Maryknoll Office for Global Concerns

Representing Maryknoll Fathers & Brothers, Maryknoll Sisters, and Maryknoll Lay Missioners
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Letter on Comment Period for New Asylum Rules

The Maryknoll Office for Global Concerns signed the following joint letter to the Department of Homeland Security urging them to extend the 30-day comment period on the new asylum rules proposed in June 2020. 

Dear Attorney General Barr, Director McHenry, Assistant Director Reid, Acting Secretary Wolf, Senior Official Mizelle, Senior Official Cuccinelli, Division Chief Dunn, and Administrator Ray:

We, the undersigned faith-based organizations and leaders, write to urge the Departments to allow at least 60 days for public comment on the above referenced NPRM. We make this request due to the length and complexity of the 161-page rule, the critical interests it implicates, and the inherent challenges of meaningfully engaging in the public comment process during an unprecedented global pandemic.

A Minimum of 60 Days is Required for Meaningful Public Comment on the NPRM

The NPRM is Extremely Lengthy, Complex, with Novel Legal and Policy Issues Executive Order 12866 requires agencies to “…afford the public a meaningful opportunity tocomment on any proposed regulation, which in most cases should include a comment period of notless than 60 days.” Executive Order 13563 likewise directs agencies to “...afford the public a meaningful opportunity to comment through the Internet on any proposed regulation, with a comment period that should generally be at least 60 days.” Citing Executive Order 12866 itself, the Departments note in the NPRM that it is a “significant regulatory action…because it raises novel legal or policy issues.” There is no compelling reason to except the NPRM from the Executive Orders’ general rule of providing a minimum of 60 days for public comment.

Thank you in advance for your time and consideration of this request. Please contact Tschika McBean at tmcbean@usbnc.org with any questions or concerns, and we look forward to your prompt response.

Sincerely,

Bahá’ís of the United States
Congregation of Our Lady of Charity of the Good Shepherd, U.S. Provinces
FaithTrust Institute
Jewish Women International
KARAMAH: Muslim Women Lawyers for Human Rights
National Advocacy Center of the Sisters of the Good Shepherd
Peaceful Families Project
Rev. Dr. Katherine Epperly,
Minister of Justice and Advocacy for Families and Children,
Disciples Home Missions, Christian Church (Disciples of Christ)
Rev Dr Leonisa Ardizzone,
UU Congregation of the Catskills, Kingston NY
Rev. Dr. Patricia Donahoo, Executive Director
Women’s Ministries, Disciples of Christ
Sojourners
St. Mary’s Episcopal Church, Harlem
The Interfaith Center of New York
The Maryknoll Office for Global Concerns
Union for Reform Judaism