DHS wants to make biometric data collection mandatory for everyone associated with any immigration benefits request. This includes US citizens involved in the application. I just submitted a Public Interest Comment criticizing this proposal. www.mercatus.org/research/pub...

This proposal expands the scope of a type of surveillance that many find especially invasive, akin to giving up a piece of yourself. As my colleague @kristenrosec.bsky.social argues, surveillance can be an affront to dignity. www.kristenrcollins.com/uploads/1/1/...

As @kristenrosec.bsky.social explains, “degrading experiences of surveillance discourage individuals from numerous forms of political participation because it communicates to them that they are members of a class of citizens that the government is likely to ignore, rendering participation futile.”

The proposed rule has other perverse consequences. The rule says that missing a biometrics appointment will lead to denied claims, and you can't reschedule except in "extraordinary circumstances." This threatens to close off legal immigration pathways, simply for a missed appointment.

As @mclem.org has documented in research for @piie.com, legal immigration pathways and illegal pathways are substitutes. www.piie.com/publications... When legal immigration pathways are closed off, we will likely see more illegal immigration.

Another concerning feature of the proposal is its effect on VAWA & T nonimmigrant visa self-petitioners. These visa categories enable victims of abuse & trafficking to leave their abusers by self-petitioning. Currently, these applicants are required to demonstrate "good moral character."

DHS highlights that submitting biometrics may be an easier way to demonstrate good moral character than current options. That's good! But for some self-petitioners, biometrics may be more invasive than alternative means. They may be deterred from self-petitioning, and stay with an abuser as a result

This is especially concerning in a time when applicants & petitioners may be fearful about attending USCIS appointments, given ICE detaining people at their appointments. www.nbcnews.com/news/us-news...

Moreover, consider the rigid requirements around biometrics appointments again. What if a survivor misses an appointment & is denied her self-petitioning option as a result? What if she stays with her abuser as a result, and suffers further abuse?

To avoid this, DHS should: 1) Allow more flexibility in biometrics appointments and interviews so that self-petitioners can reschedule when necessary. 2) Allow the use of biometric data as an option for demonstrating good moral character, rather than making it mandatory for all self-petitioners.