Thread by @David_J_Bier

I'm reading the comments on USCIS's "comment box" for all the ways they could be a better agency. Here's the first one from @GSiskind. I love it!

There's so much to love in this next one. Why are EADs necessary at all?

USCIS is not a serious agency. We all know this. But not using email is an embarrassment.

Here are the first three suggestions from @doug_rand targeting the #USCISbacklog

Also, @doug_rand says USCIS needs to use its authority to extend premium processing to other forms, raising revenue to hire adjudicators and reduce the backlog for everyone.

Here's one of my new suggestions that I submitted as part of our comments. @gsiskind helped me with the implications for doctors. I published it as a blog post today. cato.org/blog/uscis-dol…

@angelopaparelli and co's comments include surveys of its clients on many issues. Very interesting! I love: "The inability for USCIS to authorize auto-extensions of Employment Authorization Documents (EAD) where agency processing delays result in work authorization gaps "

There are so many good ideas here! Masterful!

I plan on writing about many of these ideas on the coming days.

@BrentRenison suggests USCIS retain the priority date for a derivative child who has aged out of EB eligibility but then enters the FB line. He notes SCOTUS has already affirmed USCIS's authority to go through with this change in 2014. Why did USCIS fail to do it under Obama?

@BrentRenison elaborates on the need for automatic EAD extensions

@BrentRenison with another great suggestion! Why are EADs valid for such a short period? It makes no sense!

More from @BrentRenison. How does a rule like this persist for so long? It's like the only lights in the USCIS building are at the adjudicators' desks, and so no one can see even a tiny big of the big picture

More from @BrentRenison. I'm getting enraged reading this. This agency is supposed to be the "pro-immigrant" immigration agency but it's actually an awful Kafka-esque bureaucratic disaster

More from @BrentRenison. If it takes more than 6 months to adjudicate something, shouldn't the timeline for filing *automatically adjust* to a period much earlier than that?

Moving onto @AILANational's comment. You really get the sense that USCIS *desperately* needed to this feedback. Its new leadership was never going to discover most of this on their own when so much has gone into making this dysfunctional system

Whaaaaaaaaaaaaaaaaaaaaaat... YOU ARE AN IMMIGRATION AGENCY!

So much basic, basic, basic, mind-numbingly basic stuff here

USCIS: "We're going to make things easier for you! Oh but we aren't going to talk to anyone before we make things easier... We're just going to wing it! Don't you love us?"

When was the last time anyone really cared about a functioning legal immigration system? Abraham Lincoln?

I just realized that AILA's comment is 20 pages. I'm only 4 pages in. Of course, Cato's comment is 40 pages, but AILA's has probably 5 times as many suggestions. Ah! This one cuts me deep. Unreliable and unhelpful data are the worst!

Last in, first out is turning the entire asylum application process into a sham. USCIS needs to fix this! 15 year wait for processing! Insanity!

It's crazy to me that USCIS has adjudications to get to its adjudications which are only caused by failure to adjudicate still other forms!

Here's another no-one-really-cares-about-you note from USCIS

Apparently this isn't happening. My brain hurts. Who has run this agency for the last 2 decades? Not to repeat, but obviously no one has really looked at why this agency is so messed up before.

Oh good thing this was created then...

Oh here's a gem from @AILANational. Please do this @USCIS

There are so many Trump policies still around. How is this possible? These are the EASY things to identify?

It certainly seems that at least some people at USCIS do not want people to easily know what the law is.

Every one of these things are enough to impeach the agency for high crimes

More Trump changes that inexplicably persist. USCIS should put into regulations that none of this is discretionary at the officer level so they can't keep easily undoing this.

CBP shouldn't get to make these decisions at all. Who cares if someone's passport is going to expire before the end of their stay? That's their problem, not CBP's. CBP should always approve for whatever the I-797 says.

An intriguing proposal. I wasn't aware that Es weren't already considered "dual intent" by virtue of the fact that they don't have to have a residence abroad that they have "no intention of abandoning" like Hs.

You would really think that Trump would've wanted more competition for @AlexNowrasteh and friends! Why is Biden keeping this?

Here's another one of my new suggestions that I submitted: "U.S. Citizenship and Immigration Services (USCIS) should increase the three‐​year limit on H-2B and H-2A extensions of status to six years." cato.org/blog/uscis-sho…

I'm hopeful that USCIS will actually do this one (unlike some of my other H-2 suggestions) because it increases the bargaining power of H-2 workers relative to their employers. If employers know that you can't extend, that's a real problem for you! cato.org/blog/uscis-sho…

Wow. Three "comply withs" in a row. USCIS is as lawless as the rest of them.

Interesting. I'd love to hear what the legal arguments are here, but let's recapture as many unused numbers as possible!

Several commenters just submitted our list of ideas to which I added three more for the comments we submitted. cato.org/publications/s…

I was always very confused by how this case turned out, but it's a great suggestion from @the_ILRC. We currently are violating the text of the law to obtain an "equal" result that harms people who are being "equalized". It doesn't make sense to me.

Ugh... there's so many problems. It's one reason why @angelopaparelli and I urged the president and the agency to require leniency in favor of the applicants in the interpretation of all laws and rules. Anything ambiguous should go to the applicant.

Somehow I messed up my own thread. Oh well

Here's a good easy one for USCIS @the_ILRC. No "Extreme" (ly vague) vetting questions

More "extreme" (ly pointless) vetting

I'm furious that I messed up this thread multiple times! I'm as bad as USCIS

Hopefully USCIS will do a better job reading the comments than I did with my threads

@NFAPResearch nails this. DHS should stop inaccurately describing its overstay report as a report on "overstays." Obama started this thing, and then Trump predictably misused it to cancel visas for certain nationalities. USCIS should clearly state that it can't count overstays

Back to @the_ILRC's awesome comments. Trying to banish people for using legal marijuana is an example of how the immigration agencies take part in some of the worst abuses of government power

Please leftists never nationalize all businesses. This is horrific.

How America treats noncitizen crime victims is illustrative of how much it values noncitizens generally.