On Oct. 18, 2019, CLINIC submitted a public comment opposing the interim rule reorganizing EOIR. CLINIC’s opposition is based on the rule’s formal establishment of the Office of Policy, relocation of the Office of Legal Access Programs under the Office of Policy, and authorization for the EOIR director to issue appellate decisions in certain cases. In our comment, CLINIC describes how the proposed changes may allow political considerations to influence OLAP operations and appellate decisions.