Comment Submitted by Wendy Stevens

I am writing to express my concern about the proposed changes to Employment Authorization Documents (EADs) and how they could affect Ukrainians and other people who are legally present in the United States under humanitarian programs. I have a Ukrainian friend who came to the United States legally through the Uniting for Ukraine program. She is a highly educated software engineer who is currently freelancing and actively looking for a full-time job. Like many Ukrainians I know, she wants to support herself, work legally, pay taxes, and contribute to the American economy. She is not looking for government assistance. She is looking for the opportunity to work. I am concerned that making it more difficult for people in humanitarian programs to obtain or renew work authorization could create a situation where people are expected to have a job before they can obtain a work permit, while at the same time employers are often unwilling or unable to hire someone who does not already have valid work authorization. This creates a difficult cycle: a person needs a work permit to obtain employment, but may be expected to have employment before receiving or renewing the work permit. This could be especially harmful to people who do not work in traditional employment arrangements. Many Ukrainians in the United States are freelancers, independent contractors, self-employed professionals, small business owners, or people who work for clients in different locations. They may not have one traditional employer who can provide a permanent job offer or participate in E-Verify. However, they still need to be able to work legally, report their income, and pay their taxes. I also know Ukrainians who are actively looking for jobs, starting businesses, working as independent contractors, providing professional services, and contributing to their local communities in many different ways. They work in technology, healthcare, elder care, childcare, construction, hospitality, education, transportation, agriculture, and other industries. Some are creating businesses and purchasing goods and services from American companies. Others rent homes, buy groceries, pay for transportation and healthcare, and spend their earnings in their local communities. Their ability to work legally contributes to the U.S. economy and generates tax revenue. Many of these people have no other source of financial support. They came to the United States because they were forced to flee a war, not because they wanted to depend on the government. They want to work and support themselves. For many, the ability to obtain a work permit is the difference between being financially independent and being forced into an extremely difficult situation through no fault of their own. Delays or restrictions in work authorization can also have consequences beyond the individual. A person may find an employer who is willing to hire them, but if the work permit process takes too long, the employer may not be able to wait. The person then loses the job opportunity and is placed back into the same cycle of being unable to obtain employment without work authorization. I believe the United States benefits when people who are legally present are able to work legally. They pay taxes, support local businesses, contribute to their communities, and reduce the need for public assistance. They also have a strong incentive to follow the law and maintain lawful employment. I respectfully ask USCIS to consider the real-world consequences of making employment authorization more difficult to obtain or renew, particularly for people who entered the United States through humanitarian programs and are trying to become self-sufficient. People who are legally present should have a realistic opportunity to work legally and support themselves. A system that makes it difficult to obtain work authorization while simultaneously requiring employment or a job offer can create an unfair and unrealistic barrier for many hardworking individuals. I hope USCIS will consider maintaining a fair and accessible process that allows legally present humanitarian immigrants to work, pay taxes, support themselves, and contribute to the United States. Thank you for considering my comments.