Portland Area Program Office's Comments to DHS Docket No. ICEB-2006-0004
Pacific Northwest Region
Portland Area Program Office
2249 East Burnside Street
Portland OR 97214
April 22, 2008
Marissa Hernandez
U.S. Immigration and Customs Enforcement
425 I St. NW, Suite 1000
Washington, D.C., 20536
Re: American Friends Service Committee, Portland Area Program Office’s Comments to DHS Docket No. ICEB-2006-0004
Dear Ms. Hernandez:
The Portland Area Program Office of the American Friends Service Committee submits these comments in opposition to the supplemental proposed rule that reissues the rule on Safe Harbor Procedures for Employers Who Receive a No-Match Letter.
The American Friends Service Committee (AFSC) is a Quaker based organization that works for peace, social justice, and humanitarian service. AFSC supports the rights and dignity of all people, regardless of their immigration status. AFSC has a long history of working in migrant and immigrant communities. Our current national initiative, Project Voice, seeks to lift up the voices of immigrants and refugees, to strengthen their communities and organizations, and to ensure their perspective is included in humane and fair national public policies. The Portland Area Office of AFSC has worked on immigration issues and with immigrant communities for more than 15 years.
Because of the SSA no-math-letters, our Portland staff has since last summer already been receiving calls from the immigrant community reporting increased fear and confusion as employees and employers struggle to understand the policy. Additionally, due to the current anti-immigrant climate, many citizens of Latino descent in Oregon have reported racial profiling cross a number of areas. Reissuing this rule can only make it worse.
Relying on a flawed database to solve our nation’s immigration issues is a mistake. Rather the DHS should pursue worksite policies which would enable employers to help their workers adjust their immigration status. It would not only be a more productive and humane, it would recognize the enormous contributions immigrant workers make daily to our nation’s economy.
The Portland Area Program Office of the American Friends Service Committee, joins our national office in strongly opposing the Department of Homeland Security’s reissuance, without any substantive change, of the Safe Harbor Procedures for Employers Who Receive a No-Match Letter. The rule does not address the issues raised by the court. The proposed changes are not substantive, thus the rule will continue to undermine labor rights thereby causing a detrimental impact on all workers. Additionally, the rule will further overburden the Social Security Administration. Finally, the rule will be costly to workers and to our nation’s economy. At a time of crisis in our nation’s economy, we should be look for policies that strengthen our workforce and that recognize the contributions that all workers make regardless of their status.
Sincerely,
Alice M. Perry
Immigration Specialist
Portland Area Office
American Friends Service Committee
aperry@afsc.org
Phone: 503-230-9427
Fax: 503-230-1835
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