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Comments Needed On Green Card Replacement Proposal

By immigrationprof

URGENT: SEND COMMENTS ON PROPOSED GREEN CARD REPLACEMENT REGULATION (DHS DOCKET NO. USCIS-2005-0056) TO U.S. CITIZENSHIP AND IMMIGRATION SERVICES BY FRIDAY, SEPTEMBER 21, 2007

BACKGROUND

Under the proposed rule, immigrants who have permanent residence cards (Form I-551 “green cards”) that do not have an expiration date (those issued between 1979 and 1989) must apply to U.S. Citizenship and Immigration Services (USCIS) for a replacement card within a 120-day period beginning October 22, 2007. They must pay a fee of $290 with the replacement application and $80 for a biometric information service (fingerprints, photograph, and signature). USCIS will set a date when the old green cards will no longer be valid. Lawful permanent residence status will not expire even if the green card is no longer valid, but the old card will no longer be valid for obtaining new employment or entering the U.S.

WHY YOU OR YOUR ORGANIZATION SHOULD SEND COMMENTS:

120 days is too little time for a green card replacement program.
Many immigrants won’t learn about the green card replacement program in time.
Many immigrants won’t be able to apply for a green card replacement in time.
Green cards might be terminated even if USCIS has not finished processing applications for replacements.
The rule will criminalize many longtime, law-abiding immigrants.
You or your organization can submit comments to USCIS about this proposed regulation. Comments are due by September 21, 2007.

HOW TO WRITE COMMENTS

The National Immigration Law Center has prepared model comments which you can adapt for your own use. Your comments can be as long or short as you choose. They should reflect your own experiences and be in your own words so that USCIS will count each comment separately. Please be mindful of the sections that are in italics where you will need to insert your organization’s information.

HOW TO SEND COMMENTS:

There are several ways to submit your comments. Be sure to:

o put DHS Docket No. USCIS-2005-0056 in the subject line.
o put your comments on your letterhead.
o pay particular attention to the sections in the model comments that are in italics where you will need to insert your own information.

Online: You may submit comments electronically on http://www.regulations.gov. Follow the instructions there for submitting comments; or.
E-mail: You may submit comments directly to USCIS by e-mail at rfs.regs@dhs.gov. Include DHS Docket No. USCIS-2005-0056 in the subject line of the message; or
Mail: You can mail comments to: The Chief, Regulatory Management Division, U.S. Citizenship and Immigration Services, Department of Homeland Security, Massachusetts Ave. NW, 3rd Floor, Washington DC 20529. Include DHS Docket No. USCIS-2005-0056 on the envelope. This address may be used for paper, disk, or CD-ROM submissions; or
Hand Delivery/Courier: U.S. Citizenship and Immigration Services, 111 Massachusetts Ave. NW, Washington, DC 20529. Contact telephone number is 202-272-8377. Include DHS Docket No. USCIS-2005-0056 on the envelope.
We would appreciate if you also send us a copy of any comments you submit to USCIS.

For more information, contact Joan Friedland at friedland@nilc-dc.org

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