Yolo Interfaith Immigration Network

YIIN is a group of people serving and advocating for immigrants in Yolo County

ADD YOUR VOICE IN OPPOSITION TO A PROPOSED GUTTING OF THE U.S. ASYLUM SYSTEM
June 30, 2020 by Sam Loomis

On June 15, 2020, the Trump Administration published in the Federal Register a proposed rule by the Departments of Homeland Security and Justice that will eviscerate the U.S. asylum system. The rule is long and complex; you can read it in its entirety HERE.

The proposed rule contains many new restrictions on both the procedural aspects of claiming asylum and the bases on which asylum will be granted. Some are particularly disturbing. It would virtually eliminate gender-based claims, resulting in a disproportionately negative effect on women and LGBTQ asylum seekers. Not only would women not be able to seek asylum based on their experiences of extreme (and virtually inescapable) domestic violence, but also even those fleeing sex slavery at the hands of gangs and terrorists would be denied protection.

By redefining the meaning of being “persecuted,” those who come to the U.S. to escape from violent gangs and terrorist groups would not be considered asylum worthy. Thus, even the most vulnerable children and young people would be prohibited from seeking asylum in our country. Many come from the Central American countries of El Salvador, Guatemala, and Honduras, which remain among the most violent countries not at war in the world. (See, e.g., Jan. 2020 article by the Council on Foreign Affairs about the effect of violence of those fleeing Central America, https://www.cfr.org/blog/top-conflicts-watch-2020-worsening-conditions-northern-triangle?utm_medium=social_share&utm_source=emailfwd)

WHAT CAN YOU DO?

This new rule is the expression of Trump and Stephen Miller’s visceral animosity towards the “caravans” of people recently seeking help at our southern border. In fact, these groups were made up largely of women walking hundreds of miles with small children in tow trying to escape extreme violence in their countries.

We must try to be their voices. We can do that by submitting public comments to the Federal Register. A proposed rule by a federal agency cannot become a final rule or regulation until it has been subject to public comment for 30 days after its submission.

The deadline for submitting a public comment for this proposed rule is Wednesday, July 15, 2020. HERE is a link to an article that includes more information about the proposed rule as well as a template for a comment.

HOW TO SUBMIT A COMMENT TO THE FEDERAL REGISTER

Making a public comment takes a bit of time, but this is important enough to make that commitment. For a detailed description of the process is HERE, but a summary of the process follows below.

You can submit by paper or electronically. You must state that you are writing about OMB Control Number 1615-0067, EOIR Docket No. 18-0002, a proposed rule by the Department of Homeland Security and the EOIR of the Department of Justice.

To submit electronically, go to the Federal eRulemaking Portal. On the left, under the heading What’s Trending, click on Procedures for Asylum and Withholding of Removal; Credible Fear and Reasonable Fear Review. That will take you to a page where at the top right, there is a blue rectangular tab, Comment Now! After clicking on that, write your comment.

To submit by paper, mail your written comment to:
Lauren Alder Reid, Asst. Director, Office of Policy
Executive Office of Immigration Review
5107 Leesburg Pike, Suite 1800
Falls Church, VA 22041

Submit your electronic comment by 9 p.m. PST (12 p.m. EST) on 7/15/20. A paper comment must be postmarked by 7/15/20.

The government review gives greater weight to those comments that do not appear to be mere copies of others’ comments, so we need to customize our submissions. The comment can be concise and limited to one aspect of the proposed rule that is troubling to you. It is helpful to add any experiences one has had with asylum seekers or people who have received asylum. However, be mindful that your public comment becomes a matter of public record.  Therefore, do not include any personal identifying information about someone you know who has either applied for or been granted asylum in your comment.

If you know others who would be interested in doing this work to try to save our asylum system, please forward this email to them.

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