Comment Submitted by Cory Dransfeldt

Docket ID: USCIS-2008-0018 OMB Control Number: 1615-0007 I write in strong opposition to this proposed reinstatement and expansion of Form AR-11, Alien Change of Address. This proposal weaponizes administrative compliance. The change-of-address requirement under INA section 265 exists so the government can maintain accurate records. It is a routine obligation placed on non-citizens in the interest of orderly administration. Expanding it to compel disclosure of means-tested public benefit receipt fundamentally perverts that purpose — transforming a neutral reporting requirement into a mechanism for building deportation cases against people who did nothing more than follow the law. The benefits at issue are, in the vast majority of cases, benefits the recipients were legally entitled to receive. Congress established eligibility rules through PRWORA in 1996 and restricted access significantly. Non-citizens who received means-tested benefits did so because they qualified under those rules. Using their lawful compliance with one part of the legal system against them through another is not enforcement — it is entrapment by bureaucracy. The chilling effects of this policy will be severe and broad. When immigrants understand that accessing any public benefit — or even reporting an address change accurately — creates a documented basis for deportation proceedings, many will disengage entirely from government systems. That means children going without school services, families avoiding emergency medical care, and people living in fear of routine civic interaction. This is not a side effect of the policy. Given its design, it is the point. The public charge ground of deportability under INA section 237(a)(5) is not new, but the systematic infrastructure this proposal creates to enforce it — mandatory self-reporting, cross-referencing with benefits agencies, data collected under compulsion — represents a qualitative escalation that cannot be justified on administrative grounds. It is punitive in design and cruel in effect. The Paperwork Reduction Act asks whether a proposed collection is necessary for the proper performance of agency functions. This collection is not. Its purpose is not administrative efficiency. It is surveillance of vulnerable people engaged in lawful behavior, for the purpose of removing them from the country. I urge USCIS to abandon this proposal entirely.