DHS-Docket No. USCIS-2021-0006 UnidosUS submitted comments to the United States Citizenship and Immigration Services (USCIS) on the Notice of Proposed Rulemaking (NPRM), Preserving and Fortifying Deferred Action for Childhood Arrivals, published on September 28, 2021.
In our comment, we take note of the essential contributions DACA recipients have made to the fabric of American society, despite legal threats to the policy which threatens these individuals with removal from the United States. We express our appreciation for DHS for prioritizing DACA and proposing this rule at a time when litigation on the subject is pending, and we offer the administration several recommendations on how to successfully “protect and fortify” this policy. These recommendations include not bifurcating deferred action and employment authorization preemptively, in addition to modernizing the eligibility date for DACA, expanding the duration of work permits for DACA recipients, decreasing DACA application fees, and reducing the backlog on DACA applications, among other changes. Lastly, we remind the administration that this proposed rule presents an expeditious opportunity to provide undocumented youth at large with the most expansive and durable protections possible for them at this moment.