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WASHINGTON, April 28 -- The Catholic Legal Immigration Network Inc. submitted a public comment letter to the U.S. Department of Homeland Security opposing the agency's Notice of Proposed Rulemaking titled "Employment Authorization Reform for Asylum Applicants," published on February 23, 2026. CLINIC, which represents a coalition of over 400 community-based and diocesan legal service providers across 48 states and D.C., critiqued the proposal for undermining the rights and dignity of asylum seekers.

The NPRM proposes multiple changes to the rules governing Employment Authorization Documents (EADs) ... Show Full Article

Economic Policy Institute Condemns DHS Proposed Employment Authorization Rule for Asylum Applicants

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WASHINGTON, April 27 -- The Economic Policy Institute, a nonprofit think tank focused on low- and middle-income workers' economic interests, submitted a public comment letter to the U.S. Department of Homeland Security opposing the agency's Notice of Proposed Rulemaking entitled Employment Authorization Reform for Asylum Applicants.

EPI criticized the proposed rule for imposing extensive delays and restrictive barriers on asylum applicants seeking Employment Authorization Documents (EADs), which could severely disrupt the labor market and harm millions of workers.

EPI highlighted that the NPRM ... Show Full Article WASHINGTON, April 27 -- The Economic Policy Institute, a nonprofit think tank focused on low- and middle-income workers' economic interests, submitted a public comment letter to the U.S. Department of Homeland Security opposing the agency's Notice of Proposed Rulemaking entitled Employment Authorization Reform for Asylum Applicants. EPI criticized the proposed rule for imposing extensive delays and restrictive barriers on asylum applicants seeking Employment Authorization Documents (EADs), which could severely disrupt the labor market and harm millions of workers. EPI highlighted that the NPRMwould extend the waiting period for initial work authorization from 150 days to 365 days and increase mandatory processing times from 30 days to 180 days. Additionally, the rule proposes to pause initial work permit processing when asylum case backlogs exceed 180 days and render application approvals discretionary, potentially leading to denials without cause. According to the institute, these changes would not only prevent asylum-seekers from supporting themselves but would also negatively affect employers, coworkers, and families dependent on their income.

The organization pointed out that EADs play a critical role in protecting workers' rights and enabling lawful employment, especially for those without permanent immigration status. EPI explained that work authorization enhances workplace safety and ensures compliance with labor standards, preventing exploitation and wage theft. It also noted that millions of workers rely on such protections, including asylum-seekers, Temporary Protected Status (TPS) holders, and Deferred Action for Childhood Arrivals (DACA) recipients, whose contributions to the U.S. economy are substantial.

EPI expressed concern that the DHS proposal underestimates the economic harm to already employed asylum applicants and falsely assumes that displaced workers can be replaced without difficulty. The institute stressed that asylum-seeking workers fill essential roles in industries such as healthcare, hospitality, agriculture, and construction, and their sudden removal would exacerbate labor shortages, increase mandatory overtime, and raise workplace safety risks. Furthermore, the NPRM threatens the stability of unions by disrupting membership and collective bargaining power.

The comment letter also warned that by restricting lawful employment access, the NPRM would push workers into the informal economy, increasing labor violations and undermining enforcement of workplace laws. This shift would depress wages and working conditions not only for immigrant workers but for all employees in affected sectors. EPI underscored that these negative consequences were not adequately addressed in the agency's analysis.

Finally, EPI emphasized that the existing asylum-based employment authorization system has created significant reliance interests among workers and employers, which the NPRM disregards. The institute urged DHS to withdraw the proposed rule, stating it would destabilize workforces, weaken labor protections, and harm the broader economy rather than streamline regulatory processes.

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Daniel Costa
Director of Immigration Law and Policy Research
Economic Policy Institute

Read full text of letter here: https://www.regulations.gov/comment/USCIS-2025-0370-6987

City of Aberdeen Highlights Transportation and Safety Priorities in Public Comment to DOT

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WASHINGTON, April 27 -- The City of Aberdeen, South Dakota, submitted a public comment letter to the U.S. Department of Transportation outlining key transportation and safety improvement priorities to support continued growth, enhance quality of life, and improve transportation efficiency. As a regional hub with heavy freight movement, Aberdeen emphasizes the need for coordinated planning, partnerships, and strategic investments to address unique challenges.

Aberdeen identifies several critical infrastructure needs, including the development of a southern truck bypass to reroute heavy truck traffic ... Show Full Article WASHINGTON, April 27 -- The City of Aberdeen, South Dakota, submitted a public comment letter to the U.S. Department of Transportation outlining key transportation and safety improvement priorities to support continued growth, enhance quality of life, and improve transportation efficiency. As a regional hub with heavy freight movement, Aberdeen emphasizes the need for coordinated planning, partnerships, and strategic investments to address unique challenges. Aberdeen identifies several critical infrastructure needs, including the development of a southern truck bypass to reroute heavy truck trafficaway from residential and high-activity areas. This measure aims to reduce congestion, improve safety, and decrease wear on city streets. Enhancements to pedestrian safety are also highlighted, focusing on improved crossings, sidewalks, and ADA-compliant infrastructure along heavily trafficked corridors like 6th Avenue.

The letter stresses the importance of community-focused design in bridge and overpass projects, advocating for pedestrian-first features, protective barriers, enhanced lighting, and aesthetics that reflect Aberdeen's identity through public art and landscaping. Gateway improvements at the Highway 12 and Main Street entrance are proposed to improve traffic flow, pedestrian connectivity, and incorporate branding elements that welcome residents and visitors.

Along the Highway 281 corridor, Aberdeen calls for improved safety and recreation connectivity by developing pedestrian crossings and multi-use trails that link parks and neighborhoods. The city suggests evaluating a roundabout at Highway 281 and 8th Avenue to enhance traffic flow and reduce conflicts, incorporating community branding within the feature.

Aberdeen is exploring involvement in the Safe Streets and Roads for All (SS4A) program to develop a comprehensive safety action plan targeting freight corridors, pedestrian routes, and high-risk intersections. The city further emphasizes collaboration with the South Dakota Department of Transportation (SDDOT) to pursue funding opportunities and coordinate technical guidance.

The letter also addresses the need for effective communication during transportation projects, recommending enhanced coordination between SDDOT and city public information officers for traffic rerouting and minimizing economic disruption. Aberdeen calls for data-driven planning to inform future growth and stresses that transportation improvements should promote safety, accessibility, and community experience to support local businesses and tourism.

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Read full text of letter here: https://www.regulations.gov/comment/DOT-OST-2026-0298-0176

Center for Immigration Studies Urges DHS to Reform Employment Authorization for Asylum Applicants

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WASHINGTON, April 27 -- The Center for Immigration Studies has submitted a public comment letter to the U.S. Department of Homeland Security Citizenship and Immigration Services addressing the proposed rulemaking on Employment Authorization Reform for Asylum Applicants. The letter responds to concerns regarding current backlogs and systemic incentives influencing asylum filings and employment authorization requests.

CIS highlights the tremendous backlogs currently burdening USCIS's affirmative asylum casework, with over 1.45 million pending claims and average processing times exceeding three years. ... Show Full Article WASHINGTON, April 27 -- The Center for Immigration Studies has submitted a public comment letter to the U.S. Department of Homeland Security Citizenship and Immigration Services addressing the proposed rulemaking on Employment Authorization Reform for Asylum Applicants. The letter responds to concerns regarding current backlogs and systemic incentives influencing asylum filings and employment authorization requests. CIS highlights the tremendous backlogs currently burdening USCIS's affirmative asylum casework, with over 1.45 million pending claims and average processing times exceeding three years.The Executive Office for Immigration Review also faces a backlog exceeding 2.4 million defensive asylum cases. These delays create a feedback loop where slow adjudication of asylum claims leads to increased filings for renewable employment authorization documents (EADs), further straining USCIS resources. Data cited in the letter indicate substantial volumes of asylum-based EAD applications, comprising nearly half of all such renewal requests.

To address these challenges, CIS supports several reform proposals aimed at restoring the discretion and integrity of the asylum-related employment authorization system. The organization backs a regulatory amendment requiring all applicants for asylum-related EADs-including renewals-to submit biometrics, enhancing identity verification and national security vetting throughout the benefit lifecycle. Further, CIS recommends restricting EAD eligibility to applicants who are not prima facie ineligible for asylum, such as those barred under statutory provisions, to prevent exploitation of the system by individuals unlikely to qualify for asylum.

CIS also endorses DHS's proposal to suspend acceptance of initial asylum-based EAD applications when affirmative asylum processing times exceed 180 days, noting that this pause would realign incentives and focus agency resources on adjudicating underlying asylum claims. Additionally, the letter advocates for extending the waiting period before asylum applicants become eligible for work authorization beyond the current 180-day minimum to mitigate the filing of non-meritorious applications motivated primarily by access to employment.

The organization supports restrictions on EAD eligibility for those who entered the United States unlawfully, emphasizing the discretionary nature of employment authorization and rejecting claims that such restrictions violate international treaties. Prioritization of asylum applications containing derogatory information discovered during EAD adjudication is also urged to expedite removal of ineligible applicants posing security threats.

Moreover, CIS proposes expanding in-person interview requirements to all asylum-based EAD applicants, eliminating the regulatory "EAD clock" that currently governs eligibility timing, and reducing the validity period of asylum-based EADs to allow more frequent reassessment of eligibility and security risks.

Collectively, CIS argues that these reforms would reduce incentives for frivolous asylum filings, enhance security and fraud prevention, improve allocation of USCIS resources, and better align employment authorization with the statutory purpose of asylum as a protection-based benefit. The letter calls on USCIS to adopt these measures to strengthen the asylum system's integrity and operational effectiveness.

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Read full text of letter here: https://www.regulations.gov/comment/USCIS-2025-0370-6682

Challenges in Rural Transportation Systems Highlighted in University of Tennessee at Chattanooga Letter to U.S. Department of Transportation

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WASHINGTON, April 27 -- The University of Tennessee at Chattanooga Center for Urban Informatics and Progress has submitted a public comment letter to the U.S. Department of Transportation addressing challenges faced by rural transportation systems. The letter responds to the agency's Request for Information on the Rural Opportunities to Use Transportation for Economic Success (ROUTES) Initiative and draws on CUIP's expertise with connected and digitally supported transportation systems, including their work on the Chattanooga Smart Corridor.

CUIP emphasizes that rural transportation struggles ... Show Full Article

Center for Immigration Studies Urges DHS to Reform Employment Authorization for Asylum Applicants

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Carbondale Area Interfaith Refugee Support Opposes DHS Employment Authorization Reform for Asylum Applicants

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WASHINGTON, April 27 -- The Carbondale Area Interfaith Refugee Support, Illinois, has submitted a public comment letter to the U.S. Department of Homeland Security opposing a proposed rule on employment authorization for asylum applicants, arguing the changes would harm vulnerable families and strain community resources.

CAIRS, a nonprofit dedicated to supporting refugees resettling in the greater Carbondale, Illinois area, argues that the proposed rule will impose severe hardship on families fleeing persecution by forcing them to wait at least one year or longer before they can legally work. ... Show Full Article WASHINGTON, April 27 -- The Carbondale Area Interfaith Refugee Support, Illinois, has submitted a public comment letter to the U.S. Department of Homeland Security opposing a proposed rule on employment authorization for asylum applicants, arguing the changes would harm vulnerable families and strain community resources. CAIRS, a nonprofit dedicated to supporting refugees resettling in the greater Carbondale, Illinois area, argues that the proposed rule will impose severe hardship on families fleeing persecution by forcing them to wait at least one year or longer before they can legally work.The organization stresses that such delays hinder both the asylum seekers' ability to sustain themselves and their assimilation into American society. CAIRS further warns that the prolonged restriction on employment authorization would increase reliance on limited public assistance and private charity, straining local nonprofit resources that are already stretched thin.

The nonprofit highlights its experience assisting refugee families from Afghanistan, Iraq, and Indonesia, noting that employment authorization has been vital for those families to achieve self-sufficiency, improve language skills, and contribute economically to Southern Illinois. Many asylum seekers fill jobs in sectors such as agriculture, construction, and domestic services-areas facing labor shortages and not typically sought after by U.S. workers. CAIRS asserts the rule's assumptions that American workers will readily replace asylum applicants are flawed and unsupported by evidence.

CAIRS also challenges several claims made by DHS, including the agency's assertion that employment authorization acts as a "pull factor" encouraging unauthorized migration. The organization points out that DHS has provided no empirical evidence to support this claim and that persecution, war, and violence remain the primary drivers of asylum seeking. Additionally, CAIRS criticizes DHS for conflating asylum seekers with national security threats without establishing a clear connection. The letter further notes that the proposed pause on accepting new employment authorization applications could last for years to decades, exacerbating hardship and dependence on community aid.

Southern Illinois, the region served by CAIRS, lacks large urban infrastructure and extensive support networks, making the inability of asylum seekers to work an even greater challenge. CAIRS calls on DHS to reconsider the proposal in favor of increasing funding and resources to process asylum claims promptly, thereby allowing asylum seekers to contribute swiftly as self-sufficient members of their communities.

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The letter was signed by:

Cindy G. Buys, Professor of Law and Chair, Carbondale Area Interfaith Refugee Council

Victoria Cisneros, Law Clerk

Nathalie Rodriguez, Law Clerk

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Read full text of letter here: https://www.regulations.gov/comment/USCIS-2025-0370-6661

Blue Star Families Urges DOD to Address State-Level Challenges Affecting Military Families

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WASHINGTON, April 27 -- Blue Star Families, Encinitas, California, submitted a public comment letter to the U.S. Department of Defense regarding state priorities for 2028 impacting service members and their families. The organization highlighted persistent quality-of-life challenges such as spouse unemployment, childcare access, food insecurity, and mental healthcare disruptions, which directly affect military readiness and retention.

The letter emphasized the high unemployment rate among military spouses, attributed to frequent relocations and licensing delays. Blue Star Families recommended ... Show Full Article WASHINGTON, April 27 -- Blue Star Families, Encinitas, California, submitted a public comment letter to the U.S. Department of Defense regarding state priorities for 2028 impacting service members and their families. The organization highlighted persistent quality-of-life challenges such as spouse unemployment, childcare access, food insecurity, and mental healthcare disruptions, which directly affect military readiness and retention. The letter emphasized the high unemployment rate among military spouses, attributed to frequent relocations and licensing delays. Blue Star Families recommendedthe expedited review and issuance of temporary occupational licenses to reduce wait times, citing examples from Alaska, Virginia, and Washington as models of successful legislative efforts. This reform is seen as a critical step in supporting military spouse employment and, by extension, family stability.

Blue Star Families also called for enhanced coordination within state infrastructures to better support military families. They pointed to initiatives such as Maryland's 2024 statute renaming its Department of Veterans and Military Affairs to the Department of Veteran and Military Families, signaling a broader commitment to family services. Other states have appointed specialized personnel to serve as military family liaisons, improving employment outreach and childcare coordination. Florida's amendment to the Interstate Compact on Educational Opportunity for Military Children to mandate training on student records transfer was also noted as a positive development.

Addressing homeschooling, the organization highlighted the challenges military families face with varying state regulations and recommended policies allowing families to maintain homeschool status based on their state of legal residence, ensuring consistency despite relocations. This approach draws on precedents used by families stationed overseas.

Mental healthcare access gaps were another priority. Blue Star Families urged the creation of military patient waivers or interstate compacts to enable licensed clinicians to provide care across state lines, facilitating continuity through virtual appointments. They also recommended codifying elements of state suicide prevention initiatives to ensure military families receive sustained support.

Further, the letter identified the exclusion of Reserve military students from critical support programs due to regulatory inconsistencies and called for updated data collection to include these students. Finally, the letter highlighted financial instability faced by National Guard and Reserve members serving as state employees, recommending statutory reforms to guarantee pay and benefits continuity during military leave, with Florida's policies cited as an example.

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Jennifer Akin, Vice President, Strategic Alliances and the White Oak Collaborative

jakin@bluestarfam.org

704/488-6740

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Read full text of letter here: https://www.regulations.gov/comment/DOD-2026-OS-0232-0114

Amazon Highlights Security Considerations for Agentic AI in Response to NIST Request

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WASHINGTON, April 27 -- Amazon Web Services submitted a public comment letter to the National Institute of Standards and Technology and the Center for AI Standards and Innovation addressing security considerations for artificial intelligence agents, specifically focusing on agentic AI systems.

Amazon frames agentic AI as autonomous systems capable of planning and executing complex sequences of actions independently, raising new security challenges beyond traditional software and generative AI models.

In the letter, Amazon emphasizes that existing security frameworks like the NIST Cybersecurity ... Show Full Article WASHINGTON, April 27 -- Amazon Web Services submitted a public comment letter to the National Institute of Standards and Technology and the Center for AI Standards and Innovation addressing security considerations for artificial intelligence agents, specifically focusing on agentic AI systems. Amazon frames agentic AI as autonomous systems capable of planning and executing complex sequences of actions independently, raising new security challenges beyond traditional software and generative AI models. In the letter, Amazon emphasizes that existing security frameworks like the NIST CybersecurityFramework, NIST AI Risk Management Framework, and Secure Software Development Framework remain applicable but require extensions to handle agentic-specific risks. Central to their recommendations is the enforcement of deterministic, infrastructure-level controls external to the AI agent's reasoning loop, known as the "security box," which restricts agent behaviors and tool access with guarantees immune to prompt injection or manipulation. This architectural approach is critical given the probabilistic nature of large language models (LLMs), which cannot reliably enforce security boundaries internally.

Amazon outlines four foundational security principles for agentic AI: applying secure development lifecycle practices to all components; maintaining relevance of traditional security controls such as identity and access management with least privilege and supply chain protections; emphasizing deterministic external controls as the primary security mechanism; and progressively increasing agent autonomy based on demonstrated performance supported by ongoing evaluation. They note that autonomy should never be granted by default but earned through rigorous monitoring, with human oversight gradually transitioning to post-hoc review and eventually to full autonomy where justified.

The letter also details key architectural building blocks including isolated compute platforms with strong virtualization, centralized identity and access management integrating with existing AWS IAM capabilities, memory management that ensures contextual isolation, and centralized tool access governed by fine-grained policies. Amazon's Bedrock AgentCore framework exemplifies these capabilities, employing formal methods for policy verification and automated reasoning guardrails to enhance safety.

Regarding security challenges, Amazon identifies managing deterministic controls at scale, emergent behaviors in multi-agent deployments, and immature evaluation methodologies as areas requiring further research and engineering focus. They further stress the importance of comprehensive observability infrastructure for real-time anomaly detection and forensic analysis that remains protected from compromise by the agents themselves.

Amazon encourages NIST and CAISI to extend current cybersecurity frameworks rather than develop separate agentic AI standards and to promote transparency through model cards and security documentation. They advocate for industry collaboration on best practices and note that while agentic AI adoption is accelerating, careful risk/benefit analyses and mature safeguards remain essential. Finally, Amazon highlights cross-disciplinary insights from human factors engineering and aviation safety as valuable for advancing secure, autonomous AI systems.

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Read full text of letter on Docket NIST-2025-0035 here: https://www.regulations.gov/comment/NIST-2025-0035-0532

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