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Dear Editor:
In a recent editorial, the Washington Post lists the challenges inherent in reforming our immigration bureaucracy and policy to enhance both national security and economic security. In light of Immigration and Naturalization Service (INS) Commissioner James Ziglar's resignation, the editorial stresses the importance of finding a replacement for Commissioner Ziglar who can as aptly manage both the enforcement of our nation's immigration laws and the improvement of service provision to newcomers.

The Post also makes some suggestions as to how these goals can be met institutionally. It recognizes as a first step the importance of adequately structuring our nation's immigration functions within the new Department of Homeland Security. The Post writes: "House-passed legislation would split the INS between the new department and the Justice Department, a bad formula that not only separates activities that should be related, but also could make it even harder to get the attention and funding needed to improve the agency's service operations. That must be corrected before any bill becomes law" ("Immigrants Aren't the Problem," Washington Post, August 27, 2002).

The Administration's own proposal also fails to effectively organize the immigration functions, burying them with a host of other agencies such as the Transportation Security Administration and Coast Guard in a "Border and Transportation Security" division. This structure virtually guarantees mission overload within that division, and does not give our immigration functions the attention they need at such a critical time.

A Senate proposal for the Department of Homeland Security, S. 2452, scheduled for floor action once Congress returns, intelligently organizes and elevates all immigration functions within the new department. This section of the bill must not be amended, as it puts the new immigration director in the best position to "manage reforms and enhance border protection without losing sight of the core commitment to civil liberties and to fair immigration policies."

Douglas Rivlin
National Immigration Forum