Agency Information Collection Activities; Reinstatement, With Change, of a Previously Approved Collection for Which Approval Has Expired: Alien Change of Address

The National Immigration Project, a national nonprofit membership organization, opposes the proposed expansion of Form AR-11. They argue that adding questions about employment, education, and public benefits exceeds the form's core purpose of reporting address changes, imposes unnecessary burdens on noncitizens, and creates significant enforcement risks and chilling effects on access to essential services.

Bay Area Legal Aid opposes the proposed changes to Form AR-11, arguing that the new requirements for reporting employment, education, and public benefits exceed the form's intended purpose of reporting address changes. They contend that the expansion will unduly burden immigrants, create a chilling effect on participation in safety net programs, and potentially jeopardize the safety of survivors of domestic violence and human trafficking.

JCFS Chicago opposes the proposed changes to Form AR-11, arguing that requiring immigrants to disclose information about public benefits, employment, and schooling turns a routine requirement into a surveillance tool. They express concern that these changes will create a chilling effect, causing immigrants to avoid reporting address changes for fear of deportation or negative impacts on their cases.

Gale Feldman, a private individual, opposes the proposed changes to Form AR-11 that would require immigrants to disclose information regarding public benefits, employment, and schooling. The commenter argues that these requirements act as a surveillance tool that could lead to deportation and create a chilling effect, preventing people from reporting necessary address changes.

The New Jersey Consortium for Immigrant Children (NJCIC) opposes the proposed changes to Form AR-11, arguing that the collection of information regarding employers, schools, and public benefits exceeds USCIS's statutory authority and violates the Paperwork Reduction Act. They express concern that the new requirements will impose an undue burden on immigrant children, create a chilling effect on their access to rights and benefits, and pose safety risks for those seeking victim-based protections.

The Minnesota Department of Human Services and the Minnesota Department of Children, Youth, and Families oppose the expansion of Form AR-11 to collect information on employment, schooling, and receipt of means-tested public benefits. They argue the change would create significant administrative burdens, compromise data privacy, and deter individuals from seeking essential services due to fears of immigration enforcement.

The Massachusetts Law Reform Institute (MLRI), representing the Immigration Coalition (IMCO), opposes the proposed changes to Form AR-11. They argue that the new requirements for reporting public benefits are unlawful, create an undue administrative and financial burden on non-citizens and state agencies, and are designed to generate fear rather than serve a practical purpose.

A coalition of state Attorneys General and the District of Columbia opposes the proposed changes to Form AR-11, arguing that the new requirements for employment, education, and public benefits information are overbroad, burdensome, and lack statutory authority. They contend that the agency is attempting to bypass the Administrative Procedure Act and that the collection of such sensitive information at the time of a simple address change is arbitrary and potentially harmful to residents.

Stop AAPI Hate, a coalition dedicated to ending racism and discrimination against Asian Americans and Pacific Islanders, opposes the proposed revisions to Form AR-11. They argue that the new questions regarding employment, education, and public benefits are unnecessary, create fear of immigration enforcement, and lack sufficient data security protections.

Greater Hartford Legal Aid, a non-profit law firm, opposes the proposed changes to Form AR-11 because they add unnecessary and over-inclusive questions regarding employment and means-tested benefits. They argue that this information is already collected elsewhere, creates confusion for recipients of specific services, and could have a chilling effect on parents seeking educational opportunities for their children.