Email this page

Public Comment Submitted on Safe-Harbor Procedures for Employers Who Received a Non-Matching Letter

DHS Docket No. ICEB-2006-0004

Submitted By

AMERICAN FRIENDS SERVICE COMMITTEE

PROJECT VOICE NETWORK

April 22, 2008

Contact Persons:

Esther Nieves
Director of Immigrant and Refugee Rights
AFSC - Community Relations Unit

1501 Cherry Street
Philadelphia, PA 19102
(215) 241-7131
enieves@afsc.org

Sara Ibrahim
Public Policy Impact Coordinator
AFSC- Washington, DC
1822 R. Street NW
Washington, DC 20009

202-483-6839
sibrahim@afsc.org

Ms. Marissa Hernandez

Department of Homeland Security
U.S. Immigration and Customs Enforcement
425 I Street N.W., Suite 1000
Washington, D.C., 20536

Re: American Friends Service Committee’s Comments to DHS Docket No. ICEB-2006-0004

Dear Ms. Hernandez:

The American Friends Service Committee is a Quaker-based organization that includes people of various faiths who are committed to social justice, peace and humanitarian service.  AFSC supports the rights and dignity of all people, regardless of their immigration status.

The American Friends Service Committee (AFSC) submits these comments as an expression of our deep concern on the proposed supplemental rule that reissues the rule on Safe Harbor Procedures for Employers Who Receive a No-Match Letter (DHS Docket No. ICEB-2006-0004). AFSC strongly opposes the Department of Homeland Security’s reissuance of the Safe Harbor Procedures for Employers Who Receive a No-Match Letter. Relying on outdated information and a flawed database is a disaster for the nation’s workforce. 

 AFSC’s Project Voice, a national immigrants and refugees’ rights initiative works to uplift these voices and to strengthen efforts of migrant-led organizations to set an agenda for fair and humane national public policies.   With 90 years of consistent work and experience in partnership with immigrant and refugee communities in 18 communities in 14 states, our national work is grounded in long-term relationships with faith, labor, local and national groups engaged in day-to-day work within immigrant and refugee communities. 

It is the daily work, collegial support and mutual learning that places AFSC staff at the center of many community issues and in this case, as immigrant families react and response to the “no match” ruling.   We recently received a comment from a staff member who has many years of work with farmworkers and their families, in the Visalia, California community.   According to Martin Cuevas, a staff member of AFSC’s Proyecto Campesino:

"We already know of several worksites in our area that are indiscriminately telling workers they will lose their jobs. This does nothing but worsen the already difficult existence of many of these workers and their families".

The use of a flawed database to verify employment serves no one, least of all employers or workers – whether native born or born in another country.  Indeed, errors and discrepancies have already fostered apprehension and fear among workers, and could lead to racial profiling, worksite or labor rights abuse, summary dismissals and other actions that impinge on the basic civil and labor rights of all workers – regardless of their status in the United States.  

AFSC strongly urges DHS to pursue worksite policies, which enable employers to help their workers adjust their immigration status, even as those workers continue to contribute to the nation’s economic vitality.  Rather than re-craft a failed approach to our nation’s immigration issues, AFSC urges the administration to pursue realistic and effective policies which provide a due and fair process for the status adjustment of workers who work from sunrise to sunset to contribute to the nation’s agricultural and economic vitality.

We look forward to your favorable consideration and reply.

Sincerely,

Esther Nieves                                                             

Director, Immigrant and Refugee Rights 

215-241-7131 (Philadelphia Center)

ENieves@afsc.org  

Sara Ibrahim

National Public Policy Impact Coordinator

202-483-6839 (Washington, DC Office)

sibrahim@afsc.org                                          

The American Friends Service Committee is a Quaker organization that includes people of various faiths who are committed to social justice, peace and humanitarian service. Its work is based on the belief in the worth of every person and faith in the power of love to overcome violence and injustice.

The American Friends Service Committee supports the rights and dignity of all people, regardless of their immigration status. Project Voice, the AFSC immigrants’ rights initiative, works to uplift migrant voices and strengthen efforts of migrant-led organizations to set an agenda for fair and humane national public policies. AFSC has 90 years experience working with immigrants and refugees and presently works with immigrants in 18 communities in fourteen states and in 22 countries around the world.

^ Top of page