery.

gaurav77
01-06-2016, 08:38 AM
I did a search for "FBI", nothing shows in the publicly visible comments. Whats going on? They seem to be actively suppressing comments that are pointing to irregularities.

I request IV core's take on this.

Of course we should not be discouraged by this. We should continue to follow IV's guidelines to fearlessly point out these irregularities and question the process.

mamit1
01-06-2016, 09:28 AM
Folks have been raising valid concerns about duplication comments.

We want to make sure that people short on motivation and time, submit something - so we ask to please submit our comments verbatim at-least once.

Please feel free to customize our comments and submit again - but please make sure you submit ours at-least as often as you submit anything else.

Thank you.


Thanks for the clarification Admin. I have been trying to put as many comments as I can as this seems to me like the moment. I think if we make enough noise someone will hear it and bring it to light. just like the number of comments that were submitted for OPT made some fizzle in the media.

To that end I would also like to ask if its possible for us to have an official Petition on the whitehouse Gove website (https://petitions.whitehouse.gov/) for an inquiry into the rule making process.

Can you also please clarify if we should state the negative aspects of the current regulation and also provide things that are positive such as 60 days grace period for layoffs? or should we only follow the template you have provided of pointing the discrepancies in the rule.

I would like like to ask if we should point out what changes we want in the regulation?

Waiting eagerly for your response and thanks for your leadership.

Ramalingam
01-06-2016, 09:28 AM
I did a search for "FBI", nothing shows in the publicly visible comments. Whats going on? They seem to be actively suppressing comments that are pointing to irregularities.

I request IV core's take on this.

They have to consider the comments if the comments are within the rules. The issue is more the number of comments more delay in decision making. DHS asked 3 months extension for OPT extension as they received 50k comments. Whatever the final rule it could go beyond 2016 in the current circumstances. And if opposing comments are more DHS can scrap the regulation itself. If they consider your comments as enhancement then no problem and there is a chance to improve. But if they consider as opposing comment then DHS has authority to scrap the regulation especially if thousands of comments are like that. If one person has the ability to water down this much the same person can delay the regulation by 3 or 4 years(It took over 3 years for H4-EAD). If after 2017 new WH team will take at least 6 months to get hold of the issue unless many of them in the existing team

kishorda
01-06-2016, 09:33 AM
I have suggestion for IV leader we should all the stake holders including administration that we will file legal brief against DAPA/DACA as there is no reason for us to support administration anymore. This will really hit them hard as it would be very difficult for them to argue in court why illegals can get EAD but not legals.

Its been long we are held hostage for comprehensive immigration reform now its our turn. We should also contact Rep Luis Gutiérrez and ask him to force administration to change there stance as we have always helped there cause.

I am nothing against illegal immigrants but at some point we have to play politics as they do and stand for ourselves.

hil3182
01-06-2016, 11:02 AM
Comments (http://www.regulations.gov/#!documentDetail;D=USCIS-2015-0008-0496) are starting to show up. Please continue to submit them - they will be reviewed.

Submitting comments (either your own or IV's) is the most effective way to shine a spotlight on the way Corporate Lobbyists have hijacked this rule. With that specific lobbyist in place acting without the spotlight being shone on their activities we will just get peanuts from this rule - contrary to the President's November 14th announcement.

As we have said earlier, more technical comments will follow - and we will ask you to submit those. However if we do not shine a spotlight in this dishonesty, there is no chance any comments will receive a fair hearing - regardless of how much time we spend crafting them.

thankstooptx
01-06-2016, 11:05 AM
I have received several private messages about the FBI strategy.

People need to understand that the only way we can expect to receive "portable work authorization" is to get the people acting in bad faith - out of the rule making process. The only way to accomplish this is with a huge volume of comments pointing out this irregularity and asking for an FBI investigation.

Hil, I there a reason we cannot mention the name of the lobbyist that joined the DHS? I want to post this on some social media websites to get attention. Was wondering if it might cause any issues.

krish2005
01-06-2016, 11:33 AM
Folks,

If Aman felt that FBI investigation only will open up the case to understand why and who watered the proposed rule, then its the way.

My suggestion is to request those fellow folks who have already reached upto senators for support HR 213 can also be reached again for their support to request information from USCIS on who and why proposed these newer rules than those that were proposed earlier. I believe that is a good way to move up the coins to get them answer. IV admin will anyway have the best insight.

Man. Do we have words to compliment Aman K for his tireless efforts and kudos to his admin team...

Krishna

LogicalImmigrant
01-06-2016, 11:34 AM
This one finally made it. But they removed the leaked memo link.

Regulations.gov (http://www.regulations.gov/#!documentDetail;D=USCIS-2015-0008-0497)

I submitted 6 comments but none of them show up.

stocks123
01-06-2016, 11:55 AM
New rule to give AP/EAD to illegals.. where is this country heading

https://s3.amazonaws.com/public-inspection.federalregister.gov/2016-00082.pdf

2008candid
01-06-2016, 11:58 AM
This country is ruled by corporate. Govt will get a piece from them. H1B/legals already paying tax. Illegals don't, once they have EAD they will start to pay tax.

hil3182
01-06-2016, 12:18 PM
This is important, so please pay attention.

Please do NOT submit positive comments to any degree. If they get enough positive comments, that rule is the best we are going to get.

If you say something to the effect of, "I support this rule but I want to see I-140 EAD" - they will count it as a supportive comment.

We will provide clear technical comments for support conditional on common-sense fixes like I-140 EAD.

If you are happy with the peanuts they are throwing at us, please feel free to disregard our request.

bob4gc
01-06-2016, 12:36 PM
Agree with hil.

Also,

"Thanks for making the rule ..." also sounds like positive (pro-regulation) though it is to acknowledge their effort. We should avoid the phrase/s that are close to positive and be explicit. For eg. start with negative statement "I do not support this rule ...".

nvedia
01-06-2016, 12:37 PM
This one finally made it. But they removed the leaked memo link.

Regulations.gov (http://www.regulations.gov/#!documentDetail;D=USCIS-2015-0008-0497)

I submitted 6 comments but none of them show up.

Did you save the comments or posted so that it can be found why they are not being shown
Would help others too

LogicalImmigrant
01-06-2016, 12:47 PM
Did you save the comments or posted so that it can be found why they are not being shown
Would help others too

I was referring to this one as it is a template provided by IV. My comments never showed up. You should be able to browse through the below link to see if your comments are approved and posted by them.

Regulations.gov (http://www.regulations.gov/#!docketBrowser;rpp=25;so=DESC;sb=postedDate;po=0; dct=PS;D=USCIS-2015-0008)

RandomizedPrecision
01-06-2016, 12:57 PM
This is important, so please pay attention.

Please do NOT submit positive comments to any degree. If they get enough positive comments, that rule is the best we are going to get.

If you say something to the effect of, "I support this rule but I want to see I-140 EAD" - they will count it as a supportive comment.

We will provide clear technical comments for support conditional on common-sense fixes like I-140 EAD.

If you are happy with the peanuts they are throwing at us, please feel free to disregard our request.


I submitted another comment and this time I put my disdain right up front :)

I DO NOT support this rule in its current form as it does nothing to relieve the suffering and exploitation of legal immigrants. The following changes are Required to this if this is to stay true to the President's Directive and the White House fact sheet released last November regarding improving the conditions for legal immigrants:

1. Drop the compelling reasons clause for folks who have an approved I-140 and grant them immediate EAD without any need to redo their PERM or I-140 with new employers. People waiting in endless greencard backlogs should be a compelling reason in itself. After all undocumented immigrants do not have to do any of this dance - so if the statue can be interpreted to apply to undocumented and if DHS and the White House is confident of defending that in the Supreme Court then it should be applied to legal immigrants as well.

2. There should be no need to redo the PERM and I-140 incase of job changes. This process unduly discriminates against immigrants by making them undesirable to prospective employers. It keeps them stuck to their current employers, suppresses wages and harms the american worker in the process by allowing unscrupulous employers to exploit immigrants who cannot switch jobs without finding another employer who would be willing to redo their visa, refile their PERM and start the immigration process all over again.

3. Grant Advanced Parole and EAD to anyone waiting in a green card backlog. After all you are granting that \ planning to grant that to the undocumented - so why should the same yardstick not apply to folks who are here legally.

How did the proposed rule deviate so drastically from the president's directive? Which corrupt officials at DHS\USCIS are responsible for watering this down and making a mockery of the President and his intentions?

Please stop the exploitation of legal immigrants as well as the American worker. This rule will continue to suppress wages, and let employers exploit workers who will continue to be stuck in endless greencard backlogs.

DMX17
01-06-2016, 01:00 PM
This is important, so please pay attention.

Please do NOT submit positive comments to any degree. If they get enough positive comments, that rule is the best we are going to get.

If you say something to the effect of, "I support this rule but I want to see I-140 EAD" - they will count it as a supportive comment.

We will provide clear technical comments for support conditional on common-sense fixes like I-140 EAD.

If you are happy with the peanuts they are throwing at us, please feel free to disregard our request.

Unless you are with the lawyers or Chamber of Commerce, please make is damn clear that you oppose this rule as presented. This is very important. We are not AILA or them. We will not accept this seemingly "something is better than nothing" (but in reality is nothing) regulation. Bootlickers beware of the lawyers and their language.

Here is an example from my own version (in the works right now).

Below are my initial comments upon reading the content of the proposed rule on a high level. I will also provide separate comments on the technical aspects of the rule in another submission(s), however the scope of this letter is limited to addressing the issue of what was promised and what the DHS intends to deliver with this sham regulation. I will use the word “betrayal” to describe the sentiment that the legal law-abiding skilled immigrant community is currently experiencing owing to the inability or indifference of the DHS and the Administration. Please register my comment as opposing the regulation in its current content. I do not support this regulation in its current form. Out of the many betrayals I can think of in the last year, I will only provide the two main ones.

testingtimes
01-06-2016, 01:03 PM
How do I revisit my comments?

RandomizedPrecision
01-06-2016, 01:10 PM
I see a few possibilities from here:

1. USCIS takes into account these comments, makes the changes we need (albeit grudgingly) and we all live happily everafter.

2. USCIS takes these comments into account but then the process gets stalled due to the FBI probe - they keep stalling for years or withdraw the rule altogether

2. USCIS tries to manipulate the comment review process and makes token changes that still keep everyone in permanent servitude

3. USCIS Makes no changes at all and continues to do implement the same nonsense

Considering that #1 is a tough road and all other options are completely useless I see that we have ABSOLUTELY NOTHING to lose by fighting back. The only way we get #1 is to relentless in showing these USCIS fuckfaces that we will not go down without a fight. We might not win but we can atleast maim these assholes along the way.

devndev
01-06-2016, 01:33 PM
This is important, so please pay attention.

Please do NOT submit positive comments to any degree. If they get enough positive comments, that rule is the best we are going to get.

If you say something to the effect of, "I support this rule but I want to see I-140 EAD" - they will count it as a supportive comment.

We will provide clear technical comments for support conditional on common-sense fixes like I-140 EAD.

If you are happy with the peanuts they are throwing at us, please feel free to disregard our request.


Very good point, Hill

Also any clue what the lawyer blogs are saying and the servants there are being asked to do about this rule?

DMX17
01-06-2016, 01:41 PM
Man! Some comments are not saying anything other than their personal story and how they wanted EAD card or how they want green card. Just raising comment count for nothing in my opinion. Such comments are easy to be thrown out or registered as "supporting comment".

Dear user of that tracking website:

Please make it clear that "I do not support this regulation in its current form and would like to register my opposition to the rule"

Got it? Hell make that as the first statement! Can not emphasize this enough. Guys let's educate our friends as much as we can please.

crackjack9
01-06-2016, 01:43 PM
Here is an example from my own version (in the works right now).


Great Inputs DMX !!

DMX17
01-06-2016, 01:47 PM
Great Inputs DMX !!

Thanks bud! Actually feeling good about this therapeutic opening paragraph right now :D

Below are my initial comments upon reading the content of the proposed rule on a high level. I will also provide separate comments on the technical aspects of the rule in another submission(s), however the scope of this letter is limited to addressing the issue of what was promised and what the DHS intends to deliver with this sham regulation. I will use the word “betrayal” to describe the sentiment that the legal law-abiding skilled immigrant community is currently experiencing owing to the inability or indifference of the DHS and the Administration. Please register my comments as opposing the regulation with its current content. I do not support this regulation. Out of the many betrayals I can think of in the last year, I will only provide the two main ones.

racoon786
01-06-2016, 01:48 PM
I had put about 20 comments so far, most of them starting with "I strongly OPPOSE this rule which does NOT help to retain skilled immigrants".

nvedia
01-06-2016, 01:49 PM
I had put about 20 comments so far, most of them starting with "I strongly OPPOSE this rule which does NOT help to retain skilled immigrants".

and how many got published?

arai2
01-06-2016, 01:54 PM
One important thing to raise in comments is how many people will the rule in current for benefit. If it impacts only 2-3% of all people waiting in backlog then how can it be said to benefit the highly skill immigrants who are stuck.

Bhishma
01-06-2016, 01:59 PM
When you all have a minute, please file your complaints with your allegations
https://www.oig.dhs.gov/hotline/hotline.php

They have an online form to report Report Corruption, Waste, Fraud, Abuse, Mismanagement and Misconduct to the Department of Homeland Security,
Office of Inspector General

You may also choose to name the offender or just file a complaint with your allegation.
Explore the form and choose the one that fits your allegation

Bhishma
01-06-2016, 02:49 PM
When you all have a minute, please file your complaints with your allegations
https://www.oig.dhs.gov/hotline/hotline.php

They have an online form to report Report Corruption, Waste, Fraud, Abuse, Mismanagement and Misconduct to the Department of Homeland Security,
Office of Inspector General

You may also choose to name the offender or just file a complaint with your allegation.
Explore the form and choose the one that fits your allegation

You can choose to remain anonymous when filing this complaint. Please do your best

racoon786
01-06-2016, 02:56 PM
and how many got published?

I tracked a few posted so far since there is 1-2 day delay when they get published.

DCToGC
01-06-2016, 04:01 PM
I noticed that there are two different versions of RIN 1615-AC05 on reginfo.gov

The first one published in Spring 2015 clearly talks about EAD
http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201504&RIN=1615-AC05

And second one is the latest one which is a garbage
http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201510&RIN=1615-AC05

This clearly shows that the first rule was left like that and second one was written later and published for comments.

In my comments I have asked the same question to DHS as to why is this done ?

hil3182
01-06-2016, 04:05 PM
I noticed that there are two different versions of RIN 1615-AC05 on reginfo.gov

The first one published in Spring 2015 clearly talks about EAD
http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201504&RIN=1615-AC05

And second one is the latest one which is a garbage
http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201510&RIN=1615-AC05

This clearly shows that the first rule was left like that and second one was written later and published for comments.

In my comments I have asked the same question to DHS as to why is this done ?

We think, the only thing that changed between the Spring and the Fall, was a registered lobbyist from the U.S. Chamber of Commerce - who also happens to be a decorated Immigration Lawyer (by no less of an authority than AILA) came in and bought off a bunch of people in DHS.

gblast
01-06-2016, 04:10 PM
We think, the only thing that changed between the Spring and the Fall, was a registered lobbyist from the U.S. Chamber of Commerce - who also happens to be a decorated Immigration Lawyer (by no less of an authority than AILA) came in and bought off a bunch of people in DHS.

Can I use the above statement while posting my comments? Please let me know.

hil3182
01-06-2016, 04:12 PM
Can I use the above statement while posting my comments? Please let me know.

You can post whatever you want to, so long as you don't mis-represent yourself as speaking on behalf of IV.

You can say whatever your want as either an individual or a member of IV - just not "management".

gblast
01-06-2016, 04:14 PM
You can post whatever you want to, so long as you don't mis-represent yourself as speaking on behalf of IV.

You can say whatever your want as either an individual or a member of IV - just not "management".

Thank you. That would be my personal opinion/ statement.

kmrr
01-06-2016, 04:19 PM
More evidence to this:

https://www.uschamber.com/sites/default/files/imm_subcommittee_agenda_draft_10-27-2015_final_-_v2.pdf

hil3182
01-06-2016, 04:25 PM
More evidence to this:

https://www.uschamber.com/sites/default/files/imm_subcommittee_agenda_draft_10-27-2015_final_-_v2.pdf

We spotted this earlier today - and in our view this is very inappropriate.

Our understanding is, when joining Government service there are explicit rules applicable to lobbyists surrounding contact with their previous lobbying shop - in this case a registered lobbyist is openly going back to their previous firm (or should I say real employer) a month after taking up employment at DHS - with a senior DHS official in-tow.

nutcracker1
01-06-2016, 04:27 PM
Guys,

We dont have much options to fight this proposed rule apart from comments. Proposal Comments can also be hijacked by immigration haters and lobbyists. The only way we can show our strength is by gathering as many signatures as possible to show white house how serious we are with this rule.
Keep pouring in as many signatures as possible on this petition -

REMOVED LINK TO A PETITION

Forward to as many friends as you can. This will definitely get the attention of white house and they can review the proposal before it is final.

There is already close to 100 signatures on this petition. We need about 3,333 signatures a day to meet the 100,000 target. Together we can make this WORK!!!

amit.vasp
01-06-2016, 04:28 PM
Also Check out her stat date at DHS per her Linked in Profile

https://www.linkedin.com/in/nice-amy-a70b8545

hil3182
01-06-2016, 04:34 PM
Guys,

We dont have much options to fight this proposed rule apart from comments. Proposal Comments can also be hijacked by immigration haters and lobbyists. The only way we can show our strength is by gathering as many signatures as possible to show white house how serious we are with this rule.
Keep pouring in as many signatures as possible on this petition -

REMOVED LINK TO A PETITION

Forward to as many friends as you can. This will definitely get the attention of white house and they can review the proposal before it is final.

There is already close to 100 signatures on this petition. We need about 3,333 signatures a day to meet the 100,000 target. Together we can make this WORK!!!

I don't know how many times we need to keep repeating our-selves - petitions are fucking useless and infact - they hurt us by diverting efforts from things that will make a difference.

As of now submitting comments and turning up the heat on the lobbyist and other compromised DHS officials is the only way to get anything substantial from this rule.

We know exactly what will happen to this petition - we know who will review it and exactly what type of "polite fuck off" reply you will get back in March or April of this year - when it is too late. Additionally, not getting 100K signatures makes us look weak.

In-fact, in my view, if there had been no petitions, we might have actually had our green-cards a long time ago since many people would have actually done something meaningful instead of sitting in-front of their computers clicking away at petitions.


So, please stop posting links to petitions here.

Shourie
01-06-2016, 04:50 PM
Dear Mr. Kevin J. Cummings,

I am hereby submitting my comments to you about the “Regulation for Retention of EB-1, EB-2, and EB-3 Immigrant Workers and Program Improvements Affecting Highly-Skilled Nonimmigrant Workers”
At the very outset I would like to make you aware that I have very profound admiration for the sense of humor that the USCIS staff which drafted the rules.
Also, I find it extremely funny that all the creativity exhibited by the DHS while making regulations for illegal immigrants by coming up with DREAM, DACA, DAPA and such catchy names somehow disappears as soon as it comes to regulations for legal immigrants.
There is a long and convoluted process in legal immigration petitions which will repeat itself whenever you change your job. For a legal immigrant with an approved immigrant petition in addition to relocation, you have to worry about starting a convoluted process again.
Contrast that with an illegal immigrant who has been here the same time as you have been. That illegal immigrant has a whole myriad number of bills/regulations, the gorgeous Eva Longoria, sympathy of millions of people, politicians, president which will practically ensure that he/she is not sent home unless he wants to. I am not sure that even after he wants to go home, he will be allowed to in some cases.
To pull out an analogy for legal and illegal immigrants, imagine two runners in a 100m (330 ft.) running race. The illegal runner has a straight, flat and hard track with minor hurdles and the legal immigrant has to run in a quicksand, an absurdly undulating track, sprinkled with minefields and if he falters anywhere in between, he starts all over again or get disqualified.
But then someday, the President who realizes that he has to act for the amelioration of the illegal immigrants announces executive actions for them. And just to make sure that the already battered legal immigrants who have been paying taxes all along their stay in the US don’t feel left out gives them some kind of an afterword. The executive actions for the legal immigrants technically meant “Providing portable work authorization for high-skilled workers awaiting LPR status and their spouses. Under the current system, employees with approved LPR applications often wait many years for their visa to become available. DHS will make regulatory changes to allow these workers to move or change jobs more easily. DHS is finalizing new rules to give certain H-1B spouses employment authorization as long as the H-1B spouse has an approved LPR application”.
Now after almost 1 year and 2 months later the DHS comes back with a piece of regulation, which makes me laugh (mostly because I can’t cry and because I follow Murphy’s laws very religiously). Now since I know the DHS is a pretty serious office which takes legal immigration not so seriously. It is quite evident with this indignant, utterly disappointing piece of legislation they came up with for legal immigrants. I take it upon myself to propose something sensible.
Before I propose something I just wanted to ask you some questions,
•Did you hire a certain Amy Nice who was a lobbyist for US Chamber of Commerce in the middle of last year while the legislation was being drafted?
•Did she help in anyways in the drafting of this legislation?
•Was hiring her not a contravention of the terms of hiring laid down by the Obama administration
•Did you answer yes to all the questions, if yes, then proceed further, if no, then proceed further anyways, but let us get her hiring investigated by the some good professional agency like Federal Bureau of Investigation (White collar crimes division to be specific).
Now, for the proposals
1.Change the compelling reasons clause or just gut it completely – The basic requirement of a clause in a rule is that it may be put to good use sometime when required and people who it is supposed to benefit. That clause is a waste of time and energy.
2.Please understand that filing a PERM application and I-140 is not very easy. Some of the best engineers have a hard time convincing their employers to do this. Please remove the “may have to file a new immigration petition every time you change a job” clause. I know it might sound ridiculous but legal immigrants don’t have to be put through the test of fire every time they change their jobs.
3.Grant Advanced Parole and EAD to anyone with an approved I-140 and with no delay. The reason I ask this is because the illegal immigrants don’t have to prove anything much as compared to what we have to while filing for our immigration petitions. If we have paid taxes, developed technology, helped the local economy, committed time, energy and skill to this country it is only fair of us to ask that we be treated better than people who broke the immigration laws of this country.

Please tackle this a little bit more professionally do what the President had asked you to do, maybe we all be a little bit better.

kmrr
01-06-2016, 04:52 PM
We spotted this earlier today - and in our view this is very inappropriate.

Our understanding is, when joining Government service there are explicit rules applicable to lobbyists surrounding contact with their previous lobbying shop - in this case a registered lobbyist is openly going back to their previous firm (or should I say real employer) a month after taking up employment at DHS - with a senior DHS official in-tow.

oh... wait wait... if I understand correctly, you say he/she took job at DHS, drafted/contributed to the rule, resigned and rejoined the previous company? is that correct understanding...

messengerofgod
01-06-2016, 04:53 PM
Dear Mr. Kevin J. Cummings,

I am hereby submitting my comments to you about the “Regulation for Retention of EB-1, EB-2, and EB-3 Immigrant Workers and Program Improvements Affecting Highly-Skilled Nonimmigrant Workers”
At the very outset I would like to make you aware that I have very profound admiration for the sense of humor that the USCIS staff which drafted the rules.
Also, I find it extremely funny that all the creativity exhibited by the DHS while making regulations for illegal immigrants by coming up with DREAM, DACA, DAPA and such catchy names somehow disappears as soon as it comes to regulations for legal immigrants.
There is a long and convoluted process in legal immigration petitions which will repeat itself whenever you change your job. For a legal immigrant with an approved immigrant petition in addition to relocation, you have to worry about starting a convoluted process again.
Contrast that with an illegal immigrant who has been here the same time as you have been. That illegal immigrant has a whole myriad number of bills/regulations, the gorgeous Eva Longoria, sympathy of millions of people, politicians, president which will practically ensure that he/she is not sent home unless he wants to. I am not sure that even after he wants to go home, he will be allowed to in some cases.
To pull out an analogy for legal and illegal immigrants, imagine two runners in a 100m (330 ft.) running race. The illegal runner has a straight, flat and hard track with minor hurdles and the legal immigrant has to run in a quicksand, an absurdly undulating track, sprinkled with minefields and if he falters anywhere in between, he starts all over again or get disqualified.
But then someday, the President who realizes that he has to act for the amelioration of the illegal immigrants announces executive actions for them. And just to make sure that the already battered legal immigrants who have been paying taxes all along their stay in the US don’t feel left out gives them some kind of an afterword. The executive actions for the legal immigrants technically meant “Providing portable work authorization for high-skilled workers awaiting LPR status and their spouses. Under the current system, employees with approved LPR applications often wait many years for their visa to become available. DHS will make regulatory changes to allow these workers to move or change jobs more easily. DHS is finalizing new rules to give certain H-1B spouses employment authorization as long as the H-1B spouse has an approved LPR application”.
Now after almost 1 year and 2 months later the DHS comes back with a piece of regulation, which makes me laugh (mostly because I can’t cry and because I follow Murphy’s laws very religiously). Now since I know the DHS is a pretty serious office which takes legal immigration not so seriously. It is quite evident with this indignant, utterly disappointing piece of legislation they came up with for legal immigrants. I take it upon myself to propose something sensible.
Before I propose something I just wanted to ask you some questions,
•Did you hire a certain Amy Nice who was a lobbyist for US Chamber of Commerce in the middle of last year while the legislation was being drafted?
•Did she help in anyways in the drafting of this legislation?
•Was hiring her not a contravention of the terms of hiring laid down by the Obama administration
•Did you answer yes to all the questions, if yes, then proceed further, if no, then proceed further anyways, but let us get her hiring investigated by the some good professional agency like Federal Bureau of Investigation (White collar crimes division to be specific).
Now, for the proposals
1.Change the compelling reasons clause or just gut it completely – The basic requirement of a clause in a rule is that it may be put to good use sometime when required and people who it is supposed to benefit. That clause is a waste of time and energy.
2.Please understand that filing a PERM application and I-140 is not very easy. Some of the best engineers have a hard time convincing their employers to do this. Please remove the “may have to file a new immigration petition every time you change a job” clause. I know it might sound ridiculous but legal immigrants don’t have to be put through the test of fire every time they change their jobs.
3.Grant Advanced Parole and EAD to anyone with an approved I-140 and with no delay. The reason I ask this is because the illegal immigrants don’t have to prove anything much as compared to what we have to while filing for our immigration petitions. If we have paid taxes, developed technology, helped the local economy, committed time, energy and skill to this country it is only fair of us to ask that we be treated better than people who broke the immigration laws of this country.

Please tackle this a little bit more professionally do what the President had asked you to do, maybe we all be a little bit better.

Good comment. But you might want to preface it (and all future comments) with "I am writing to register my opposition to this rule in its current form", otherwise the community college para-legal scoring the comment - might put that as you being in favor of the comment.

goldengate001
01-06-2016, 04:59 PM
oh... wait wait... if I understand correctly, you say he/she took job at DHS, drafted/contributed to the rule, resigned and rejoined the previous company? is that correct understanding...

Nope. That is not what he is saying. Do re-read.

Shourie
01-06-2016, 05:18 PM
oh... wait wait... if I understand correctly, you say he/she took job at DHS, drafted/contributed to the rule, resigned and rejoined the previous company? is that correct understanding...

I don't think opposing this would be a good idea. I am not saying we shouldn't be opposing this, but let us be rational here. I know that USCIS fucked us big time, but we should also be aware that maybe this is the best we would end up with. As much as I would hate to live with it, it would be acceptable to some of my brothers and sisters and I don't want to kick the ball away from them. But yeah maybe in my next comment I would remember to preface it with a total opposition.

DMX17
01-06-2016, 05:21 PM
oh... wait wait... if I understand correctly, you say he/she took job at DHS, drafted/contributed to the rule, resigned and rejoined the previous company? is that correct understanding...

No No No, now is not the time to leave DHS. Not yet. Otherwise, who will read our comments?

kmrr
01-06-2016, 05:33 PM
Nope. That is not what he is saying. Do re-read.


Ok, my understanding was based on the bold below:

"
We spotted this earlier today - and in our view this is very inappropriate.

Our understanding is, when joining Government service there are explicit rules applicable to lobbyists surrounding contact with their previous lobbying shop - in this case a registered lobbyist is openly going back to their previous firm (or should I say real employer) a month after taking up employment at DHS - with a senior DHS official in-tow."

DMX17
01-06-2016, 05:43 PM
I don't think opposing this would be a good idea. I am not saying we shouldn't be opposing this, but let us be rational here. I know that USCIS fucked us big time, but we should also be aware that maybe this is the best we would end up with. As much as I would hate to live with it, it would be acceptable to some of my brothers and sisters and I don't want to kick the ball away from them. But yeah maybe in my next comment I would remember to preface it with a total opposition.

Make up your mind. Your post sounded like AILA blog.

Whatever good your brothers and sisters are imagining to be in the rule, those things are already given to us without this rule. Effectively, we already have the same "flexibility" even today and just adding that I-140 cannot be revoked does not change the fact that most immigrants would ask their next employer to start GC process again as soon as possible.

I don't know how many people (a very tiny fraction) would have used an employment model that he/she would continue to be in the eternal H-1B cycle using the approved I-140 and change jobs at the same time without asking to re-start GC process. Even if they did, that would be a major compromise based on "this is the best we can do with this rule". These people better not comment as I do not think they understand the root of their misery or maybe green card backlog is not a serious issue for them.

With this crap of the rule, I would want the new employer to start my GC process immediately. In this sense, I don't need this rule as before I change my job as I am already getting 3 yr extension.

The brothers and sisters ain't gonna get shit. Don't even get me started with the 60 day grace period "one-time" bonus offer.

RandomizedPrecision
01-06-2016, 05:44 PM
I don't think opposing this would be a good idea. I am not saying we shouldn't be opposing this, but let us be rational here. I know that USCIS fucked us big time, but we should also be aware that maybe this is the best we would end up with. As much as I would hate to live with it, it would be acceptable to some of my brothers and sisters and I don't want to kick the ball away from them. But yeah maybe in my next comment I would remember to preface it with a total opposition.
Oh shut the fuck up dude.. grow a pair and stop wimping all the time. Right now what might seem OK to you will soon be a monstrous trap when you find yourself roiling in this mess for another decade.

Shourie
01-06-2016, 05:47 PM
Make up your mind. Your post sounded like AILA blog.

Whatever good your brothers and sisters are imagining to be in the rule, those things are already given to us without this rule. Effectively, we already have the same "flexibility" even today and just adding that I-140 cannot be revoked does not change the fact that most immigrants would ask their next employer to start GC process again as soon as possible.

I don't know how many people (a very tiny fraction) would have used an employment model that he/she would continue to be in the eternal H-1B cycle using the approved I-140 and change jobs at the same time without asking to re-start GC process. Even if they did, that would be a major compromise based on "this is the best we can do with this rule". These people better not comment as I do not think they understand the root of their misery or maybe green card backlog is not a serious issue for them.

With this crap of the rule, I would want the new employer to start my GC process immediately. In this sense, I don't need this rule as before I change my job as I am already getting 3 yr extension.

The brothers and sisters ain't gonna get shit. Don't even get me started with the 60 day grace period "one-time" bonus offer.

I totally agree with you, that is why I said I would put my opposition from the next comment onward.

DMX17
01-06-2016, 05:49 PM
I totally agree with you, that is why I said I would put my opposition from the next comment onward.

We are cool! Bring those brothers and sisters to their senses.

hil3182
01-06-2016, 05:50 PM
Good comment. But you might want to preface it (and all future comments) with "I am writing to register my opposition to this rule in its current form", otherwise the community college para-legal scoring the comment - might put that as you being in favor of the comment.

Good idea. I am going to do that will all my comments going forward - to make sure there is no ambiguity about where I stand on this turd.

Ok, my understanding was based on the bold below:

"
We spotted this earlier today - and in our view this is very inappropriate.

Our understanding is, when joining Government service there are explicit rules applicable to lobbyists surrounding contact with their previous lobbying shop - in this case a registered lobbyist is openly going back to their previous firm (or should I say real employer) a month after taking up employment at DHS - with a senior DHS official in-tow."

I meant "visited". To the best of my knowledge, this lobbyist is still in the employ of DHS.

Oh shut the fuck up dude.. grow a pair and stop wimping all the time. Right now what might seem OK to you will soon be a monstrous trap when you find yourself roiling in this mess for another decade.

My sentiments exactly.

RandomizedPrecision
01-06-2016, 05:54 PM
I totally agree with you, that is why I said I would put my opposition from the next comment onward.
Please do. This "Something is better than nothing" attitude has to change. The folks stuck in backlogs have to realize that this attitude is what got us here in the first place and this asinine rule is worse than "Something".

It takes away more than it gives - it takes away our only chance in what might be another decade to get this system less suffocating to people who just want to not get tethered to the same employer for decades.

Shourie
01-06-2016, 05:56 PM
We are cool! Bring those brothers and sisters to their senses.

You are kidding me right ! They won't, they think that this is the second Miracle happening to them after Moses spread the fucking red sea.

People are more concerned about how they can squeeze the most out of the peanut they have been given.

Shourie
01-06-2016, 05:59 PM
Please do. This "Something is better than nothing" attitude has to change. The folks stuck in backlogs have to realize that this attitude is what got us here in the first place and this asinine rule is worse than "Something".

It takes away more than it gives - it takes away our only chance in what might be another decade to get this system less suffocating to people who just want to not get tethered to the same employer for decades.

I agree man. Just like you guys but certainly not as intensely as the IV people, I am doing what ever is possible from my side.

pappu
01-06-2016, 06:22 PM
Please spread this advice

Comments should have the first sentence in your own words that says something like - "I am writing to register my opposition to the rule in its current form". That way DHS absolutely cannot score it as a positive comment.

right2niru
01-06-2016, 06:41 PM
Please spread this advice

Comments should have the first sentence in your own words that says something like - "I am writing to register my opposition to the rule in its current form". That way DHS absolutely cannot score it as a positive comment.

Submitted comment again with own words in the comments box .
New tracking # 1k0-8n8n-px87 , not sure how long does it take before showing up in comments .

DMX17
01-06-2016, 08:00 PM
For those who want to practice anger management, read the Regulatory Impact Analysis on the rule (looks like posted or updated yesterday).

Regulations.gov (http://www.regulations.gov/#!docketDetail;D=USCIS-2015-0008)

So they did all this work to estimate the "maximum" number of people and made wild assumptions and then throw in the below thing for their employer buddies ;)

Finally, DHS does not anticipate that a significant number of nonimmigrant workers with approved EB-1, EB-2 or EB-3 petitions will be able to demonstrate compelling circumstances justifying an independent grant of employment authorization. Employment authorization based on compelling circumstances, for example, will not be available to a nonimmigrant worker solely because his or her statutory maximum time period for nonimmigrant status is approaching or has been reached. Likewise, employment authorization generally would not be available to a nonimmigrant if the tendered compelling circumstance is within his or her control.

Therefore, DHS considers these volume estimates as maximum estimates that overstate the actual numbers of individuals who would apply for unrestricted employment authorization under this proposed rule. While DHS is not able to estimate a percentage or number of the maximum pool of possible applicants that might seek such employment authorization, DHS does not expect that a significant percentage of principal beneficiaries will take advantage of the proposed amendment to obtain unrestricted employment authorization, and, by extension, DHS does not expect a significant percentage of dependents will apply for employment authorization.

Tarang
01-06-2016, 08:08 PM
Why this farce of 181 pages when they already know significant majority of immigrant workers and their dependents will not benefit from it?

HumHongeKaamyaab
01-06-2016, 08:10 PM
My comment posted on DHS website today...pasting it below...the THIRD word in my response was REJECT...I have been putting in differently worded comments but with the similar REJECTION theme apparent in the first sentence...comments are above 4000 now... KEEP COMMENTING EVERYONE!!! THIS IS SPARTA!!!!!!!!

I completely REJECT this rule in its current form and would like to request an official FBI enquiry into why everything that was discussed and rediscussed with the LEGAL imigrant community was removed from the final rule based on hiring lobbyists at the DHS inspite of Mr. Obama's Executive Order on Ethics Committments that state that no lobbyist will be appointed for a period of 2 years from the date of their appointment at specific private companies and parties.

The legal immigration community has reason to believe that unethical practices took place behind closed doors to limit and severely restrict legal immigrants' rights from them. The mafia like network that operates behind closed doors needs to be exposed and thus, I call for an immediate FBI enquiry.

The current system has mutated to enslave H1B workers by locking them into one company through a physically and emotionally draining process of having to restart the green card process everytime they want to change jobs, which leads to reduced bargaining power of the H1B employee, leading to reduced wages for these H1B employees and most significantly, the eventual depression of wages for the AMERICAN WORKER. H1B workers stand WITH the American workers NOT against. The corporate greed and lawyer and LOBBYIST's networking power works against a regular person with limited access to money. This is a perversion of the intent of the system and it disgusts me to my core. I am ashamed that I moved to the US when my friends in Canada and Australia mock me for the lack of freedom I have living in supposed 'the land of the free'.

I first came to the US in 2004 to pursue a masters in science degree. I will have to wait until 2025 in the current situation to be able to BE CURRENT with my priority date. Why this 21 year wait for me and my family for following rules and paying taxes LEGALLY??? Why am I being punished for doing the RIGHT THING?

In my current situation, I have had to pass over multiple opportunities with higher wages (Upto 40% increase) and more responsibilities because the hiring firm did not want to go through the hassle of filing PERM and I-140 for me after 6 rounds of interviews!! What if I had an EAD in this situation as was discussed through this rule? I have a masters in science degree and used up my OPT after that. I have been wanting to do an MBA for the last 8 years, but because your rules DO NOT grant an OPT for the same education level, I have been unable to pursue this second master's degree. I cannot wait for H1B after my MBA as school ends in May and H1B starts in October of the next fiscal year creating a gap employers dont want to deal with. What if I had an EAD/Green Card in this situation? I would have earned an MBA and started a company employing AMERICAN workers, paying AMERICAN wages. This example is at the heart of how restrictive the rules are and how they curb an immigrants' ambitions. Please afford us freedom in the form of PORTABILITY and Advanced Parole. In another instance, I had to interface with a client in Canada but could not travel as I do not have a valid visa for re-entry and for which I have to go back to my home country! Ridiculous.

Your rules are regressive and way behind the times compared to the rest of the world. Raise your head and please look at what other countries are doing to make it a compelling case for us immigrants to move there. Your rules are emotionally crushing. Your ways are perverted to feed corporate greed. According to Senate's lobbying disclosure website, a specific top registered lobbyist for US Chamber of Commerce was related to lobbying or political contributions of over $395 million since 2011. With that standard, this is the top industry registered lobbyist that has lobbied for many years on behalf of companies to push for their agenda which works against the AMERICAN WORKER AND the H1B worker.

1- WE WANT AN FBI EQUIRY INTO THIS MATTER.
2- WE WANT THE AMERICAN PEOPLE TO KNOW THAT WE ARE ABUSED DUE TO THE STATUS QUO WHICH IN TURN HURTS THE AMERICAN WORKER AND LEADS TO DEPRESSED WAGES.
3- WE WANT JOB MOBILITY SO WE CAN LIVE OUR LIVES, BUY HOUSES AND LIVE IN FREEDOM.
4- MAKE THIS RIGHT PER Mr. OBAMA'S OBJECTIVES SET THROUGH EXECUtiVE ACTION.
5- WE WANT ADVANCED PAROLE SO WE CAN TRAVEL FOR WORK INTERNAIONALLY.

See attached for more comments that I support.

Thank you

greenappletx
01-06-2016, 08:46 PM
IV,

As you advised, many of us are posting the negative (rejecting) about rule. What will happen when we have more negative comments? How this rule get affected? Will they rework on this rule with modification to include EAD+AP or stop this rule?
As some benefits like 1. 60 day grace period 2. Employer can't the I140 revoke after 180 days 3. Extn based on the I140 etc we might loose if they do nothing.

Obviously, you know more than me/us, hence pls suggest. Thanks

kmrr
01-06-2016, 09:08 PM
Immigration Lawyers are silent after seeing USCOC and DHS meeting- details being out now... not even responding on that..

As Aman mentioned, these lawyers are lying and playing behind the scenes to screw the backlogged community more.

Rakesh Bhandari
01-06-2016, 09:11 PM
IV,

As you advised, many of us are posting the negative (rejecting) about rule. What will happen when we have more negative comments? How this rule get affected? Will they rework on this rule with modification to include EAD+AP or stop this rule?
As some benefits like 1. 60 day grace period 2. Employer can't the I140 revoke after 180 days 3. Extn based on the I140 etc we might loose if they do nothing.

Obviously, you know more than me/us, hence pls suggest. Thanks

Launched an enquiry against Amy Nice at DHS office of inspector general using this website: https://www.oig.dhs.gov/hotline/hotline.php

There should a federal investigation against her and everyone who is involved in this scam.

Not only Amy, Greg Siskind should also be reported to FBI and DHS anti-fraud devision for his inflamatory comments on twitter against indian and chinese people.

Look at how he is making fun of our misery on regulations.gov in the comment -

Regulations.gov (http://www.regulations.gov/index.jsp#!documentDetail;D=USCIS-2015-0008-0968)

Urging all the H1B slaves to report these lobbyists from AILA to the authorities so that they can be thrown behind bars.

greenappletx
01-06-2016, 10:06 PM
IV,

Regulations.gov (http://www.regulations.gov/#!documentDetail;D=USCIS-2015-0008-0937)

Just found the above comment, it says that it is by Aman Kapoor, is that our (IV's) Aman Kapoor or someone else? I see Aman supports some points. Please confirm.

hil3182
01-06-2016, 10:08 PM
IV,

Regulations.gov (http://www.regulations.gov/#!documentDetail;D=USCIS-2015-0008-0937)

Just found the above comment, it says that it is by Aman Kapoor, is that our (IV's) Aman Kapoor or someone else? I see Aman supports some points. Please confirm.
No its just some lowlife idiot.

mgmanoj
01-06-2016, 10:48 PM
1k0-8n8r-inf9

Done

thokkalohdi
01-06-2016, 10:54 PM
"are you on H1-B".. i am going to ask people infornt of other citizens.. if he is a "slave". And i propose.. always use the word slave.. and not "h1b non-immigrant worker".

And if IV can sell badges that says "i am a slave" i want to buy it and wear it to work, so that others are aware of what is going on and raise it in their meetings or discussions on immigration.

grave circumstances will require extra ordinary actions. And we need to raise up now...

greenappletx
01-06-2016, 11:10 PM
Submitting around 15-30 comments every day in line with IV. Asking my team to stay more time and complete this task :-)

VinayJ
01-06-2016, 11:40 PM
I have so far posted many comments in different form from the day comment period started for FBI investigation.however I don't see any of the comments showing up so far. Is USCIS is filtering and removing those comments?

racoon786
01-06-2016, 11:52 PM
Guys,

We dont have much options to fight this proposed rule apart from comments. Proposal Comments can also be hijacked by immigration haters and lobbyists. The only way we can show our strength is by gathering as many signatures as possible to show white house how serious we are with this rule.
Keep pouring in as many signatures as possible on this petition -

REMOVED LINK TO A PETITION

Forward to as many friends as you can. This will definitely get the attention of white house and they can review the proposal before it is final.

There is already close to 100 signatures on this petition. We need about 3,333 signatures a day to meet the 100,000 target. Together we can make this WORK!!!

douche

sfben
01-07-2016, 12:17 AM
For those who wanna learn more about how lobbying works in Washington and how a rule like I-140 EAD can be killed/watered down by Employer community(Chamber of Commerce), there is a youtube video that explains it

https://www.youtube.com/watch?v=CHiicN0Kg10

maddy1234
01-07-2016, 01:22 AM
Dear Mr. Cummings,

I completely oppose the proposed rule in its current form.

I have been in this country for more than 8 years and I am waiting in the GC backlog for many years now ..

The proposed rule does not comply with the intentions of Mr. Obama's executive action on Immigration, as it is only beneficial to the 1% of the whole EB community . I think it is better not to waste DHS & all the stakeholder's time in creating something that is not useful.

I feel like I am being treated as a slave to my Employer as he continuously exploits my current dependency on him as a bonded labor. I have been working for the same employer for more than 6 years and I cannot change jobs/advance in my career as new employers do not want to go through the hassle of filing a PERM or sponsoring a H1B.

I think it makes no sense that there are more restrictions on a LEGAL LAW ABIDING TAX PAYING HIGH SKILLED IMMIGRANT to get an EAD/AP with an approved LPR than an ILLEGAL immigrant through programs like DACA/DAPA . I hope you guys do understand it is counter-productive to American economy and American Citizens as a bonded H1B worker is more attractive at a lower wage than an American Citizen. Number of workers that are on H1B is inversely proportional to wage inflation, which has been one of the biggest issue in today's economy.

This non-freedom for an high skilled immigrant also keeps the potential new businesses from getting started, undermining the creativity & new job growth in the US.

I would also like to know why the rule has be deviated from the initial proposal/draft within the last few months, specifically starting Sep 2015?

Are there any lobbyists involved in driving the changes so the proposed rule would keep the interests of immigration lawyers and employers in check and make the legal immigrant employee be in the H1B HYPERLOOP for ETERNITY and live in constant fear ?

I think an investigation by FBI would make sense in understanding of what has all happened in drafting this rule.

I do sincerely hope you guys consider changing the proposed rule, so that a Legal immigrant with approved LPR would get an EAD/AP without any "Compelling Reasons & 1 Year cut off limit on Priority Date" nonsense .

Lets work together for better world....!!!!

Your Comment Tracking Number: 1k0-8n8t-bylg

RandomizedPrecision
01-07-2016, 10:09 AM
I have so far posted many comments in different form from the day comment period started for FBI investigation.however I don't see any of the comments showing up so far. Is USCIS is filtering and removing those comments?
Mine have started showing up with the FBI language. So keep at it. Good luck to all of us!

gopal008
01-07-2016, 10:24 AM
I sent few about asking for EAD and AP and FBI. Looks FBI comments are showing up now. Lets put mroe comments. It is ridiculous we have huge indian people waiting for green card but I see only 4000 comments. The outreach seems to be very limited.

bajajpulsar
01-07-2016, 10:52 AM
Sounds like a good idea to register the complaint with the DHS OIG. Another place we can vent our frustration at, with the hope that it turns the heat on for the lobbyist.

What is IV board's opinion?

Launched an enquiry against Amy Nice at DHS office of inspector general using this website: https://www.oig.dhs.gov/hotline/hotline.php

There should a federal investigation against her and everyone who is involved in this scam.

Not only Amy, Greg Siskind should also be reported to FBI and DHS anti-fraud devision for his inflamatory comments on twitter against indian and chinese people.

Look at how he is making fun of our misery on regulations.gov in the comment -

Regulations.gov (http://www.regulations.gov/index.jsp#!documentDetail;D=USCIS-2015-0008-0968)

Urging all the H1B slaves to report these lobbyists from AILA to the authorities so that they can be thrown behind bars.

nvedia
01-07-2016, 11:05 AM
I sent few about asking for EAD and AP and FBI. Looks FBI comments are showing up now. Lets put mroe comments. It is ridiculous we have huge indian people waiting for green card but I see only 4000 comments. The outreach seems to be very limited.
Dont' be discouraged as long as you are doing your part by telling your colleagues and neighbors by spreading the word
Most people don't know about immigration voice, how these rules work, and if they can actively participate in the whole process so spreading the knowledge helps

skrovvidi
01-07-2016, 11:50 AM
Despicable ,Detrimental, Dirty, Disease, Disgusting, Disheveled, Dishonest, Dishonorable, Dismal: This is how I would define this rule that USCIS/DHS pulled out of thin air disregarding president Obama's EO reforms.

Looks like Big Business lobbying efforts($$$) paid off and sabotaged President Obama's reform.

This proposed rule works only for the Employers and of course the Lawyers get paid a ton of money for the additional paper work(ka-ching).
Guess we'll see many more Immigration lawyers become Millionaire and Billionaires!

The legal highly skilled Immigrants gets left out high and dry as usual and has to go through a maze of new rules( more paperwork + long processes) to achieve the American dream( LPR + Citizenship).

Immigration Trivia: Did you know it take on an average 30-50 years for a Legal Immigrant from China/India abiding by the rules and regulations of US constitution to become a Citizen of this great country?

All Legal Immigrant go through an excruciatingly painful obsolete US Immigration process during their 30-50 years of living in the States, so we requested the Obama Administration to give us much needed flexibility
for career progression/better companies. DHS/USCIS want us to be bonded to US employers via H1B / 140 petition and hands over the keys to them.

hil3182
01-07-2016, 12:11 PM
Here is the first comment I banged out today. I will continue tweaking and re-submitting. 1k0-8n94-o1ad

Dear Kevin,

I am writing to register my OPPOSITION to this rule - as an EB3 Immigrant Worker.

The core issue EB–1, EB–2, and EB–3 workers are facing, while waiting for a visa number number to become available - is unhealthy and unnatural dependence on the employer - and this ridiculous 180 page regulation does absolutely nothing to make the employee independent of the employer.

DHS has the authority to issue EAD and Advance Parole to EB–1, EB–2, and EB–3 workers with approved immigration petitions stuck in these backlogs, while making sure they move through the immigration process as priority dates become available and not requiring redundant re-filing of Labor certifications/I-140. DHS can continue issuing EAD's until the eventual adjudication of their I-485 application - without insisting on "Compelling Circumstances" or putting any artificial restrictions on their career and personal growth.

In fact, the above was the intent behind the President's Executive order in November 2014, when he ordered a modernization of the Legal Immigration System. No other modern western industrialized country keeps legal immigrants in an extended state of Visa limbo or treats them like indentured servants like the United States does.

Additionally, creating a two tiered class system of workers in the American Labor market creates incentives for employers to prefer hiring workers with less rights - i.e. workers on H1-B visa's as opposed to American workers. Companies underpay their American workers by using the implicit threat of replacing them with lower paid guest workers on H1-B (and L1) visas. Companies have lobbied very hard to create, preserve and protect this two tiered class system of workers.
As mentioned above, the root cause of this abuse by Companies on all workers (guest and domestic) in the American Labor market is the unhealthy and long-term dependence of immigrant workers on their employer. Also, Companies have lobbied very hard to create and maintain this system. I think that we all know that the U.S. Chamber of Commerce is the premier lobbying entity for Corporations that do business in the United States.

Given how hard Companies have worked to maintain this system and how much they benefit from the lack of job mobility with their H1-B workers, I have the following fair and reasonable questions for you about THE former top Immigration lobbyist from the U.S. Chamber of Commerce - who joined DHS in September 2015. I want to know:
1. Why the lobbyist was allowed join DHS right after leaving the Chamber of Commerce without a cool-off period?
2. Why was this lobbyist allowed to work on the exact same Regulations - whose job required them to lobby on - quite literally the week before they joined DHS.
3. Why did this lobbyist and a senior DHS official visit the U.S. Chamber of Commerce shortly after the lobbyist joined DHS? Is such contact between the lobbyist and their former employer appropriate? Is it legal? Proof of this visit can be found in the following link: https://www.uschamber.com/sites/default/files/imm_subcommittee_agenda_draft_10-27-2015_final_-_v2.pdf

Given the strong hint of impropriety (not to mention that the rule directly contravenes a Presidential Executive order), I would also like to request an FBI investigation into the process that went into the drafting of this rule, namely if promises of employment (or other enticements) were made to DHS employees by the U.S. Chamber of Commerce. Additionally, I think it only fair that the FBI keep track of the careers of other employees associated with the drafting of this rule and see if any of them end up at the U.S. Chamber of Commerce or related entities when the current Administration demits office.

nutcracker1
01-07-2016, 12:35 PM
douche

Son of a Douchebag

gulute
01-07-2016, 12:45 PM
Here is the first comment I banged out today. I will continue tweaking and re-submitting. 1k0-8n94-o1ad

Done - 1k0-8n95-1e3y

hil3182
01-07-2016, 12:46 PM
It is very important to get the word out, that people explicitly "Reject" the Rule in the first line of all comments - or DHS might score it as a positive comment and we will not get the changes we want.

Bhishma
01-07-2016, 12:54 PM
I encourage everyone to report this horrible person who was a former lobbyist and a current DHS employee who jeopardized lives of millions of law abiding skilled
immigrants.

Please report to
DHS OIG at
https://www.oig.dhs.gov/hotline/hotline.php

Also, this person has either not disclosed all information to a federal investigation officer at OPM who conducts background investigation for Security Clearance for
DHS. This is a crime and this person can be charged for lying or not disclosing information leading to a decision on her Security Clearance background investigation.

Please report to OPM also. In my honest opinion, it is OPM who is more responsible for this investigation than FBI

devndev
01-07-2016, 01:18 PM
I do not support this regulation in its current form and would like to register my opposition to the rule.. Please reinstate the provisions that our President originally intented to provide relief to the backlogged EB community

I strongly urge you to update the proposed rule to accomodate the following:

1. EAD's should be issued to all the approved I-140 holders with advance parole. There should be no compelling circumstances clause. Being stuck in the visa back log for years in itself is a compelling circumstance.

2. Job portability: An I-140 approved petition holder should not have to re-start PERM/I-140 after change of employment. This would be real job portability. Anything else is a step-backward.

3. EAD Renewal - There should be no condition of 1 year difference between priority date and visa cut-off date. This puts the EAD holder in jeopardy due to uncertainty in the visa cut-off dates. EAD's should be renewed automatically in 3 years increments when an extension has been filed.

4. Conduct an investigation of how this regulation changed from its original form in the last few months and any involvement of lobbyists and corruption

hil3182
01-07-2016, 01:36 PM
Tweaked the last one slightly to avoid being flagged as a dupe 1k0-8n96-ee5x

Dear Kevin,

As an EB3 Immigrant worker, I am writing to OPPOSE this rule.

The core issue Immigrant workers stuck in long backlogs are facing,- is unhealthy and unnatural dependence on the employer - and this 180 page regulation does absolutely nothing to make the employee independent of the employer.

DHS has the authority to issue EAD and Advance Parole to Immigrant workers with approved immigration petitions stuck in these backlogs, while making sure they move through the immigration process as priority dates become available and not requiring redundant re-filing of Labor certifications/I-140. DHS can continue issuing EAD's until the eventual adjudication of their I-485 application - without insisting on "Compelling Circumstances" or putting any artificial restrictions on their career and personal growth.

In fact, the above was the intent behind the President's Executive order in November 2014, when he ordered a modernization of the Legal Immigration System. No other modern western industrialized country keeps legal immigrants in an extended state of Visa limbo or treats them like indentured servants like the United States does.

Additionally, creating a two tiered class system of workers in the American Labor market creates incentives for employers to prefer hiring workers with less rights - i.e. workers on H1-B visa's as opposed to American workers. Companies underpay their American workers by using the implicit threat of replacing them with lower paid guest workers on H1-B (and L1) visas. Companies have lobbied very hard to create, preserve and protect this two tiered class system of workers.

Given how hard Companies have worked to maintain this system and how much they benefit from the lack of job mobility with their H1-B workers, I have the following fair and reasonable questions for you about THE former top Immigration lobbyist, formerly in the employ of the TOP Corporate lobbying organization, the U.S. Chamber of Commerce - who joined DHS in September 2015. I want to know:
1. This IMMIGRATION lobbyist was allowed to write regulations on IMMIGRATION in DHS. Why was this lobbyist allowed to write regulations on a subject they were lobbying on literally until the week before they joined DHS?
2. Why the lobbyist was allowed join DHS right after leaving the Chamber of Commerce without a cool-off period?
3. Why did this lobbyist and a senior DHS official visit the U.S. Chamber of Commerce shortly after the lobbyist joined DHS? Is such contact between the lobbyist and their former employer appropriate? Is it legal? Proof of this visit can be found in the following link: https://www.uschamber.com/sites/default/files/imm_subcommittee_agenda_draft_10-27-2015_final_-_v2.pdf

Given the strong STINK of impropriety (not to mention that the rule directly contravenes a Presidential Executive order), I would like to humbly and respectfully request an FBI investigation into the process that went into the drafting of this rule, namely if promises of employment (or other enticements) were made to DHS employees by the U.S. Chamber of Commerce. I also would like to request that the FBI probe the visit where the Lobbyist and the senior DHS official visited the U.S. Chamber of Commerce. Additionally, I think it only fair that the FBI keep track of the careers of other employees associated with the drafting of this rule and see if any of them end up at the U.S. Chamber of Commerce or related entities when the current Administration demits office.

sengs
01-07-2016, 01:38 PM
I think it is a great idea to paste a copy of your submission here, just like hil3182 did. We can mix and match and create lots of unique comments from the repertoire.

Whatever you do, begin your comments explicitly mentioning that- I REJECT this proposed rule

RH_93
01-07-2016, 01:50 PM
It is very important to get the word out, that people explicitly "Reject" the Rule in the first line of all comments - or DHS might score it as a positive comment and we will not get the changes we want.

Hi hil....question - how is it that this rule has been approved by the OMB? The OMB sits within the White House and if what's proposed is not aligned to the President's vision the OMB will not approve it but they have....That being the case, what gives? Why has the OMB approved this rule that even remotely does not match what the president mentioned in his stump for EO? We have been sold for cheap in the barter that's happened....and the WH approves this. Comments?

sengs
01-07-2016, 01:53 PM
OMB has not approved the rule. It has approved the proposed rule to be published for comments by stakeholders. Please comment on this version of the rule, and send it back to DHS for good.

hil3182
01-07-2016, 01:53 PM
Hi hil....question - how is it that this rule has been approved by the OMB? The OMB sits within the White House and if what's proposed is not aligned to the President's vision the OMB will not approve it but they have....That being the case, what gives? Why has the OMB approved this rule that even remotely does not match what the president mentioned in his stump for EO? We have been sold for cheap in the barter that's happened....and the WH approves this. Comments?

We have the sold down the river and the WH either - didn't think we were worth fighting for or people in the WH were bought too. There is no doubt that they knew what was going on.

Either way, if we stay quiet, nothing is going to happen. They thought we would stay quiet and be thankful for the peanuts they threw at us - we need to upset that calculation.

RH_93
01-07-2016, 01:58 PM
We have the sold down the river and the WH either - didn't think we were worth fighting for or people in the WH were bought too. There is no doubt that they knew what was going on.

Either way, if we stay quiet, nothing is going to happen. They thought we would stay quiet and be thankful for the peanuts they threw at us - we need to upset that calculation.

Got you..thanks much !

Shourie
01-07-2016, 02:00 PM
We have the sold down the river and the WH either - didn't think we were worth fighting for or people in the WH were bought too. There is no doubt that they knew what was going on.

Either way, if we stay quiet, nothing is going to happen. They thought we would stay quiet and be thankful for the peanuts they threw at us - we need to upset that calculation.

Pardon my unawareness, but out of curiosity I was wondering is there a precedent where the DHS or whatever dumbfuck agency has produced this garbage would change it solely based on the comments.

hil3182
01-07-2016, 02:00 PM
Got you..thanks much !

You are welcome. Please comment on the rule and start every comment with a firm and clear rejection of the rule.

If you aren't explicit about your rejection, the slime-balls might mark your comment as being a positive comment.

skal
01-07-2016, 02:04 PM
I completely OPPOSE the proposed rule in its current form.

dvsj
01-07-2016, 03:11 PM
If this helps framing comments -

Labor market impacts - Finally, DHS assumes that the proposed rule may negatively impact some U.S. employers who sponsor workers for employment-based immigrant visas, primarily through higher rates of employee turnover due to accepting offers of employment with other employers. Employers incur costs by filing an employment-based immigrant visa petition on an employee’s behalf when seeking to sponsor that employee for lawful permanent residence. However, employers may view the costs associated with sponsoring an employee as a tangible investment in the company. At the same time, if the principal beneficiary of the immigrant visa petition pursues unrestricted employment authorization under this rule and changes employers, the petitioning employer could incur some turnover costs. Consequently, increased rates of employee turnover may occur as certain nonimmigrant workers pursue unrestricted employment authorization.

Benefits - The finalized rule would grant a newly created benefit of permitting certain nonimmigrant workers who face compelling circumstances, as well as their dependents, to apply for unrestricted employment authorization. The ability to obtain these employment authorizations increases incentives to nonimmigrant workers who have begun the process of becoming LPRs and find themselves under difficult circumstances to remain in and contribute to the U.S. economy as they complete the LPR process. The lengthy timeframes and lack of flexibility in the process of becoming an LPR can be discouraging and drive many high-skilled nonimmigrant workers to abandon their pursuit of permanent status. The unrestricted employment authorizations are an attractive benefit in retaining these high-skilled workers as they wait to become LPRs, especially when those workers are faced with compelling circumstances that might otherwise cause them to abandon their efforts. These EADs allow such high-skilled workers to continue to progress in their careers by allowing flexibility in accepting offers of employment, with their current employer or with a new employer, while maintaining their position in the queue for visa availability. Retaining these high-skilled nonimmigrant workers who intend to become LPRs is important when considering the contributions of these individuals to the U.S. economy, including advances in entrepreneurial, research and development endeavors. Moreover, the ability to pursue new career choices does not eliminate the requirement for such workers to have a new employer petition on his or her behalf for permanent employment.

Toadie
01-07-2016, 03:16 PM
Tweaked the last one slightly to avoid being flagged as a dupe 1k0-8n96-ee5x

So Did I.

Dear Mr. Kevin,

I am writing to show my strong REJECTION to this rule in it's current format.

The basic plight of an Highly Skilled Worker is that he is stuck in long backlogs caused by multiple reasons- per country quota limit, agency's incompetence to utilize all visas over the years; causing dependence on employer, thus forfeiting any natural career progression and ability to start own business and possibly employ US Citizens. This 180 page rule does nothing to circumvent this, as it was intended initially in President's Executive Order.

DHS has the authority to issue EAD and Advance Parole to Immigrant workers with approved immigration petitions (I-140) stuck in these backlogs, while making sure they move through the immigration process as priority dates become available and not requiring redundant re-filing of Labor certifications/I-140 and thus helping grow in career, switch employers at will. DHS can continue issuing EAD's until the eventual adjudication of their I-485 application. This, being anchored to a single employer, can be relieved.

In fact, the above was the intent behind the President's Executive order in November 2014, when he ordered a modernization of the Legal Immigration System. No other modern western industrialized country keeps legal skilled immigrants in such a matrix of unreality and treats them like indentured servants like the United States does.

This also creates a classifications of workers in same field. Ones who have limited rights and others who are US citizens. This entices US employers to exploit both classes; keeping US citizen workers accept lower rates of wages in fear of being replaced by H1Bs. And immigrant workers being pressurized to work at lower rates by limiting their rights to move around in jobs. This is a great motivational factor for employers to not allow immigrant employees to have freedom to switch jobs as it builds up their bottom line.

Given how hard Companies have worked to maintain this system and how much they benefit from the lack of job mobility with their H1-B workers, I have the following fair and reasonable questions for you about THE former top Immigration lobbyist, formerly in the employ of the TOP Corporate lobbying organization, the U.S. Chamber of Commerce - who joined DHS in September 2015. I want to know:
1. Why this IMMIGRATION lobbyist was allegedly allowed to write or influence regulations on IMMIGRATION in DHS, swaying the original intent of regulation in a way that does not conform to The President's EO at all.
2. Why the lobbyist was allowed join DHS right after leaving the Chamber of Commerce without a cool-off period?
3. Why did this lobbyist and a senior DHS official visit the U.S. Chamber of Commerce shortly after the lobbyist joined DHS? Is such contact between the lobbyist and their former employer appropriate? Is it legal? Proof of this visit can be found in the following link: https://www.uschamber.com/sites/defa...final_-_v2.pdf

With this conflict of interest, I would like to request an FBI investigation into the process that went into the drafting of this rule, namely if promises of employment (or other enticements) were made to DHS employees by the U.S. Chamber of Commerce. I also would like to request that the FBI probe the visit where the Lobbyist and the senior DHS official visited the U.S. Chamber of Commerce. Additionally, I think it only fair that the FBI keep track of the careers of other employees associated with the drafting of this rule and see if any of them end up at the U.S. Chamber of Commerce or related entities when the current Administration demits office.

hopein2015
01-07-2016, 03:24 PM
Looks like someone communicated about the meeting link to chamber of commerce. Page from the link got removed.

hopein2015
01-07-2016, 03:34 PM
Found this. Please check "Adjustment of Status Applcations" part

Regulations.gov (http://www.regulations.gov/#!documentDetail;D=DHS-2011-0015-0028)

gulute
01-07-2016, 03:36 PM
Looks like someone communicated about the meeting link to chamber of commerce. Page from the link got removed.

PDF is attached.

skywalker
01-07-2016, 03:39 PM
No the link is still alive.

https://www.uschamber.com/sites/default/files/imm_subcommittee_agenda_draft_10-27-2015_final_-_v2.pdf

But I think it is a good idea to save the evidences just in case ;-)

hopein2015
01-07-2016, 03:40 PM
Okay,may be the other post from someone had the wrong link.

goldengate001
01-07-2016, 03:52 PM
Found this. Please check "Adjustment of Status Applcations" part

Regulations.gov (http://www.regulations.gov/#!documentDetail;D=DHS-2011-0015-0028)

Hmm. Does not make sense to me. May be shedding crocodile tears?
Mod, you guys have an explanation?

hopein2015
01-07-2016, 04:00 PM
Hmm. Does not make sense to me. May be shedding crocodile tears?
Mod, you guys have an explanation?
That was from 2011 though.

hopein2015
01-07-2016, 04:02 PM
Hi Hill,

How can we let WH know that we are not happy with the proposed rules? How about flower campaign on Feb 29th?

hil3182
01-07-2016, 04:11 PM
Hmm. Does not make sense to me. May be shedding crocodile tears?
Mod, you guys have an explanation?

This is bullshit. Asking for this in 2011 is like asking for Dependent Exemption and Recapture in 2014 - just not going to happen.

Also, since she sent the comments in, why didn't she just do the fix in 2015 - when she spent 2 months writing the Reg - or should I say re-writing the Reg?

Toadie
01-07-2016, 04:14 PM
Hi Hill,

How can we let WH know that we are not happy with the proposed rules? How about flower campaign on Feb 29th?

1. White House knows what went down.
2. White House knows that we're not happy.
3. Flower campaign? we know how that went.

hate_me
01-07-2016, 04:22 PM
We have the sold down the river and the WH either - didn't think we were worth fighting for or people in the WH were bought too. There is no doubt that they knew what was going on.

Either way, if we stay quiet, nothing is going to happen. They thought we would stay quiet and be thankful for the peanuts they threw at us - we need to upset that calculation.

So what happened about rude IV admins blasting anyone who said against WH when EO came out, and also what happened to don't talk about illegals they are like are brothers, Hispanic lobby back stabbed IV yet again as they have been doing so and arrogant IV back stabbed there very few followers which are left. First time in the history I have seen IV claiming to be grass root organization but instead IV cut legal immigrants from their root. Wake up people Aman and his chamcha's are trying to get into politics using legal immigrants as ladder. :D

goldengate001
01-07-2016, 04:28 PM
1. White House knows what went down.
2. White House knows that we're not happy.
3. Flower campaign? we know how that went.

I agree. All these flower and get well campaigns are too old-style. We should stop being naive.

moon_walker333
01-07-2016, 04:34 PM
I had posted two comments on Monday out of which one is showing up today when searched with my name. The one which got removed had IV's PDF file attached as-is. For the second comment which is saved and is active, I had exported content of PDF into a TXT file and had uploaded that. You can do the same. Discontinue attaching IV's PDF file in your comments as-is because it will get removed.

goldengate001
01-07-2016, 04:44 PM
So what happened about rude IV admins blasting anyone who said against WH when EO came out, and also what happened to don't talk about illegals they are like are brothers, Hispanic lobby back stabbed IV yet again as they have been doing so and arrogant IV back stabbed there very few followers which are left. First time in the history I have seen IV claiming to be grass root organization but instead IV cut legal immigrants from their root. Wake up people Aman and his chamcha's are trying to get into politics using legal immigrants as ladder. :D

When I think of alternatives, I see AILA, fwd, siskinds, the gotchers and a few others. I believe all of them have their own agendas and not the legal immigrant's best interests. I strongly believe IV is our best bet. Anyone in the leadership team having ambitions to get into politics does not bother me, as long as they continue to represent our best interests. Everyone started somewhere! As regards the Hispanic lobby, I have nothing but compassion for them. They should get a better deal, just like us. Their family(particularly children) are as institutionalized in this country as our family and children.

hil3182
01-07-2016, 05:10 PM
When I think of alternatives, I see AILA, fwd, siskinds, the gotchers and a few others. I believe all of them have their own agendas and not the legal immigrant's best interests. I strongly believe IV is our best bet. Anyone in the leadership team having ambitions to get into politics does not bother me, as long as they continue to represent our best interests. Everyone started somewhere! As regards the Hispanic lobby, I have nothing but compassion for them. They should get a better deal, just like us. Their family(particularly children) are as institutionalized in this country as our family and children.

No one has an interest in politics, infact at this time most of us are disgusted by the politicians repeated betrayals.

We want to get a permanent (Green Card) fix in, shut this organization down and get our lives back.

Ignore this idiot and others like him.

DMX17
01-07-2016, 05:37 PM
Guys - now let's start mixing different people's comments to make new ones and give them more shit. Here is mine for your copy/paste/mix/jumble up pleasure.


Dear Mr. Cummings,

I oppose this rule in its entirety as it is a complete betrayal by the Administration.

Respectfully, I request an FBI investigation over the personnel involved in the rule making and ask them to make sure that these personnel are not offered promises of employment after they leave their current positions. Please read comments below for further information.

Below are my initial comments upon reading the content of the proposed rule on a high level. I will also provide separate comments on the technical aspects of the rule in another submission(s), however the scope of this letter is limited to addressing the issue of what was promised and what the DHS intends to deliver with this sham regulation. I will use the word “betrayal” to describe the sentiment that the legal law-abiding skilled immigrant community is currently experiencing owing to the inability or indifference of the DHS and the Administration. Please register my comments as opposing the regulation with its current content. I do not support this regulation. Out of the many broken promises I can think of in the last year, I will only provide the two main ones.

Betrayal # 1
Per president’s glorified announcement and the various Memos surrounding the announcement, the immigrant community was led to believe that this rule will allow workers in long green card backlog with approved LPR petitions to “change jobs more easily”. Please note the words “more easily” and that would mean more easily than the current laws allow. Under no one’s definition, changing jobs on H-1B visa is considered “changing jobs more easily” than what the immigrants are already allowed. If the immigrants have to change jobs on H-1B, please note this provision has been in place for about 15 years since the enactment of AC21. Now, for DHS officials to have to have brazenness to come out with this rule and point us to a legislation that was implemented 15 years ago is extremely ruthless and cunning.



Betrayal # 2
The original RON: 1615-AC05 can be found here:
http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201504&RIN=1615-AC05

Text:
The Department of Homeland Security (DHS) is proposing to modernize the immigrant visa system by amending its regulations governing the adjustment of status process and employment-based immigration. Through this rule, DHS proposes to allow certain approved Immigrant Petition for Alien Worker (Form I-140) beneficiaries to obtain work authorization, clarify the meaning of portable work authorization, and remove unnecessary restrictions on the ability to change jobs or progress in careers, as well as provide relief to workers facing lengthy adjustment delays.

It is repulsive that some lawyers in DHS can play with words like “certain” so differently when it comes to its meaning in different regulations. For example, with the rule that provided EAD cards to H4 spouses (using the same Authority of the DHS secretary), the word “certain” is used broadly to apply a large group. With this so-called AC21 regulation, we see that “certain” means “those with compelling circumstances”. This is a major reason for the anguish that proposed rule has created for a million immigrants, most of whom are working as “indentured servants” tied to the same employer that has documented effects on the American workers by lowering wages and making American workers less attractable to employers who preferentially hire H-1B for their immobility. In this sense, this rule as proposed is Anti-American as it does nothing new to help the American workers and the economy. As such, this rule (i.e. no-rule) clearly defies the stated intent of the Executive Order 13563, which incorporates and builds upon the principles of Executive Order 12866, and which requires Federal agencies to design cost-effective, evidence-based regulations that are compatible with economic growth, innovation, job creation, and competitiveness. This is a betrayal to the American people, since the Economic Impact Analysis presented with this rule is flawed, biased, and self-contradicting to say the least.

Below is the link to June 2015 USCIS Memo describing different options under consideration for
the purpose of this regulation. And you will agree that none of the proposals discussed are implemented, let alone the preferred option #2.
https://www.dropbox.com/s/dwcu66m3vnj9nta/USCIS_Memo_for_EAD_for_I140_June2015.p
df?dl=0

Please address in your review my main concern as follows:

With the above points, I suspect that the rule has been derailed and significantly changed by some unfair and powerful influence after the rule making process started in the last few months. I request you to address the issue of integrity and ethics in the process of rulemaking. Specifically, I have read that a influential former lobbyist in strict violation of the Executive Order on Ethics Commitments was allowed or invited to work on the same rule which they lobbied for prior to joining DHS in the last year. The immigrant community suspects that this registered lobbyist with a long and distinguished track record of working with the U.S Chamber of Commerce was hired by DHS a few months ago, which would be non-compliant with the requirements set forth by the President in the below link.
https://www.whitehouse.gov/the_press_office/ExecutiveOrder-EthicsCommitments

The community has doubts that this former registered lobbyist contributed and influenced this regulation in favor of previous organization which represents interests of employers. If true, no one with a sane mind can consider this rule to be unbiased and hence the economic analysis must be revisited for the interests of American workers and the “so-defined” beneficiaries who are being used as statistical tools to increase immigration level in this country.

In fact, relying on such influence is completely against the intent of the rule to provide relief to the immigrants, as immigrants interest is not represented by the U.S. Chamber of Commerce or any other employer group for the issue of “mobility” and the “entrepreneurship by IMMIGRANTS” that is direct result on the mobilty. Clearly, the original intent of this rule making was indeed immigrant favored, but you have now qualitatively pointed in the cost benefit analysis that allowing free movement to immigrants will cost to employers in the form of “turn over”. Was the original intent of the rule to prevent “turn over” for the employer? If so, this rule was not needed at all.

In summary, I request an FBI investigation over the personnel involved in the rule making and also to make sure that the personnel involved in this rule making are not offered promises of employment after they leave their current positions.

Regards,

BABUG
01-07-2016, 05:54 PM
Guys,
I posted several comments but when i used the term "I am writing to register my opposition to the rule in its current form", The heading of my comment came as Mass Mail Campaign <Number>,

Please check if they are identifing some kind of Mass Campaigns in this way as well..:o

Bhishma
01-07-2016, 06:16 PM
This is bullshit. Asking for this in 2011 is like asking for Dependent Exemption and Recapture in 2014 - just not going to happen.

Also, since she sent the comments in, why didn't she just do the fix in 2015 - when she spent 2 months writing the Reg - or should I say re-writing the Reg?

Not so 'Nice'

DCToGC
01-07-2016, 06:26 PM
I register strongest opposition to the proposed rule.

why the Original Proposed rule published in Spring Agenda of 2015 is not being persuade ? Please find the link for the same – http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201504&RIN=1615-AC05

Why Compelling Conditions Criteria is added to the proposed rule? This rule will never offer stability and job flexibility for majority of the beneficiaries of approved employment-based immigrant visa petitions while they wait to become lawful permanent residents. With this rule in place I believe the proposed rule will always nourish H1B Bonded slavery of an employee to the employer who is sponsoring the same

Presidential Immigration Actions asks for - Providing portable work authorization for high-skilled workers awaiting LPR status and their spouses, Why this is not included unconditionally in the proposed rule?

President's Immigration Actions promises Advance Parole travel documents for high-skilled workers awaiting LPR status and their spouses, Proposed regulation does not have any provisions for I 140 beneficiaries ? Why this is not included unconditionally in the proposed rule?

Since announcing Executive Action on Immigration, the same sub-section of the law has been applied to grant EADs to H-4 and OPT. Why would the USCIS/DHS not use the same sub-section of the law and legal authority to grant unconditional “Portable Work Authorization” to immigrants with “approved LPR application” who are waiting many years for their visa to become available ?

During the election of 2008 and 2012 President Obama pronounced and promised that lobbyists will not run his Administration, I have learned that a top registered lobbyist with a long and distinguished track record of working with the U.S Chamber of commerce was hired by DHS a few months back. And that this former registered lobbyist contributed and influenced this regulation. It is pretty obvious that the registered lobbyist was sent (or invited) into DHS to not let high-skilled immigrants get “Portable Work Authorization” as intended in the Executive Action on Immigration.

It is clear that the specific former registered lobbyist did not adhere to President’s Ethics commitments, Can DHS certify that the process employed for the making of this regulation was ethical and legal?

Any normal and fair person watching this process would agree that the process of this regulation is flawed, unethical and in bad faith

I ask for FBI to inquire if any favors were exchanged or promised during the making of this regulation?

For disclosure and transparency purposes, could you please provide the names of all the public officials, staffers, officers and appointed officials, elected officials at DHS, USCIS, OMB and White House (and any other agency) associated with policy, drafting or approving of the contents of this regulation?

I ask for FBI to investigate all meetings, phone calls, emails or any form of communication of these staffers since the announcement of President’s Executive Action on Immigration. To ensure that no future favors are promised in return for watering down this regulation, in all fairness, FBI should keep track if any of these staffers take up jobs with the companies, law firms, organizations or entities that they were engaged with during the making of this regulation.

In short, this regulation does not provide any relief to i 140 approved high-skilled workers specially from the backlogged countries which contradicts with President Obama's Immigration Executive Actions by all the means.

DMX17
01-07-2016, 06:32 PM
Also, since she sent the comments in, why didn't she just do the fix in 2015 - when she spent 2 months writing the Reg - or should I say re-writing the Reg?

I suspect that because they re-wrote it, in the economic impact analysis they conservatively assumed that ALL people in the backlog (minus the H4 EADs etc.) will apply for new EADs. Then they threw in the language later "we cannot determine the number of people with compelling circumstances" or some shit like that. Just easy is that. Cunning work indeed.

As expected, not so Nice.

devndev
01-07-2016, 06:40 PM
Guys,
I posted several comments but when i used the term "I am writing to register my opposition to the rule in its current form", The heading of my comment came as Mass Mail Campaign <Number>,

Please check if they are identifing some kind of Mass Campaigns in this way as well..:o

That seems to be true... My only comment that got posted so far has this Mass Mail tag :mad:

DMX17
01-07-2016, 07:04 PM
That seems to be true... My only comment that got posted so far has this Mass Mail tag :mad:

Let's start changing the words around. Rearrange and be creative.

nvedia
01-07-2016, 07:47 PM
Looks like someone communicated about the meeting link to chamber of commerce. Page from the link got removed.

Good find...
What was the link...we can get the cached copy of it

racoon786
01-07-2016, 09:49 PM
This is a useless proposal who I strong oppose naturally. I do not know if USCIS/DHS is doing this for laughs just to torture legal immigrants or just low skilled people who barely made it out of colleges. First, they whine about having to a lot of work and forced DOS to withdraw the October 2015 visa bulletin. And now, they waste our time with a meaning less proposal designed to help their lawyer buddies perpetually. The people who wrote this proposal should be investigated for corruption and unethical conduct. The only real help, if that was ever their intent, is to give EAD's for people who have an approved I-140 for more than three years. It is simple and requires a page and not the 80 page garbage that was proposed here.

Commented submitted by: First Name: Jai - Last Name: Hind

DMX17
01-08-2016, 12:47 AM
https://www.federalregister.gov/articles/2015/02/25/2015-04042/employment-authorization-for-certain-h-4-dependent-spouses?utm_campaign=pi+subscription+mailing+list&utm_medium=email&utm_source=federalregister.gov

It will help to read these H4 ead final rule where they talk about public comments.

Helpful in making new comments that can be easily identified as opposing comments.

haranrk
01-08-2016, 01:18 AM
This is fantastic! Thanks for sharing DMX17! They have even referred to individual comments. Wow! All the more reason why we should register our comments - strongly opposing the regulation.

https://www.federalregister.gov/articles/2015/02/25/2015-04042/employment-authorization-for-certain-h-4-dependent-spouses?utm_campaign=pi+subscription+mailing+list&utm_medium=email&utm_source=federalregister.gov

It will help to read these H4 ead final rule where they talk about public comments.

Helpful in making new comments that can be easily identified as opposing comments.

foia
01-08-2016, 07:36 AM
I just sent a message on official WH site, not sure how much helpful will it be.

Dear Mr. President:

Hope you are doing great.

This is regarding a proposed rule "RIN: 1615-AC05: Retention of EB-1, EB-2, and EB-3 Immigrant Workers and Program Improvements Affecting Highly-Skilled Non-immigrant Workers" which was supposed to provide relief to high-skilled legal law-abiding tax-payer (to-be) immigrants as per the EO given by you in Nov 2014. Earlier the rule text was in-line with whatever you ordered in the EO, but going forward, the involved agencies (DHS and USCIS especially) modified the text of the rule so much that in spite of providing relief, it is more pain and restriction for the legal immigrants. You can compare the initial text and final text of the proposed rule in various sessions (Spring Vs Fall) as below:

Spring 2015: http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201504&RIN=1615-AC05
Fall 2015: http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201510&RIN=1615-AC05

As you can see above, in the spring agenda of the rule, the text clearly says "Through this rule, DHS proposes to allow certain approved Immigrant Petition for Alien Worker (Form I-140) beneficiaries to obtain work authorization", which would have given full job portability to the workers who, currently, can not plan for their families, can not buy homes, can not start a business, can not think US as their permanent home, in spite of everything they are doing for this great country of immigrants. In the Fall agenda of the rule, the text omitted the "Work Authorization" clause completely, and by the time, it was submitted to OMB for approval, it even put some "Compelling Reasons" clause and no renewal of the authorization, which is directly opposing the motive of the EO.

WE are sure, this happened because of the pressure of the businesses, who wants to keep us hostages and do not let us free in terms of job portability. I would request you to please look into this matter, since this is illegal for the agencies to NOT follow an EO from the President.

Thanks in Advance,
A law-abiding, Tax-paying worker, who trust Democracy

aadohio
01-08-2016, 09:40 AM
DMX17 -- this is great information. Thanks for sharing.

IV Admins and Gurus --
One item in this document is concerning.
https://www.federalregister.gov/articles/2015/02/25/2015-04042/employment-authorization-for-certain-h-4-dependent-spouses?utm_campaign=pi+subscription+mailing+list&utm_medium=email&utm_source=federalregister.gov#h-31

Apparently there were comments on the H4 EAD rule that requested principle applicants (H1B holders) to get EAD card as well. Back then DHS declined it citing that if EAD is given and the principle switches to a job that was not on the petition the H1B is not valid anymore.

Is this something that can come back and bite us again? After all the thousands of comments we send in DHS can come back and simply decline our requests based on this same logic again.

Please let us know if this is a false alarm. We are not experts, good chance I am reading this wrong.

https://www.federalregister.gov/articles/2015/02/25/2015-04042/employment-authorization-for-certain-h-4-dependent-spouses?utm_campaign=pi+subscription+mailing+list&utm_medium=email&utm_source=federalregister.gov

It will help to read these H4 ead final rule where they talk about public comments.

Helpful in making new comments that can be easily identified as opposing comments.

Aemon.Targ
01-08-2016, 10:52 AM
IV Admins and Gurus --

I am about to submit my comments for this useless rule and I would like to take your advice here.

I am thinking to add the below text in my comment, please let me know whether its appropriate to write that text or not.

"and finally I would like to request you to please disclose the names of officials who drafted the final text of this rule".

jaggu bhai
01-08-2016, 10:56 AM
Per H4 regulation - I see this. Question is by the way of comments are expressed for current proposal - Majority sounded like "I oppose" in current form.
Does it have any impact!! on the direction of this rule? (i dont benefit from the current form either :()


The approximately 10 percent of commenters who opposed the proposed rule cited to potential adverse effects of the rule, including displacement of U.S. workers, increasing U.S. unemployment, and lowering of wages. Some commenters expressed concern that the rule may negatively affect other nonimmigrant categories. Other commenters were concerned that this rule may cause the lowering of minimum working standards in certain sectors of the economy, such as in the Information Technology sector. Some commenters questioned DHS's legal authority to promulgate this regulatory change.

DMX17
01-08-2016, 11:15 AM
DMX17 -- this is great information. Thanks for sharing.

IV Admins and Gurus --
One item in this document is concerning.
https://www.federalregister.gov/articles/2015/02/25/2015-04042/employment-authorization-for-certain-h-4-dependent-spouses?utm_campaign=pi+subscription+mailing+list&utm_medium=email&utm_source=federalregister.gov#h-31

Apparently there were comments on the H4 EAD rule that requested principle applicants (H1B holders) to get EAD card as well. Back then DHS declined it citing that if EAD is given and the principle switches to a job that was not on the petition the H1B is not valid anymore.

Is this something that can come back and bite us again? After all the thousands of comments we send in DHS can come back and simply decline our requests based on this same logic again.

Please let us know if this is a false alarm. We are not experts, good chance I am reading this wrong.

I read that and am still thinking. I read somewhere else in the H4 final rule that kinds implied: Since Congress in AC21 intended that we all remain on H1b using extensions beyond 6 years, giving an EAD would be against Congressional intent in AC21.


The fucking lawyers argue whichever way to make the case. As you said we are not lawyers. We are victims of their cunningness.

hil3182
01-08-2016, 12:06 PM
We were promised I-140 EAD. The rule was 90% written to actually fix this problem - but a lobbyist stole it from us.

DHS has clear authority to issue I-140 EAD, but did not. Had they issued EAD's they could have come up with very good legal arguments to support issuing us EAD's - namely they have absolute unquestioned statuary authority to issue EAD's and Advanced Parole.

Now is the time to let the Administration know about our outrage, let the Administration know how little the rule changes - how useless the rule is and shine a spotlight on this possibly criminal irregularity.


This is not a time for Intellectual discussion.

devndev
01-08-2016, 12:36 PM
Not sure if IV has already explored this... Have we already taken legal advice on this matter of alleged corruption by the lobbyist ? If there is strong legal grounds, then why cant we formally register a case and get this Lady removed from any involvement in DHS affairs or at least strengthen the chances of her wrong doings being exposed which may force her to resign..


We were promised I-140 EAD. The rule was 90% written to actually fix this problem - but a lobbyist stole it from us.

DHS has clear authority to issue I-140 EAD, but did not. Had they issued EAD's they could have come up with very good legal arguments to support issuing us EAD's - namely they have absolute unquestioned statuary authority to issue EAD's and Advanced Parole.

Now is the time to let the Administration know about our outrage, let the Administration know how little the rule changes - how useless the rule is and shine a spotlight on this possibly criminal irregularity.


This is not a time for Intellectual discussion.

kmrr
01-08-2016, 12:37 PM
We were promised I-140 EAD. The rule was 90% written to actually fix this problem - but a lobbyist stole it from us.

DHS has clear authority to issue I-140 EAD, but did not. Had they issued EAD's they could have come up with very good legal arguments to support issuing us EAD's - namely they have absolute unquestioned statuary authority to issue EAD's and Advanced Parole.

Now is the time to let the Administration know about our outrage, let the Administration know how little the rule changes - how useless the rule is and shine a spotlight on this possibly criminal irregularity.


This is not a time for Intellectual discussion.

Also, I didn't understand why we have to be on H1 when one is given I140-EAD? The reason they didn't honor EAD for H1 during H4-EAD is different, because H4-EAD is for H1 folks dependants... But this case is different...

messengerofgod
01-08-2016, 12:42 PM
Also, I didn't understand why we have to be on H1 when one is given I140-EAD? The reason they didn't honor EAD for H1 during H4-EAD is different, because H4-EAD is for H1 folks dependants... But this case is different...

We would not have to maintain H1 during I140-EAD. There is no reason we could not have stayed on I-140 EAD until our I-485 was approved.

The only reason against it is because AILA members would have lost their "tax" every 3-years and Chamber of Commerce members would lose a lot of cheap labor.

As Hil said, we should be submitting angry comments now, not being "Intellectual" about it.

Bhishma
01-08-2016, 12:42 PM
a lobbyist stole it from us.

Some A$$holes on twitter are spreading their propaganda that this evil lobbyist may have secured a waiver before she joined the agency.

I request you to kindly not to fall for this propaganda and do what you think is the right thing

DMX17
01-08-2016, 12:47 PM
As hil said, let us focus on as many opposing comments right now.

I am about to go on a nonstop comment mode for the next 2 hours. Hopefully 30 comments per hour rate.

Hey parth, just play for playing sake right now (said Krishna to Arjuna :))

skywalker
01-08-2016, 12:51 PM
Guys,

Looks like there are good number of comments from our members but they are being tagged with Mass Mail campaign. Look at the below info

Mass Mail Campaign 3: Comment Submitted by Gaurav Gandhi (Total as of 1/5/2016: 794)

Mass Mail Campaign 67: Comment Submitted by George Thomas, Total as of 1/7/2016: 11


Search by those names in comments are and you will find PDF we were attaching for commenting.

We need to get smart in commenting to avoid getting tagged as mass mail campaign.

right2niru
01-08-2016, 12:57 PM
Guys,

Looks like there are good number of comments from our members but they are being tagged with Mass Mail campaign. Look at the below info

Mass Mail Campaign 3: Comment Submitted by Gaurav Gandhi (Total as of 1/5/2016: 794)

Mass Mail Campaign 67: Comment Submitted by George Thomas, Total as of 1/7/2016: 11


Search by those names in comments are and you will find PDF we were attaching for commenting.

We need to get smart in commenting to avoid getting tagged as mass mail campaign.

Does this mean they will consider or ignore these submissions ?

skywalker
01-08-2016, 12:59 PM
I am no expert on their policy but I am guessing they will consider it as one comment.

right2niru
01-08-2016, 01:09 PM
I am no expert on their policy but I am guessing they will consider it as one comment.

Reason i ask is at least the above comment was flagged as Mass campaign ,however mine submitted twice still doesnt show up :(

foia
01-08-2016, 01:27 PM
Does this mean they will consider or ignore these submissions ?

They will have to address why these comments were not accepted or whatever. F$%&ing a$$holes.

sfben
01-08-2016, 01:34 PM
White House responded to a petition named Making a Murderer that gathered 120K signatures in less than 20 days. And it made national headline.

Petition
https://petitions.whitehouse.gov/petition/pardon-steven-avery-and-brendan-dassey-their-alleged-involvement-murder-teresa-halbach

Headline
https://www.google.com/search?q=white+house&oq=white+house&aqs=chrome.0.69i59j69i60l3.891j0j4&sourceid=chrome&es_sm=119&ie=UTF-8#tbm=nws&q=white+house+making+a+murderer

IV, unless you have other ways to pressure White House, why not start a petition to "Investigate DHS for the Killing of I-140 EAD". We can go on the streets of hundreds of cities in the US and gather signatures from sympathetic Americans!

We have never gathered enough signatures in past petitions. And we have to ask why. Is this because most of us don't care to sign and just want a free ride in this struggle?

Maybe we forgot that there are so many American people who are sympathetic with us and if we ask them they would happily sign for this petition. We have alienated ourselves from the mass support of the reasonable Americans.

IV, educating Americans on the benefit of highly skilled legal immigrants and gathering their support in our struggle should be on your agenda. Let's not fight alone.

racoon786
01-08-2016, 02:39 PM
Hey Sampath from TX and Harish from NJ,
Thanks for helping us with negative comments and of course special thanks to your numbersusa brethren.

pappu
01-08-2016, 03:09 PM
White House responded to a petition named Making a Murderer that gathered 120K signatures in less than 20 days. And it made national headline.

Petition
https://petitions.whitehouse.gov/petition/pardon-steven-avery-and-brendan-dassey-their-alleged-involvement-murder-teresa-halbach

Headline
https://www.google.com/search?q=white+house&oq=white+house&aqs=chrome.0.69i59j69i60l3.891j0j4&sourceid=chrome&es_sm=119&ie=UTF-8#tbm=nws&q=white+house+making+a+murderer

IV, unless you have other ways to pressure White House, why not start a petition to "Investigate DHS for the Killing of I-140 EAD". We can go on the streets of hundreds of cities in the US and gather signatures from sympathetic Americans!

We have never gathered enough signatures in past petitions. And we have to ask why. Is this because most of us don't care to sign and just want a free ride in this struggle?

Maybe we forgot that there are so many American people who are sympathetic with us and if we ask them they would happily sign for this petition. We have alienated ourselves from the mass support of the reasonable Americans.

IV, educating Americans on the benefit of highly skilled legal immigrants and gathering their support in our struggle should be on your agenda. Let's not fight alone.

You can even sign such online petitions once every hour with a new ID and it will mean 24 people signed. :D

The only way to protest are the following

- Hire top lobbyists for a long period of time and spend a lot on lobbying. Lobbying on shoestring does not yield much. You have to go with top lobbyists. This requires capital. We have identified a modest budget to start with as stated in the last week's public conference call. This is why we want everyone to sign up for monthly contributions asap.

- Advocate. Advocate. Advocate. We need to do grassroots campiagns more and for a long period of time. Civil rights law did not come into being with that just one speech by MLK. That campaign went on for a long period of time at grassroots level. We need to have several advocacy days in DC. Say once every 3-4 months and want more people coming to DC regularly every month.

- Show up in tens of thousands and protest in public a few times. If it is even less than 10 thousand, it will not have desired impact. We have done that a few times in IV in the past and this is the learning. It has to be a recurring thing like undocumented folks who are advocating

- Volunteer to IV and help run this organization.

- Get more active after becoming citizen of GC holder. You can contribute to election campaigns, PAC and as a citizen you can do a lot in IV.

- Get your company to support IV and its agenda. Talk to your CEOs and higher management about it. Contact us and we will give you tips.

- Spread the name of IV in your friends and local organizations. We need everyone affected be a part of this movement,

foia
01-08-2016, 04:20 PM
Not very nice...

DMX17
01-08-2016, 05:08 PM
Some A$$holes on twitter are spreading their propaganda that this evil lobbyist may have secured a waiver before she joined the agency.

I request you to kindly not to fall for this propaganda and do what you think is the right thing

These aholes have lost their credibility. Nice!

I have an idea for the followers: They should ask their expensive suits from AILA to provide 14,000 "expert opinions" supporting the I-140 EAD/AP (DHS authority etc.) and attach them as support individually. Well, they do not have do much on work on this since memo was leaked already to ...........Any takers to see where that goes?:D

Sorry for the side track from commenting. I read this link and found it useful in learning about this rule making process:

Administrative Procedure Act | Center for Effective Government (http://www.foreffectivegov.org/node/226)


Keep em comments coming guys!

thankstooptx
01-08-2016, 06:01 PM
These aholes have lost their credibility. Nice!

I have an idea for the followers: They should ask their expensive suits from AILA to provide 14,000 "expert opinions" supporting the I-140 EAD/AP (DHS authority etc.) and attach them as support individually. Well, they do not have do much on work on this since memo was leaked already to ...........Any takers to see where that goes?:D

Sorry for the side track from commenting. I read this link and found it useful in learning about this rule making process:

Administrative Procedure Act | Center for Effective Government (http://www.foreffectivegov.org/node/226)


Keep em comments coming guys!

https://redd.it/401j1a

krish2005
01-08-2016, 06:01 PM
Aman and team announced in FB that WH team wants to hear from IV..

Please please make the our case representation stronger. We are one of those pitiful beings left stranded in the H1B limbo and thanks a lot for trying to make this point known to WH.

This is really a great news after that hit we took when they pushed down the watered down crap rule.

We all are eagerly awaiting for a good news from IV core.

WH: Please have some humane approach to our cases.

Thanks

Krishna

right2niru
01-08-2016, 07:06 PM
Aman and team announced in FB that WH team wants to hear from IV..

Please please make the our case representation stronger. We are one of those pitiful beings left stranded in the H1B limbo and thanks a lot for trying to make this point known to WH.

This is really a great news after that hit we took when they pushed down the watered down crap rule.

We all are eagerly awaiting for a good news from IV core.

WH: Please have some humane approach to our cases.

Thanks

Krishna

Keeping fingers crossed

nvedia
01-08-2016, 07:16 PM
Aman and team announced in FB that WH team wants to hear from IV..

Please please make the our case representation stronger. We are one of those pitiful beings left stranded in the H1B limbo and thanks a lot for trying to make this point known to WH.

This is really a great news after that hit we took when they pushed down the watered down crap rule.

We all are eagerly awaiting for a good news from IV core.

WH: Please have some humane approach to our cases.

Thanks

Krishna

All the best!

greenappletx
01-08-2016, 07:55 PM
Go IV !! Good luck and hope to hear some positive news!

puneet2k5
01-08-2016, 09:02 PM
When is the meeting? Has IV gotten enough advance notice to prepare well for the meeting?

devndev
01-09-2016, 09:37 AM
When is the meeting? Has IV gotten enough advance notice to prepare well for the meeting?

It already happened yesterday afternoon.. Hoping to hear some positive updates :)

eadeadead
01-09-2016, 10:46 AM
Anxiety already kikking in. Hopefully something positive will be coming out.:):confused::confused:

mgmanoj
01-09-2016, 10:57 AM
In compromise with EAD they should least give us quarterly spill over

HumHongeKaamyaab
01-09-2016, 01:26 PM
Any updates? I think even if the WH listens to IV, it will be the next iteration of the rule that may contain what we want (Fingers crossed) which means another 60 odd days...I really wonder if they think they can take all the time in the world to keep dicking around with us immigrants...I am so pissed...

Yesterday heard of my Pakistani friend getting his green card (Happy for him)...he came here 3 years ago for his master's...I have been here 11 years !! I keep getting upset. Now time to channel this anger into another comment against the rule...off to the website to comment AGAINST it...I think Ive put in about 23 comments in so far...KEEP GIVING THEM HELL GUYS!!!