Comment Submitted by Alex Petyshkin

I respectfully ask USCIS to carefully consider the practical impact this proposed rule may have on people who were lawfully admitted to the United States under humanitarian parole and have already become productive members of their communities. I came to the United States through the Uniting for Ukraine program and received employment authorization lawfully. Since then, I have worked continuously, paid federal and state taxes, and supported myself and my family without relying on public assistance. My wife and I both hold master's degrees and built professional careers before coming to the United States. We came prepared to support ourselves through our education, skills, and work. Since our arrival, we have supported ourselves entirely through our own work and earnings. We have not relied on government financial assistance and have paid for all of our housing, food, transportation, health care, and other living expenses ourselves. Like most working families in the United States, my family depends on my income to pay for housing, utilities, food, health care, transportation, and other ordinary living expenses. My employment is not optional—it is the means by which I support my family and remain financially independent. The fact that I work continuously to support my family, pay taxes, and remain financially independent is itself strong evidence of economic necessity. I work as a broadcast maintenance engineer for a major television broadcasting company in the United States. My responsibilities include maintaining the technical systems that support daily television broadcasting, local news, and emergency communications. This is specialized technical work that requires training, experience, and reliability. Like many employers in technical fields, my employer has invested significant time and resources in hiring and training me. The proposed changes could create unnecessary uncertainty for both employees and employers. Even individuals who have fully complied with all immigration requirements, maintained lawful status, established stable careers, and consistently contributed to their communities could face additional barriers to continuing lawful employment. I am particularly concerned about requirements that may depend on an employer's participation in E-Verify. An employee who has fully complied with all legal requirements should not lose the opportunity to continue lawful employment because of an employer's administrative decisions or participation in a particular verification program—matters that are entirely outside the employee's control. I am also concerned that employment authorization could become too dependent on the discretionary judgment of an individual officer rather than on clear, objective, and consistently applied standards. Families who have complied with the law, worked continuously, paid taxes, and remained self-sufficient should be able to understand the requirements in advance and rely on a fair and predictable process, rather than face uncertainty based on subjective determinations. Nothing in my record suggests that granting employment authorization is contrary to the public interest. To the contrary, I have consistently complied with U.S. laws, maintained lawful employment, paid taxes, and supported my family without relying on public assistance. I am also concerned about requiring individuals who have already demonstrated years of lawful employment to repeatedly prove their "economic necessity" to work. For people who consistently work, pay taxes, support their families, and remain financially independent, continued lawful employment is itself strong evidence that employment remains economically necessary. Requiring additional proof in these circumstances creates an unnecessary administrative burden without providing a clear public benefit. Employment authorization allows humanitarian parolees to support themselves, contribute to the U.S. economy, pay taxes, and reduce reliance on public resources. Individuals who have demonstrated compliance with U.S. laws, maintained good moral character, and established stable employment should continue to have a clear, fair, and predictable process for maintaining their work authorization. Thank you for considering my comments and for taking into account the experiences of lawfully admitted humanitarian parolees who are working hard to contribute to the United States.