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本帖最后由 huamaogy 于 2015-11-10 11:33 编辑
我总结了一下rule里面支持的观点和DHS需要comment的点。希望给大家写comment一点思路。大家可以多列举实际的例子。比如科研上的成就有没有对普通美国人带来福利，潘石屹给哈佛捐款啊等等。
For people who want to write a powerful comment to support the OPT STEM extension！(Summary of the proposed rule document) ..
. From 1point 3acres bbs
Below I summarized 1)the points from the proposal that support the OPT STEM extension, 2) previous comments on the 2008 proposal that criticize the OPT STEM extension and how DHS will modify the terms to protect U.S. workers and 3) the new requirements that DHS are seeking comment on. I think a meaningful comment should address at least one of above points. Data/real examples would be very powerful to support your arguments.. 1point3acres
1) The points from the proposal that support the OPT STEM extension:. Waral dи,
1.1 International students have historically made significant contributions to the U.S economy, through the payment of tuition and living expenses for self and family.
1.2 Foreign students significantly promote cultural understanding, and contribute to the overall economy by building global connections between their hometowns and U.S. host cities.. 1point 3acres
1.3 Foreign STEM students contribute more specifically to a number of advanced and innovative fields that are critical to national prosperity and security by conducting scientific research, developing new technologies, advancing existing technologies and creating new products and industries.
1.4 Research has shown that foreign students who earn a degree and remain in the United States are more likely than native born workers to engage in activities, such as patenting and the commercialization of patents that increase U.S. labor productivity.
1.5 The United States has long been a global leader in international education. However US’s share of foreign students decreased, due to increasingly competitive international education programs from other countries.
1.6 DHS believes that students in STEM fields should be encouraged to pursue meaningful projects that contribute to a deeper understanding of their field of study. This type of significant project—often involving a grant or fellowship application, management of grant money, focused research, and publication of a report—typically requires several years to complete.
. .и
2) Previous comments on the 2008 proposal that criticize the OPT STEM extension (rebut on these criticism in your comment) and how DHS will modify the terms to protect U.S. workers
. Χ
2.1 The demand for technical workers was very weak in engineering occupations and growing modestly in computing and mathematics occupations.
2.2 When combined with H-1B, L-1, and other skilled workers, the number of students taking advantage of the STEM OPT extension would distort the domestic labor market.
2.3 Employers would prefer to hire F-1 students on STEM OPT extensions because these students would work for lower wages.. Waral dи,
2.4 Some U.S. firms had previously advertised STEM positions as being available only to OPT students.
With respects to above criticisms, there may be additional STEM opportunities obligation: A student may only participate in a STEM practical training opportunity in which the employer attests that: the employer will not terminate, lay off, or furlough a U.S. worker as a result of providing the STEM OPT to the student. So the practical training has no appreciable adverse consequences on the U.S. labor market.
2.5 Eliminate the “Cap-Gap” provision that is intended to avoid the inconvenience of temporary gaps in status, which would normally require individuals to leave the country and thereby suffer significant disruption to their careers and family. DHS continues to believe that the Cap-Gap provision is a commonsense administrative measure fully consistent with the underlying purpose of the practical training program.
. 1point3acres.com
3) The new requirements that DHS are seeking comment on
3.1 Many research projects take years to complete, and under the new STEM OPT extension, a student would have increased opportunities to learn how to apply for a grant or fellowship, become a responsible steward of grant money, initiate a study or project, see the study or project through to conclusion, write a report and obtain peer review, and have the report published. DHS requests public comment and the submission of empirical data in relation to this proposition. In addition, DHS requests public comment regarding the length of research, development, testing and other projects for which STEM graduates (regardless of nationality) from U.S. universities are typically assigned in the workplace.
3.2 DHS requests public comment on the proposed 24-month STEM OPT extension and the ability for qualifying students to receive an additional such STEM OPT extension based on a second STEM degree. In particular, DHS requests comment from STEM students, educational institutions, and employers on the appropriate STEM OPT extension length to ensure that practical training for STEM students is most meaningfully educational and beneficial to them, and less disruptive for institutions and employers. DHS is particularly interested in public input regarding whether 24 months is the appropriate duration for STEM OPT extensions, or whether a shorter or longer duration (e.g., 17 months or 36 months) is preferable, and why.
3.3 In the event that a final rule resulting from this rulemaking does not take effect before the vacatur of the 2008 IFR, DHS will lack clear regulatory authority to grant pending applications for STEM OPT extensions. In that case, DHS will evaluate options to address pending applications, such as returning such applications and requiring re-filing upon completion of a final rule. DHS seeks comments on these and other options for addressing pending applications if a final rule is not in place prior to the court’s vacatur, including comments on the harm that such a gap may cause. DHS welcomes comments regarding each of the proposed transition procedures described above, including alternatives to the potential courses of action identified here.
3.4 DHS requests comment from the public on the academic benefit of the STEM OPT extension for STEM students generally as well as for specific STEM fields. DHS also requests comment on whether changes to the current content or structure of the list may be helpful or appropriate.
3.5 DHS believes that the E-Verify enrollment requirement would continue to provide an efficient and accurate manner of better ensuring that students participating in the STEM OPT extension are legally authorized to work. DHS requests comment on this proposal, including from students and employers that have had experience with this requirement under the 2008 IFR.
3.6 DHS requests public comment, especially from employers and labor organizations, on all aspects of this provision, including the types of business factors employers would use to evaluate whether their workers are similarly situated.
3.7 DHS requests comment on the feasibility and effectiveness of each of these provisions, including the obligations to confirm (1) that the terms and conditions of a STEM OPT student’s employment are commensurate with those for similarly situated U.S. workers, and (2) that no U.S. worker will be terminated, laid off, or furloughed as a result of a STEM OPT opportunity.
3.8 DHS requests comment from universities, DSOs, and other interested members of the public on how DHS can most effectively ensure an appropriate level of participation in this program by educational institutions.
3.9 DHS requests comment from the public on all aspects of this proposal, including the feasibility and effectiveness of imposing a firm accreditation requirement as a condition of participation in the STEM OPT extension.
. 1point 3 acres
3.10 DHS also believes that the proposed unemployment limits (150 days) for students granted a STEM OPT extension would provide additional flexibility when compared to the 120 days permitted under the current program’s 17-month extension. With this change, DHS acknowledges the concerns of commenters who described the challenges that international students face in locating and obtaining training experiences in the United States. DHS welcomes comments on this issue. |
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