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Expansion of Expedited Removal

R​‌‍‍‍‌‍‍‌‍‌‌‍‍‍‌‍‌‌‌‍​ead the following Notice published in the Federal Register expanding expedited removal:https://www.federalregister.gov/documents/2019/07/23/2019-15710/designating-aliens-for-expedited-removal Answer the following whether the expansion of expedited removal should have gone through Notice and Comment beforebeing implemented. You may wa​‌‍‍‍‌‍‍‌‍‌‌‍‍‍‌‍‌‌‌‍​nt to consider the following questions: (1) Are you persuaded that the good cause exception to N&C applies? (in other words, that it would be impractical, unnecessary, or contrary to the public interest to go through N&C?); (2) Is DHS’s “discretionary” request for comments after making the change effective an adequate subs​‌‍‍‍‌‍‍‌‍‌‌‍‍‍‌‍‌‌‌‍​titute?