Attachments
Dear Ms. Reid:
The Women’s Refugee Commission (“WRC”) writes to comment upon the joint notice of proposed rulemaking issued by the Department of Homeland Security and Department of Justice (the “Departments”) on June 15, 2020, entitled “Procedures for Asylum and Withholding of Removal; Credible Fear and Reasonable Fear Review” (the “Proposed Rule”).
The Proposed Rule would put in place an unprecedented array of new standards and requirements that will make asylum and withholding of removal unavailable to many applicants who face persecution for their beliefs, actions and identity, and who would previously have been eligible for relief. The result will be that many, including many women and children, will suffer persecution and death, even though our country’s laws provide for relief. The Proposed Rule is contrary to our nation’s laws, and a dramatic departure from its tradition as a place of refuge for those who are prosecuted for what they believe or simply who they are.
The limited duration of the comment period and the overwhelming scope of the proposed changes makes it impossible for WRC to respond fully to each aspect of the Proposed Rule. We therefore focus in these comments on the aspects of the Proposed Rule that will most directly and profoundly impact applicants fleeing gender-based violence or discrimination.