Witching Hour For DOD Comments On Foreign Workers
November 01, 2006, 07:38 PM
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The deadline for making comment to the Department of Defense proposal for relaxing security requirements for foreign workers is coming soon. I hope there are a few more ghosts and goblins who are lurking in the shadows with commentary because the deadline is November 2.

Universities are the main group who seems to be pushing for relaxing security standards. They submitted a flurry of comments the last two weeks.

Universities and their sub-contractors hope that by gutting security they can hire more researchers on visas such as H-1B and TN. You can bet they will also assign research to foreign students that work for free!

The most conspicuous absence on the website is a single comment from an organization that purports to represent American workers. Ditto for immigration reform groups. Weird, huh?

Why is there such a lack of concern about mass immigrations of foreign spies and saboteurs into our research labs? If you are one of the few Americans that think this is an important issue, you have until November 2 to tell the DoD why.

I have some new information below, so be sure to read it. It's not all repeat!

***** PROCEDURE FOR VIEWING COMMENTS *****

The procedure for viewing documents has changed once again. Fortunately it's simpler than the 9 steps I listed last time. They change this website faster than I can send newsletters!

Follow these directions verbatim.

1) Go to this page at Regulations.Gov.

2) Enter "2004-D010" without quotes in the search engine. Leave all other settings at default.

3) Click the submit button.

4) In the Docket ID column click DARS-2006-0065.

5) You will see comments listed under the column labeled "Views". Just click on them to read.

***** PROCEDURE FOR POSTING COMMENTS *****

  • The easiest way to post comments is to send an email to dfars@osd.mil. You must put "Case 2004-D010" in the subject heading without the quotes. You can also put other stuff in the subject heading if you want to add more.
  • Please do not CC me on your email posting because the CC will show online. If you want to send me a copy, forward the email instead of using CC. It's probably bad form to have the CC posted.
  • If you send your email in HTML format instead of plain text they will automatically generate a PDF file, which looks far better than just plain text.
  • They will also post attachments in PDF or Word format. I don't recommend Word format because many people can't view MS documents.

Alternate posting methods

  • Repeat steps 1-4 above, or click the back button on your browser.
  • Click the "add comments" icon. They have several other alternatives including an online form. Some people have reported that the online form is buggy, so be sure to have a separate copy of your writings in case it crashes.

My two-bits worth of advice

Take this exercise very seriously, because the DoD may make a published document out of all this material. This is a great opportunity to go on the record with your views! Read this privacy statement from the webpage:

Any information (e.g., personal or contact) you provide on this comment form or in an attachment may be publicly disclosed and searchable on the Internet and in a paper docket and will be provided to the Department or Agency issuing the notice.

As expected, the universities have wasted no time posting comments. Most of their comments reference the following document on the Association of American Universities website (AAU).[AAU comment:PDF]

Universities and big business are pushing these changes in order to exploit cheap foreign labor and to cut costs by gutting security requirements. However true, be frugal about emphasizing the cheap labor argument because the DoD might think it's a good idea if money can be saved. Perhaps a better line of argument would be to explain why replacing Americans is bad for security and how it harms our technology infrastructure.

Consider it fair game to copy other people's comments. The universities are doing it. In the DFARS document they logged the number of comments for or against a certain provision, so in some respects the quantity of comments is just as important as the content.

It wouldn't hurt if you spent some time reading my previous newsletters on the DoD as well as some of the comments already submitted at the website.

For further reading, and more background on this issue, read my commentary. It is document DARS-2006-0065-0012.

I also wrote this essay on VDARE.com Be sure to follow up on the links. DoD Eases Security Rules For Foreign Workers, October 05, 2006

I wrote a shorter version that was targeted for newspaper op-eds. It was picked up by a syndicated editorial company and then the op-ed was sent out to hundreds of newspapers, but unfortunately it hasn't been published. These types of stories are a very tough sell in the mainstream media.

You can read that op-ed column on the Californians for Population Stabilization website:Pentagon Proposes to Gut National Security, September 2006

If any of you are in the media and want to publish the column in your newspaper, please contact CAP-S.org here.