Policy Integrity encouraged the Department of Homeland Security ("DHS") to both supplement its Regulatory Impact Analysis (“RIA”) for its Proposed Rule on Deferred Action for Childhood Arrivals ("DACA") and more thoroughly address several arguments that it previously offered against the DACA program in its rescission memos. In particular, DHS should:
- Make further use of existing scientific and economic research to quantify and monetize key unquantified benefits in the RIA, such as improvements in mental health, increased belonging and hope for the future, advance parole, ancillary benefits from employment authorization documents, and cost savings from streamlined enforcement encounters
- Offer more evidence that the DACA program has no significant effect on legal or illegal immigration, in light of concerns raised by the U.S. District Court for the Southern District of Texas and in the Nielsen Rescission Memo
- More thoroughly address policy arguments such as litigation risk and case-by-case enforcement that DHS previously offered as justification to rescind the DACA program.