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Dear Editor:
Attached are FAIR's public comments on the proposed regulation requiring acknowledgment of the duty of address change notifications on various immigration forms. FAIR supports the proposed amendment, which establishes a simple, just, and effective method to enable non-citizens in the United States meet their affirmative statutory requirement to inform the federal government of their current address. Consistent enforcement of the change of address regulations is a necessary component of immigration law enforcement.

However, the legal rationale offered by the Service to justify the regulatory change is in conflict with and misrepresents the comprehensive statutory scheme established by Congress to govern the conduct of aliens in the United States. Our public comment articulates the correct law of alien registration, enacted by Congress to safeguard our country against non-citizens whom our courts have characterized as subversives, enemies, and, in current public usage, terrorists.

A correct analysis of alien registration law supports FAIR's additional practical recommendations that the required acknowledgement also confirm that adult aliens are aware of their related duty to carry documentation of registration on their person at all times, that the Attorney General authorize a more stringent special registration of aggravated felons and other deportable aliens, and that a systematic public information program would help to minimize the inconvenience of compliance for legitimate foreign visitors and immigrants.

Michael M. Hethmon
FAIR Staff Attorney


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