Comment Submitted by Nataliia Koptsevych

The proposed rule raises serious concerns regarding the requirement to demonstrate the necessity of employment authorization on a discretionary basis. For many categories of applicants, including children, proving the "need" for employment authorization may be extremely difficult or even impossible. Children often cannot independently justify such a need, despite the fact that possessing a valid Employment Authorization Document (EAD) is essential not only for future employment opportunities but also for obtaining a Social Security Number, opening access to financial services, and ensuring equal participation in everyday life in the United States. Lawfully present families, including those admitted through humanitarian programs or other authorized pathways, should not face additional discretionary barriers that create unequal treatment compared to other lawfully present families. Additionally, USCIS should establish mandatory adjudication deadlines for Form I-765 applications. The current processing delays have already created situations where individuals lose lawful employment authorization for many months through no fault of their own. Families must continue supporting themselves, paying rent, buying food, and caring for their children. These unreasonable delays effectively force otherwise law-abiding individuals into impossible situations where they may feel compelled to violate immigration or employment laws simply to survive. Such outcomes undermine respect for the law rather than promote it. The final regulation should preserve clear, objective eligibility standards for employment authorization and include enforceable processing time limits to ensure that applicants are not harmed by agency delays beyond their control.