During a Stakeholder meeting held September 8, 2011, participants commented that withdrawal of EADs during the appeal process placed a significant financial burden on typically low-skilled laborers and the most vulnerable. Participants suggested economic need should be considered as a factor in extending employment authorization. Participants also argued that EADs are often the only identification documents held by TPS holder, without which TPS holders can be unable to acquire other documents such as drivers licenses. Participants also argued that TPS is often withdrawn or denied due to government error. Allowing TPS holders to retain EADs during the appeal process can reduce detrimental effects of such mistakes. Participants also argued that the revocation of EADs can also result in an unnecessary governmental buden. USCIS will review the concerns raised and consider the proposal in the formulation of new regulations.
