FR 2024-29494

The recent notice from the Department of Homeland Security (DHS), specifically from the U.S. Citizenship and Immigration Services (USCIS), announces a revision to the information collection process for Form I-360, which pertains to petitions for Amerasian, Widow(er), or Special Immigrants. With a deadline for public comments set for January 21, 2025, the notice emphasizes the need for community feedback, especially regarding the estimated burden associated with completing this form and the related response times.

Document Summary

The USCIS is seeking public input on the revised information collection process involved with Form I-360. This form is crucial for certain individuals, including Amerasians, widows or widowers, and various categories of special immigrants, including abused spouses or children and specific workers, to establish eligibility for immigration benefits. Additionally, the form assists in granting employment authorization in certain cases. The notice indicates an estimated total annual burden of 127,230 hours and an associated cost of approximately $7.82 million on the public for complying with this information collection.

Key Issues and Concerns

Several issues arise from the notice:

• Lack of Detailed Justification: While the document seeks public comments, it does not clearly explain why revisions are necessary. This lack of transparency could hinder the public’s ability to provide meaningful feedback or understand the revisions' implications.

• Methodology Clarity: The notice provides extensive estimates concerning respondent numbers and burden hours; however, it does not clarify the methodology used to arrive at these estimates. This omission might lead to perceptions of opaqueness in how these data points were calculated.

• Complexity and Language: The use of specialized terms and references to regulatory frameworks without sufficient explanation may make the document inaccessible to those unfamiliar with legal or bureaucratic jargon.

Public Impact

For the general public, especially those who may need to use Form I-360, this notice represents an opportunity to voice concerns or suggestions to improve the form’s usability and minimize burdens. However, without clear justification or simplified language, the document might fail to engage some individuals, limiting the potential for constructive feedback.

Impact on Stakeholders

• Positive Impact: For stakeholders, such as immigration advocates and public interest groups, the notice provides a platform to influence policy by contributing insights that could make the form more efficient and user-friendly.

• Negative Impact: On the other hand, the lack of detailed breakdown of the cost components and unclear methodology in burden estimation could frustrate stakeholders who require this information to assess the proposal’s impact comprehensively. This opacity might reduce the effectiveness of stakeholder advocacy.

In summary, while the notice is an essential part of the regulatory process, ensuring transparency and accessibility in communications could significantly enhance the quality of feedback received from various interested parties. These improvements would ultimately serve the interests of both the USCIS and the public, leading to a more efficient and effective immigration process.

In reviewing the Federal Register document, there is a notable focus on the estimated total annual cost burden associated with the information collection for the Petition for Amerasian, Widow(er), or Special Immigrant. This cost is explicitly stated as $7,820,533. This figure represents the financial impact on the public interacting with the U.S. Citizenship and Immigration Services (USCIS) through these particular petition processes.

While the document does provide a total cost estimate, a significant issue is the lack of detailed breakdown of this figure. Potential stakeholders, such as individuals filling out these forms or organizations assisting them, may find it challenging to comprehend what contributes to this $7.8 million burden. Understanding the components of this estimate (such as processing fees, administrative costs, or additional expenditures for applicants) would enhance transparency and allow the public to evaluate the reasonableness of these costs.

The absence of a breakdown also ties to the issue regarding the methodology used to derive various estimates of public burden, including hours spent and cost. The document mentions different categories of the petitioners and the estimated number of respondents for each category along with their respective hour burdens. However, without an insight into the assumptions and methods used to calculate these, it is difficult to validate the associated financial implications.

Moreover, this cost burden is presented as an aggregate figure without contextual explanations, making it potentially overwhelming or confusing for the general audience. This lack of clarity might lead some readers to question the necessity and efficiency of the costs involved, which could influence their feedback during the public comment period.

In summary, while the document effectively states the overall expected public cost burden, the absence of a detailed accounting for this figure contributes to confusion and could limit the utility of the public commentary period. A more transparent presentation of how these costs are structured would likely improve stakeholder understanding and engagement.