Public Comments

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seth morrow
PRA Comments, EOIR (EOIR)
[EXTERNAL] Public comment — OMB 1125-0001 — total annual burden arithmetic inconsistency
Monday, August 24, 2026 10:06:54 PM

Executive Office for Immigration Review,
I am submitting a focused comment on the August 20, 2026 60-day notice for OMB Control
No. 1125-0001 (Forms EOIR-42A and EOIR-42B).
The notice states a combined total annual burden of 88,873 hours. However, the burden table
lists 8,492 hours for EOIR-42A and 80,380 hours for EOIR-42B. Those two published
subtotals sum to 88,872 hours, not 88,873.
Because this notice specifically asks for comment on the accuracy of the burden estimate and
the validity of the methodology, I recommend reconciling the one-hour discrepancy before the
package is submitted to OMB. If the intended total is 88,873, the underlying row-level value
or rounding method should be corrected or explained; if the row values are correct as
published, the combined total should read 88,872.
This is a narrow arithmetic/data-integrity comment; I am not taking a position on the
substantive immigration policy reflected in the forms.
Thank you,
Seth Morrow
Individual public commenter