The Advocates for Human Rights (“the Advocates”), submits this comment related to DHS Docket No. USCIS–2025–0370 and urges the Department of Homeland Security (the “Department”) to withdraw the Notice of Proposed Rulemaking (“NPRM”) in its entirety. See Employment Authorization Reform for Asylum Applicants, 91 Fed. Reg. 8616 (Feb. 23, 2026) (DHS Docket No. USCIS-2025-0370). The NPRM would make sweeping changes to employment authorization for pending asylum applicants, including a potentially indefinite pause on new Employment Authorization Document (“EAD”) applications, a tripled waiting period, new discretionary and arbitrary eligibility barriers, and extended processing timeframes.