Read the comments here.

The Department of Homeland Security (DHS) proposes removing the regulatory provision which states that U.S. Citizenship and Immigration Services (USCIS) has 30 days to grant or deny an initial employment authorization application (EAD application) from the date an asylum applicant files the initial Form I-765. The stated purpose of the removal is to provide USCIS with sufficient time to process EAD applications.

The Niskanen Center believes removing the rule altogether, especially without a replacement, imposes unacceptable costs that dwarf the purported benefits.

This comment first describe why DHS’s cost estimates, as large as they are, are underestimates. Further, it makes conservative adjustments to derive more realistic, though still low, estimates. The comments conclude  with alternatives to consider that would better manage the costs.