The Daily Demarche
Wednesday, April 20, 2005
Visas and Immigration - Comment and Critique, Part III
This, the final installment of my musings on visas and immigration, touches on the area with which I am least familiar: what happens when a foreign visitor enters the country. Therefore I’m going to be doing a fair amount of speculation, although it is informed to the extent that I have worked fairly closely with members of all three of the immigration related branches of DHS (ICE, CBP, and CIS).

First off, I should point out that my experience with ICE/CBP/CIS people has given me the impression that they are hard working, dedicated public servants who, like most everyone else I’ve met in the Federal Government, are trying to do the best they can for our country. Unfortunately, in many instances these individuals are let down by a truly byzantine bureaucracy and a system that fails to properly provide the right resources to the right people at the right time. It makes me question whether the decision to subsume the old INS and Customs Service into DHS was the right thing to do, although further down the page I’m going to suggest further tinkering with the services.

Citizenship and Immigration Services (CIS) handles, among other things, petitions for immigrant visas (which, if approved, lead to Lawful Permanent Resident or “green card” status) and naturalizations. As such, they have no law enforcement component, unlike the other two agencies previously mentioned (CBP and ICE). My general impression is that they are often overworked and understaffed, although this varies greatly between Field Offices and Service Centers. However, generally speaking, petitions for immigrant visas often face very long delays when filed in the United States.

The remit of Customs and Border Protection (CBP) includes, inter alia, inspections at the various ports of entry and patrolling our borders. Customs agents, which have their own directorate within CBP, are organized among 20 Field Operations offices, 312 ports of entry, and 14 preclearance stations. The Border Protection directorate, on the other hand, is divided into sectors, each responsible for a particular stretch of the border.

Immigration and Customs Enforcement (ICE), on the other hand, defines as its task to be “...responsible for identifying and shutting down vulnerabilities in the nation’s border, economic, transportation and infrastructure security.” Like CBP, ICE has a law enforcement component. ICE does deportations, investigations, and houses the Federal Air Marshall Service (FAMS). Each individual ICE Office has its own bureaucratic structure. The Office of Investigations and FAMS both use a Special Agent In Charge (SAC) system similar to that of the FBI. The Office of Detention and Removal Operations is subdivided into various field offices.

As you can see the current system as I have spelled it out is rather opaque, to be charitable, and I have simplified it considerably in hopes of saving the two readers who haven’t yet fallen asleep. It is, in my opinion, far too complex and unwieldy. Furthermore, heads of the various Sectors, Field Offices, and District Offices have great autonomy, resulting in sometimes wildly inconsistent practices from one location to another. That this colossus of an organization is large is a necessity, and as I have noted elsewhere, the various organizations need more people in virtually all areas. I believe, however that such far flung and disparate organization is too decentralized, meaning that resources cannot be allocated effectively as needs might arise.

To remedy this, I propose the following:

First, combine CBP and ICE. Then, do away with the myriad internecine organizational structures, and bring them all together. I suggest that this massive bureaucracy take as its inspiration another huge US government bureaucracy: the US military. Divide the United States up into five commands: Northern (dealing with our Canadian border), Pacific, Midwestern, Atlantic and Southern (dealing with our Mexican border). In so doing, the government can streamline the various bodies by allocating personnel and resources more efficiently.

Policies and procedures might not be consistent between an office in Duluth, Minnesota and one in El Paso, Texas, but at least they will be consistent between El Paso and San Diego. If intelligence indicates an upsurge in illegal immigrants coming through one area and a decrease in another, commanders could rapidly reposition assets to the area where they are most needed, even if to do so would have previously crossed jurisdictional lines.

I realize that this proposal would hardly eliminate bureaucratic infighting among the main commands. But it could change the scope and location of the infighting from the micro to the macro level, decreasing the amount and pettiness of small-scale turf battles which our system is currently rife with.

As far as CIS goes, I believe that their problems are in large part due to chronic understaffing. Hiring more personnel would help. But there are other options on the table. For this, CIS, who as their primary brief handle a lot of paperwork, should look towards another megalithic government agency known for handling paperwork: the Social Security Administration (SSA). Believe it or not folks, SSA is considered to be one of the best run government agencies. They accomplish this by embracing modernization and technology and emphasizing training. This makes the existing personnel work better, more courteously (which many people will agree CIS is in some need of), and more efficiently. To do this also requires a fairly strong hand to push things along.


This is a very cursory discussion of the large problems facing a truly gargantuan agency. I could go on, but I think I've pretty much said my piece. I hope you've enjoyed it, and I continue to encourage readers to leave comments.
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dé·marche 1) A course of action; a maneuver. 2) A diplomatic representation or protest 3) A statement or protest addressed by citizens to public authorities.

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