President George W. Bush
The White House
1600 Pennsylvania Ave. N.W.
Washington, DC
Dear Mr. President:
We, the undersigned ethnic, religious, and civil rights organizations write to express our concern with the INS's ""Special Registration Program."" Our organizations are committed to working with America's leaders to enhance our security. We stand united in doing all we can to help make our nation safer. The United States has the fundamental right to maintain pertinent data on those who visit our nation on a temporary basis. However, the ""Special Registration Program"" is flawed in both design and implementation, and will not enhance our security
The Special Registration program appears to target people based on national origin, race and religion, rather than on intelligence information. With the exception of North Korea, all the countries in the program are Arab or Muslim. Moreover, the recent addition and subsequent removal of Armenia from the list of countries raises even more questions about the criteria and process by which countries are included in the list. To make matters worse, the registration process is being wrongly applied. Instead of identifying terrorists, the INS in some local offices is using the special registration procedure to identify and detain people who are on the path to permanent residency.
Not only is the call-in registration program ill-conceived, it also is being ineffectively implemented. The Department of Justice (DOJ) has not given the INS the staff, resources, and guidance necessary to do this job, and has not effectively disseminated information about the program. In fact, the INS/DOJ did not even issue a press release or post information about program requirements until December 6, only ten days before the December 16 deadline.
This program should be eliminated. Failing that, given the conditions referenced above, we urge the following:
Special Registration (or other future programs) should not detain or deport people who have a claim to legal status. Some INS offices are detaining and deporting people who are technically out of status, often due to INS delays and inefficiencies. In some offices, such as Los Angeles, large numbers of registrants have been detained. Some of these people have approved family or employment petitions and are eligible to adjust their status in the U.S. under Section 245(i), a program that you strongly support. It makes no sense from security or economic perspectives to target people who eventually will be granted lawful status because they have applications pending for lawful permanent status, have been issued employment authorization documents, or otherwise are eligible for lawful status.
THE DOJ/INS must adequately publicize program requirements, must initiate effective outreach programs, and hold harmless those who did not register because they did not know about the program. The DOJ/INS needs to do a better job of effectively disseminating information about the program. Dissemination and outreach is especially crucial given the drastic consequences for not registering and the fact that two other registration deadlines loom. DOJ/INS also must take responsibility for inadequately publicizing this program and its requirements by granting waivers for those who did not register for the program because they had no knowledge of it or because of the fear engendered by the mass arrest of registrants in some offices.
The INS must implement uniform procedures in their district offices, and these procedures must make sense. INS district offices have adopted widely disparate practices to implement special registration. Some District offices have been allowing attorneys to represent registrants, while others have not. Various District offices have announced different procedures for persons out of status who have a pending, valid application for permanent residence. In addition, each district office appears to be following different policies regarding documentation. Finally, there seems to be a wide degree of discretion from office to office on procedures ranging from fingerprinting to interview questions.
THE INS/DOJ needs to clarify registration requirements. Specifically the definition of 'national' in the guidance is unclear and has been interpreted differently by various INS district offices. The result has been that some aliens are being turned away from registration centers while others are unsure if they are required to register. The lack of outreach to the affected communities compounds this problem.
Special registration is a false solution to a real problem. We urge you to implement initiatives that address our security concerns, but also are effective and effectively implemented. These initiatives should target terrorists, not innocent immigrants, so as not to alienate communities whose cooperation is needed.
Given the gravity of the current situation, we will be contacting your office to request a meeting on this and related issues.
Sincerely,
National Organizations
Alliance of Iranian Americans (AIA)
American Civil Liberties Union
American Friends Service Committee (AFSC)
American Immigration Lawyers Association (AILA)
American Immigration Law Foundation (AILF)
American-Arab Anti-Discrimination Committee (ADC)
American Arab Institute (AAI)
Center for Constitutional Rights (CCR)
Center for Human Rights and Constitutional Law
Church World Service Immigration and Refugee Program
Council on American-Islamic Relations (CAIR)
Defending Immigrants Partnership
Immigrant Legal Resource Center (ILRC)
Immigration & Refugee Services of America (IRSA)
International Rescue Committee (IRC)
Japanese American Citizens League (JACL)
Labor Council for Latin American Advancement (LCLAA)
Lahore Foundation, Inc.
Lawyers Committee for Human Rights (LCHR)
Mexican American Legal Defense and Educational Fund (MALDEF)
National Asian Pacific American Legal Consortium (NAPALC)
National Coalition for Asian Pacific American Community Development (CAPACD)
National Coalition Against Domestic Violence (NCADV)
National Council of La Raza (NCLR)
National Federation of Filipino American Associations (NaFFAA)
National Immigration Forum (NIF)
National Immigration Law Center (NILC)
Organization of Chinese Americans (OCA)
Presbyterian Church, U.S.A., Washington Office
Salvadoran American National Network (SANN)
Sikh Mediawatch and Resource Task Force (SMART)
Tahirih Justice Center
United Methodist Committee on Relief (GBGM)
Regional, State, and Local Organizations
American Civil Liberties Union of New Jersey (Newark, NJ)
Arab Community Center Economic and Social Services (ACCESS) (Dearborn, MI)
American-Arab Anti-Discrimination Committee, LA Chapter (Los Angeles, CA)
Asian Law Alliance (San Jose, CA)
Asian Pacific American Legal Center of Southern California (Los Angeles, CA)
Catholic Charities of Santa Clara County (Santa Clara, CA)
Catholic Charities Immigration Legal Services (San Jose, CA)
Catholic Charities Immigration Legal Services (Washington, DC)
Central American Resource Center (Los Angeles, CA)
Fellowship of Reconciliation LA/OC Chapter (Los Angeles, CA)
Florida Immigrant Advocacy Center (FIAC) (Miami, Florida)
Haitian Community Service Center Of Atlanta (Decatur, GA)
Hate Free Zone Campaign of Washington (Seattle, WA)
Heartland Alliance for Human Needs & Human Rights (Chicago, IL)
Immigrant and Refugee Project, Washington Lawyers' Committee for Civil Rights and Urban Affairs (Washington, D.C.)
Illinois Coalition for Immigrant and Refugee Rights (Chicago, IL)
International Institute of New Jersey (Jersey City, NJ)
Lawyers' Committee for Civil Rights, San Francisco (San Francisco, CA)
Massachusetts Immigrant and Refugee Advocacy Coalition (MIRA) (Boston, MA)
Mexican American Bar Association of Los Angeles County (MABA) (Los Angeles, CA)
Mexican American Bar Association of Ventura County (Oxnard, CA)
Midsouth Peace and Justice Center (Memphis, TN)
Nashville Kurdish Forum (Nashville, TN)
Public Counsel (Los Angeles, CA)
Somali Family Care Network (SFCN) (Falls Church, VA)
South Asian Network (Artesia, CA)
Washington Defenders Immigration Project (Seattle, WA)