When you think about who is going to be hit the hardest by pollution, whether it’s conventional air water and soil pollution or climate change, it is very often low-income communities and communities of color. The undercutting of these kinds of protections is going to have a disproportionate impact on these very same communities.
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Department of Homeland Security
and manages complaints against agents through the OPR. In addition, CRCL, OIG, GAO, and Congress all perform detention oversight. These multiple bodies place unmanageable and unreasonable burdens on ICE to manage several sometimes inconsistent audits/inspections at the same time.
IfOIDO remains a DHS component, the Secretary should immediately issue a directive stripping CRCL of its immigration portfolio. OIDO is in a better position with dedicated resources and immigration experts to perform this function than CRCLis. Allowing both offices to conduct detention oversight is duplicative and wasteful.
The Secretary should conduct a thorough review of the effectiveness of Directive 0810.1,” which is widely interpreted as requiring a wholesale referral of cases to OIG. In reality, OIG investigates only a small fraction of them and often sits on cases for longer than the five-day window specified in the directive. Meanwhile, the other agencies wait in limbo to execute their duties.
CISOMB. The Office of the Citizenship and Immigration Services Ombudsman should be eliminated. The DHS bureaucracy is too large, and the Secretary has too many direct reports. CISOMB’s policy functions can be performed (and sometimes already are) by OIG and GAO. The specialized case work can be moved into USCIS as a special unit, much like the IRS Taxpayer Advocate. This would require a statutory change to Section 452 of the Homeland Security Act of 2002.?°
If CISOMB continues as a DHS component, a policy should be issued that prohibits CISOMB from assisting illegal aliens to obtain benefits. Currently, approximately 15 percent-20 percent of CISOMB’s workload consists of helping DACA applicants obtain and renew benefits, including work authorization. This is not the role of an ombudsman. In addition, the government should be a neutral adjudicator, not an advocate for illegal aliens.
AGENCY RELATIONSHIPS
Itis critical to the achievement of the President’s policy objectives that all agencies and departments touching immigration policy work in sync with one another. While there are numerous areas in which such cooperation is critical, immigration has proven to be the most difficult. Accordingly, several objectives will be necessary for each of the following departments.
• Department of Health and Human Services: Agree to move the Office of Refugee Resettlement (ORR) to DHS or, alternatively, implement an aggressive and regular effort by the Secretary of HHS to ensure that ORRis fully pursuing presidential objectives in support of DHS.
• Department of Defense: Assist in aggressively building the border wall
system on America’s southern border. Additionally, explicitly acknowledge and adjust personnel and priorities to participate actively in the defense