Comment Submitted by The Asylum Seeker Advocacy Project (“ASAP”)

Summary: The Asylum Seeker Advocacy Project (ASAP), a national membership organization representing over 700,000 asylum seekers, opposes the proposed rule. They argue that the rule "silently" eliminates the 30-day processing requirement for initial asylum-based work permits, which they claim is arbitrary, capricious, and violates the Administrative Procedure Act.