Draft Comments to “Public Charge”

The national advocacy coalition against the expansion of public charge, Protecting Immigrant Families (PIF) has made submitting comments easy. Individuals, organizations, and businesses are able to submit their comments through the comment form at https://protectingimmigrantfamilies.org/#take-action. PIF has pre-populated its online form with a sample comment for you. Comments are due December 10, 2018.

Global Detroit encourages you to edit this pre-populated comment with your own thoughts that incorporate our draft comments below and your own analysis that highlights how you, your organization, or business will be impacted by the proposed rule. You can cut-and-paste them into the PIF online comment submission text box or you may submit via the instructions on the proposed rule change document at the National Archives, here.

The more specific and personal your comments, the more likely they are to be given consideration. It is important to note that the Federal Government is required to read and respond to every single comment and provide reasoning for why the proposed rule is still valid. If we all use the same sample comment, the administration can draft only one reason in response. But if we all insert our own truthful and personal reasons for opposing the public charge, the administration will be required to respond to all of those reasons. If they fail to, this could be grounds for legal action.

If you have any questions or need any support please contact Steve Tobocman, Executive Director, Global Detroit at steve@globaldetroit.com or (313) 516-9681.

Suggested Comments

General Comments

I oppose the Department of Homeland Security’s proposed rule change to vastly expand the “public charge” to cover millions of hard-working Americans, their U.S.-born citizen children, as well as hundreds of thousands of annual visa applicants seeking to pursue the American Dream. The proposed policy will make immigrant families afraid to access essential health, nutrition and shelter programs. By forcing choices no family should have to make, it puts our whole country at risk.

If finalized, the rule would impact millions of immigrant families hoping to secure their permanent future in this country. It will devastate a crucial source of population growth for struggling cities, like Detroit, across the Midwest and Northeast. It will devastate labor markets in critical U.S. industries, including hospitality, retail, service industries, construction, agriculture, manufacturing, and healthcare—even impacting our nation’s ability to attract top global talent in technology and advanced industries, putting our national economy at risk.

By creating a culture of fear, as well as forcing immigrant families to have to choose between various health care, housing, or food security needs and their immigration status, the proposed rule will reduce the use of critical health, food, and housing programs that will reduce spending in a variety of industries costing our economy billions of dollars and hundreds of thousands of jobs. States and localities also would be negatively impacted by the reduced participation in these programs that improve the health and well-being of their communities.

The Trump Administration should immediately withdraw its proposal. How you live your life and contribute to your community should define you in this country, not how much money you have. Immigration has been proven to be a critical component of economic growth and this proposal will cost American jobs, reduce tax revenues, and shrink economic output, hurting American workers, families, and communities.

Comments Specific to Restaurants and Retail Establishments

As a business owner, I am a job creator. My business’ ability to continue to provide jobs, pay taxes, and contribute to the American economy depends upon our ability continue or grow our revenues. Securing able and willing employees and staff is one of the most critical challenges that my business faces.

Even here in the city of Detroit—a city with one of the nation’s highest poverty rates—my business struggles to secure the talent we need to compete and to thrive. My business pays well above minimum wage [OPTIONAL: and offers health benefits]. With Michigan’s unemployment rate falling below 4 percent, it is inconceivable that the Department of Homeland Security is considering the proposed rule to expand the “public charge” to deny America’s business community the opportunity to secure the labor we need to stay in business.

The proposed expansion of the “public charge” reflects an historic and profound shift in American immigration policy and history as a welcoming nation where hard-working and ambitious families across the world could come and pursue the American Dream. Simply put, the proposed rule can have grave impacts on our nation’s workforce at a time where there are critical shortages throughout the economy as reflected by historically low unemployment numbers. In fact, according to New American Economy, 91 percent of all adults active in the labor force who would be affected by the public charge rule are employed. We cannot afford to lose these contributors to the American economy.

[OPTION – more detail on working-class positions]

Over the last two decades, the size of the U.S.-born population with a high school degree or less has significantly decreased. This trend is particularly evident among young workers, ages 25-44, the group typically most capable of doing physically demanding work. As this population declined, however, the number of jobs for workers with that education level held steady. Thus, real and persistent gaps in the American workforce have opened up, especially in agriculture, hospitality, and meatpacking. Foreign-born workers—a group considerably more likely than natives to lack education beyond high school—step in to fill those jobs that would otherwise remain vacant. 

While immigrants make up 16.5 percent of the working-age population in the United States, there are whole industries that are dependent on their labor. From 2008 to 2012, for instance, immigrants made up 72.9 percent of field and crop workers. In other large industries, such as construction, immigrant workers frequently take on the most physically demanding roles, while U.S.-born workers frequently prefer positions that require more English-language skills or experience in management or customer service. In fact, of the top 10 occupations with the largest share of immigrant workers, nine of them are labor-intensive in nature or involve repetitive, manual tasks. 

On its face the proposed rule targets immigrant families that provide this important labor often because these industry positions pay the poverty-level wages targeted by this proposed rule. Without this supply of labor, entire industries will experience critical labor shortfalls

Personal History Comment

I oppose the Department of Homeland Security’s shameful proposed rule change to “public charge.”  The proposed policy reflects an historic and profound shift in American immigration policy and history as a welcoming nation where hard-working and ambitious families across the world could come and pursue the American Dream.

I find this proposal particularly offensive because I would not be an American if this rule had been in place when  [I or my family member] migrated to the U.S. [Describe family member and their migration experience. For example:

My grandfather Morris Tobocman immigrated to Detroit from Poland to pursue the American Dream in 1910. He had almost no formal education, arrived penniless, and knew no English. Like so many immigrants—both during Detroit’s ascendance into one of America’s great cities and those arriving today—he worked with his hands (originally as a tinsmith) and did well enough to put two sons through architecture school at the University of Michigan.

My family story is a typical American story shared by tens of million of other American families and it’s a story essential to our nation’s and region’s character and future. Unfortunately, under this proposed rule change to “public charge” that story may no longer be possible and, as a result, our nation’s economic future lay in jeopardy.

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