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Sira's Draft Comments On Rin_1615-ac05

Discussion in 'General discussion about executive action' started by cuckoo, Feb 27, 2016.

  1. cuckoo

    cuckoo Super Moderator

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    We have made significant revisions to some legal authority sections and also our comments throughout as of 4.40 AM today. These revision strengthen or provide legal authority for filing AOS post EAD/AP and PERM portability without location restrictions and also add more scathing comments. Please resubmit comments with revised version, if you have already submitted.

    Dear All,

    Attached are our exhaustive draft comments on the reg. Please feel free to use them as you see fit. It would be best if you can personalize your comments. We also wanted to let you know that at least some White House officials are listening to us. We have discussed our concerns and shared our comment outline with them. They want the backlogged EB community to submit their concerns about the regulation in the form of serious well thought out quality comments. Although, the outcome of these efforts continues to be uncertain, we think this is a welcome development, Let us not get our hopes up too much but do what we need to do. Please take the time to submit your comments by Monday. Here is the link for submissions:
    http://www.regulations.gov/#!submitComment;D=USCIS-2015-0008-0001
    Please share with all, post it on forums you visit. Let us get it done.

    Please remove SIRA header and personalize. If you want to use SIRA's document in its entirety, please write some comments of your own and then say, as a member or supporter of SIRA, I fully support SIRA's enclosed comments. Then attach the file. Submit it in your name.

    Team SIRA
     
    Last edited: Feb 29, 2016
  2. agulv

    agulv Guru

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    Thank you Cuckoo and Sira team.
     
  3. rv_sree

    rv_sree Junior Member

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    Cuckoo - Thanks a lot. I just submitted SIRA's comments.
     
  4. mar212011

    mar212011 Well Regarded Member

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    Very well thought through and detailed.
     
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  5. cuckoo

    cuckoo Super Moderator

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    Did you submit comments in your name or Sira's? We might still have some changes in the legal authority part before we submit.
     
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  6. kashish sharad

    kashish sharad Guru

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    Thank you SIRA for all the hard work.
     
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  7. kkrun

    kkrun Member

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    Thanks SIRA!

    I tailored my comments based on the draft, and feel satisfied about it.
     
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  8. Shane

    Shane Junior Member

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    email I need to send my comments to
    Please let me know I am basing on my comments on SIRA but dont know where to send

    Pls help
     
  9. cuckoo

    cuckoo Super Moderator

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  10. Shane

    Shane Junior Member

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  11. agulv

    agulv Guru

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    My 2 cents:
    I want to bring to your attention with this comment that even if this regulation is meant for ALL EB categories, it overlooks the high demand in EB1 category for last few years. The recent I485 inventory report which was published by USCIS contains statistics up to January 2016. For EB1 category the pending inventory for 2014 was 4,494 and for 2015 are 23,265. This is almost an increase by approx. 400% in this category in the last 2 years. How come Unites States of America needs such a High percentage of Executives and manager’s in the last few years and what is driving this demand? This regulation is focusing more on H-1B candidates who are eligible only for EB2/3 categories for Employment based petition. It clearly overlooks the need for a fix to the EB1 category especially for applicants under L1A visa. If this regulation is meant to be fair for all EB categories then the agency should enforce the need for “Labor Certification” under EB1C category so all are treated fair and have passed the labor requirements as set forth by Department of Labor.
     
  12. cuckoo

    cuckoo Super Moderator

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    you can add this to your comment . Bottomline, EB1c is exempt from PERM under the statute. They can't change that with a reg.
     
  13. agulv

    agulv Guru

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    I understand but highlighting this item brings a major issue to their attention. They may or may not fix it in my lifetime but at least i did my part.
     
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  14. PDCOM

    PDCOM Guru

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    Done! Thank you.
     
  15. PDCOM

    PDCOM Guru

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    @cuckoo You mention some WH officials are listening. Hope they are the ones who will help modify the rule.

    It also reminds me of the other group who claimed a lot of things giving us false hopes.

    The draft is good for SIRA, getting it personalized does take time. Folks should factor that in when planning to post comments.
     
  16. agulv

    agulv Guru

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    Read Greg's recommendation and he also did a good job. Hope all this comments are read with the right intention.
     
  17. speedracer

    speedracer Guru

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    great job ! I hope we get the rule to really help people stuck in backlog and hope that they would actually give job portability to legal immigrants
     
  18. agulv

    agulv Guru

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    I like where Greg has stated in his comment's "Being stuck in a Green card backlog itself is "compelling"". I plan to put this comment.
     
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  19. alpha0

    alpha0 Guru

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    I added a comment today..at the end i added about american dream. i wrote something like - if american dream is about giving everyone an opportunity to prosperity and social mobility based on skills and hard work irrespective of circumstances at birth, put an disclaimer that it does not apply to legal skilled immigrants from india and china!
     
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  20. WhatSheSaid

    WhatSheSaid Member

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    Excellent comments! Makes my blood boil to see how unfair USCIS is to immigrant community.

    Shall I upload comment as myself or SIRA?
     

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