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Make your voice heard about a new proposed rule that would make it impossible for asylum seekers to get a fair shot at obtaining protection. In yet another attack on asylum, the administration proposed new rules that would further increase barriers to asylum— dealing yet another blow to survivors of gender-based violence who are trying to access safety and justice.

Among the proposed changes included, are shortened and stricter deadlines for asylum seekers to submit applications and narrow and restrictive timelines to make decisions on asylum applications, with limited opportunities for extensions. The cumulative impact of the barrage of recent rules attacking the asylum process is to slam the door on people who need protection from persecution.

Before the proposed rule can be finalized, the government is required to review and respond to each unique public comment submitted by organizations or individuals responding to the rule. This is your chance to make your voice heard.*

Below is a sample comment for the general public

It is critical that you DO NOT simply copy and paste the model comment into the form you submit. The government will only review and respond to unique comments. When expressing your opposition to the proposed rule, please be sure to reformulate the text, adding your own voice and speaking to your own professional expertise and personal experiences, or those of people you know. Explain why, in your view, the U.S. must preserve access to protection for all asylum seekers, including those fleeing gender-based violence.



All public comments are due by October 23, 2020 at 11:59 p.m. ET.




Lauren Alder Reid, Assistant Director
Office of Policy
Executive Office for Immigration Review
5107 Leesburg Pike, Suite 2616
Falls Church, VA 22041

RE: RIN 1125–AA93; EOIR Docket No. 19–0010; A.G. Order No. 4843–2020, Public Comment Opposing Proposed Rules on Procedures for Asylum and Withholding of Removal

I submit this comment in opposition to the above-mentioned rule. This rule creates draconian new procedures that will make it impossible for asylum seekers to get a fair shot at obtaining protection. People who could otherwise qualify for the life-saving protection of asylum will find it even harder than it is now to ask for safety in the U.S.

Asylum seekers come from all over the world, leaving everything – family, work, money, home, community – behind, and risk their lives making perilous journeys to come to our shores. Many asylum seekers have experienced or fear torture, domestic violence, rape, forced marriage, female genital mutilation/cutting, and other severe harm. We have an obligation to afford them a fair chance to ask for protection. This is both a legal obligation and a moral one.

[Insert any personal information, experiences, expertise, or other details that set your comment apart.]

The rule, however, would put a strict limit on the length of each case, setting it to just 180 days. This will mean that few if any applicants will get a meaningful chance to make their case – immigration court will become a conveyor belt for deportations.

The only possible defense against swift deportation in these circumstances would be having a good lawyer, but the government does not appoint lawyers for immigrants facing deportation.  And the rule also requires many asylum seekers to file their applications within only 15 days, making it nearly impossible for them to find a lawyer on their own.

Even if an asylum seeker does manage to find a lawyer, they will barely have enough time to prepare the case properly. Mistakes and inaccuracies will be the norm in rushed situations like this, meaning that there will be easy reasons for an immigration judge to deny asylum to someone who would have otherwise qualified. This is especially concerning because the rule also specifically requires immigration judges to reject asylum applications for minor errors made when filling out the form. An application can also be rejected if a newly-created fee is not paid. The rule could ultimately be a death sentence for many thousands of deserving asylum seekers, permanently shutting the door to protection from unimaginable, life-threatening harm.

The proposed rule would also fundamentally alter the role of the immigration judge by allowing judges to submit their own evidence in asylum proceedings. Judges should be impartial adjudicators and should not act like parties to the case. The judge’s goal should not be to find ways to deport people or to find ways to keep them in; the judge should be considering evidence given by the applicant and their attorney fairly and with an eye to upholding the law.

Finally, I object to the rule because of the 30-day comment deadline. The public should have been given more than 30 days to comment on a rule that would make such dramatic and fundamental changes to the immigration court process. There is no reason for the changes to be pushed through so quickly. Given the pandemic, and the upcoming election, people have even less time to become educated about and oppose rules like this one.

I believe that survivors of gender-based violence, torture, and other persecution should have a fair chance to plead their case. When facing deportation back to severe harm or even death, it is critical that they have a chance to find a lawyer and present their case. It is also critical that they meet an impartial judge who will consider their eligibility fairly. There are a lot of problems with the current system, but this is not a good way to fix them.

Thank you for considering this comment.

[name, location]



All public comments are due by October 23, 2020 at 11:59 ET.

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Make your voice heard about a new proposed rule that would make it impossible for asylum seekers to get a fair shot at obtaining protection.