Comment Submitted by Legal Aid Justice Center
AnonymousOpposeAdvocacy
Summary: The Legal Aid Justice Center, an organization providing legal representation for low-income immigrants, opposes the proposed changes to Form AR-11. They argue that the expansion into collecting employment, education, and public benefits data exceeds the form's statutory purpose, creates unnecessary administrative burdens, chills access to public benefits, and violates privacy and Paperwork Reduction Act requirements.
July 6, 2026
John R, Pfirrmann-Powell Acting Deputy Chief
Office of Policy and Strategy Regulatory Coordination Division USCIS
Re: COMMENT IN OPPOSITION to Agency Information Collection Activities; Reinstatement, With Change, of a Previously Approved Collection for Which Approval Has Expired: Alien Change of Address, 91 Fed. Reg. 24910, OMB Control No. 1615-0007, Docket ID USCIS-2008-0018
To Whom It May Concern,
The Legal Aid Justice Center appreciates the opportunity to provide the following comments in response to the Notice of Proposed Rulemaking regarding the Proposed Changes to the AR-11, Alien Change of Address.
The Legal Aid Justice Center (LAJC) has been providing legal representation for low-income individuals in Virginia since 1967. Our mission is to seek equal justice for all by direct representation, community organizing, and large-scale systemic advocacy. LAJC’s Immigrant Justice Program supports low-income immigrants in their efforts to fight for justice and fair treatment.
The Legal Aid Justice Center (LAJC) strongly opposes the proposed rule. For the reasons detailed in the comments that follow, LAJC urges United States Citizenship and Immigration Services (USCIS) to immediately withdraw their current proposal to change the form and dedicate efforts to maintaining a straightforward system of address reporting, protecting the data and privacy of immigrants, and abiding by the statutory limitations place on them by Congress.
Please see attached for full comment.
Sincerely,
Rohmah A. Javed, Legal Director
Claudia Arias, Legal Intern
Legal Aid Justice Center
Immigrant Justice Program
6402 Arlington Boulevard. Suite 1130
Falls Church, VA 22042