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  #1 (permalink)  
Old 02-06-2016, 02:22 AM
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Default Would commenting really make a difference?

Need help from IV for following questions

1. Does more number of comments opposing the rule and suggesting the change mean the rule would be modified accordingly (eg grant EAD to I140 approved) or cancelled ?

2. If comments are important, then why there is no push after the initial call from IV for more and more comments. May be weekly call/updates etc. I do see updates on the other facebook group etc and people for getting more and more comments but no tracking/guidance from IV on this. So, commenting much is not going to make a difference? Is it just a formal activity/process which can be ignored with "thanks, we will consider but not at this time"
Or commenting more would make a difference? I am asking because in the initial call, IV asked strictly not to get into any online petition since its a distraction and most of us did not get involved in any.
But here we ought to know if commenting this way is going to be useful or just not needed
(most people in panic mode commenting almost everyday multiple times or giving examples that out of 1 million people, why only 10K comments so far. Does the less number shows less strength?)

3. Any regulations in the past where commenting made a difference and got any concrete changes made? (apart from being digital searchable property and showing strength in terms of numbers).

4. I read that commenting is not a voting process. So, going by all the comments, most of us already did our part by explaining what we don't want, what we want and how DHS ha authority to grant EAD etc and proposed solution ? (http://www.regulations.gov/docs/Tips...e_Comments.pdf)
<<<

The comment process is not a vote one well supported comment is often more influential
than a thousand form letters
>>>

5. If big lawyers and companies can lobby to go against President Executive Action and turn the rule in their favor, then what really is going to be the value of these comments eventually?

Clarity would give us confidence that what we are doing is worth the effort

Please answer it would help everyone as there are only 3 weeks left before comment period ends so we can make best use of our time
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  #2 (permalink)  
Old 02-06-2016, 04:54 PM
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Ramalingam is infamous around these parts Ramalingam is infamous around these parts Ramalingam is infamous around these parts Ramalingam is infamous around these parts Ramalingam is infamous around these parts Ramalingam is infamous around these parts
Default

Comment process supposed to work. To see how accurately it works you have to see past regulations. Minor modifications were done in some regulations. In past usually supporting comments were more and no issues and only minor changes were included. One change was for H4-EAD initially it was proposed to give EAD only for who cleared I140 and after 6 years of H1b was done. But that was changed but not sure it was after comment or before comment process

Similarly what if someone gives impractical comment. I read someone wrote a comment about backlog removal in the I140 regulation. So those things will be rejected. Most comments were the giving unconditional and portable EAD without H1b renewal. One can argue for and against it. If that is legal then they could include otherwise they will reject those comments I am expecting that comments will exceed 25k before Feb. That itself will take 6 months to process. If 1 million comments are given then it will take 10 years to process

Quote:
Originally Posted by nvedia View Post
Need help from IV for following questions

1. Does more number of comments opposing the rule and suggesting the change mean the rule would be modified accordingly (eg grant EAD to I140 approved) or cancelled ?

2. If comments are important, then why there is no push after the initial call from IV for more and more comments. May be weekly call/updates etc. I do see updates on the other facebook group etc and people for getting more and more comments but no tracking/guidance from IV on this. So, commenting much is not going to make a difference? Is it just a formal activity/process which can be ignored with "thanks, we will consider but not at this time"
Or commenting more would make a difference? I am asking because in the initial call, IV asked strictly not to get into any online petition since its a distraction and most of us did not get involved in any.
But here we ought to know if commenting this way is going to be useful or just not needed
(most people in panic mode commenting almost everyday multiple times or giving examples that out of 1 million people, why only 10K comments so far. Does the less number shows less strength?)

3. Any regulations in the past where commenting made a difference and got any concrete changes made? (apart from being digital searchable property and showing strength in terms of numbers).

4. I read that commenting is not a voting process. So, going by all the comments, most of us already did our part by explaining what we don't want, what we want and how DHS ha authority to grant EAD etc and proposed solution ? (http://www.regulations.gov/docs/Tips...e_Comments.pdf)
<<<

The comment process is not a vote one well supported comment is often more influential
than a thousand form letters
>>>

5. If big lawyers and companies can lobby to go against President Executive Action and turn the rule in their favor, then what really is going to be the value of these comments eventually?

Clarity would give us confidence that what we are doing is worth the effort

Please answer it would help everyone as there are only 3 weeks left before comment period ends so we can make best use of our time
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  #3 (permalink)  
Old 02-06-2016, 06:58 PM
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Default

Quote:
Originally Posted by Ramalingam View Post
Comment process supposed to work. To see how accurately it works you have to see past regulations. Minor modifications were done in some regulations. In past usually supporting comments were more and no issues and only minor changes were included. One change was for H4-EAD initially it was proposed to give EAD only for who cleared I140 and after 6 years of H1b was done. But that was changed but not sure it was after comment or before comment process

Similarly what if someone gives impractical comment. I read someone wrote a comment about backlog removal in the I140 regulation. So those things will be rejected. Most comments were the giving unconditional and portable EAD without H1b renewal. One can argue for and against it. If that is legal then they could include otherwise they will reject those comments I am expecting that comments will exceed 25k before Feb. That itself will take 6 months to process. If 1 million comments are given then it will take 10 years to process
So, too many comments are only going to delay the whole process
What if there are almost equal number of comments 'for' and 'against' this regulation ?

For instance, not related but I was going through comments for recent FAA registration of small unmanned aircraft
Regulations.gov

The only thing I see on the final regulation passed is what people commented (Search for "Many commenters" , "Several commenters" etc ) and their response "IFR Requirement and Responses to Comments/Recommendations" explaining how they cannot implement the "suggestion"

So, our comments can all be put under few categories and can be easily responded on how it cannot be done?
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Old 02-07-2016, 02:55 PM
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RandomizedPrecision is a jewel in the rough RandomizedPrecision is a jewel in the rough RandomizedPrecision is a jewel in the rough
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Quote:
Originally Posted by nvedia View Post
So, too many comments are only going to delay the whole process
What if there are almost equal number of comments 'for' and 'against' this regulation ?

For instance, not related but I was going through comments for recent FAA registration of small unmanned aircraft
Regulations.gov

The only thing I see on the final regulation passed is what people commented (Search for "Many commenters" , "Several commenters" etc ) and their response "IFR Requirement and Responses to Comments/Recommendations" explaining how they cannot implement the "suggestion"

So, our comments can all be put under few categories and can be easily responded on how it cannot be done?
Here is the sobering reality. You DON'T have too many choices. Things have been manipulated against us and we, as a community, are an impatient bunch who don't seem to be able to coalesce around anything very well. Every interest group uses that to screw us over.

You can either stay quiet, do nothing and keep pondering about all the scenarios that might or might not happen.

OR

You can continue to post clear unambiguous comments that leave nothing open to interpretation about what we feel about the rule.

Every agency is required to review all public comments and consider them before drafting the final rule. Yes, there is a chance that nothing might come out of all of this - but NOTHING will for sure if we just sit on our asses and do nothing. There is something to be said about strength in numbers - so if they see many many people complaining about how useless this rule is to them, questioning the process and any improprieties that might have occurred in its drafting then it should make them think long and hard before rejecting these comments.

IV's directive is simple for now. Comment clearly (with "I DO NOT Support" in the first statement) and comment often. Rest assured you will get the technical comments soon and you will need to restate them so that it does not get counted as a mass mailer.

Trust me, all the cartels (AILA, COC etc.) are going to wait till the last minute and then post their comments so that no one will get too much of a chance to critique them when the comment period is live. I think that is absolutely the right strategy for IV to do the same.
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  #5 (permalink)  
Old 02-08-2016, 07:18 AM
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Default

Quote:
Originally Posted by RandomizedPrecision View Post
Here is the sobering reality. You DON'T have too many choices. Things have been manipulated against us and we, as a community, are an impatient bunch who don't seem to be able to coalesce around anything very well. Every interest group uses that to screw us over.

You can either stay quiet, do nothing and keep pondering about all the scenarios that might or might not happen.

OR

You can continue to post clear unambiguous comments that leave nothing open to interpretation about what we feel about the rule.

Every agency is required to review all public comments and consider them before drafting the final rule. Yes, there is a chance that nothing might come out of all of this - but NOTHING will for sure if we just sit on our asses and do nothing. There is something to be said about strength in numbers - so if they see many many people complaining about how useless this rule is to them, questioning the process and any improprieties that might have occurred in its drafting then it should make them think long and hard before rejecting these comments.

IV's directive is simple for now. Comment clearly (with "I DO NOT Support" in the first statement) and comment often. Rest assured you will get the technical comments soon and you will need to restate them so that it does not get counted as a mass mailer.

Trust me, all the cartels (AILA, COC etc.) are going to wait till the last minute and then post their comments so that no one will get too much of a chance to critique them when the comment period is live. I think that is absolutely the right strategy for IV to do the same.
That is exactly the same thing I had in my mind "strength in numbers"

I am not sure about the reason behind "not coalesce around", I believe most people don't even know about this regulation, there is no awareness

Still was expecting a response from IV since they have been doing this for more than 10 years and they would know best
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