On 29 September, AGU submitted a public comment to the Department of Homeland Security (DHS) Docket No. ICEB-2025-0001, titled “Establishing a Fixed Time Period of Admission and an Extension of Stay Procedure for Nonimmigrant Academic Students, Exchange Visitors, and Representatives of Foreign Information Media.” If enacted, this regulatory change could have harmful impacts on our Earth and space science community in the U.S. and across the globe. Read the full comment: 

 

On behalf of the American Geophysical Union (AGU) and our global community of more than half a million Earth and space scientists and allies, we are writing with our strong concerns over the proposed changes to Duration of Status policies outlined in DHS Docket No. ICEB-2025-0001, titled “Establishing a Fixed Time Period of Admission and an Extension of Stay Procedure for Nonimmigrant Academic Students, Exchange Visitors, and Representatives of Foreign Information Media.”  

We have several concerns about the proposed changes to the Duration of Status and extension of stay procedures, especially as they impact F visas. These proposed changes would not only disincentivize exceptional global talent from coming to the United States for their education but also create confusion and unrealistic expectations for science students to finish their studies in four years. More than 75% of doctoral degrees awarded in 2023 were to students in STEM fields, and over one-third of those awardees completed their studies on a temporary visa like the F1. However, because science and research do not happen on preset timelines and are often dependent on access to facilities and infrastructure like telescopes, satellite data, and labs, Ph.D. STEM doctoral awardees science Ph.D. programs take an average of 5.6 years to complete.¹   

Applying for an extension of stay will also add to the uncertainty and pressure students will face under a 4-year limit. Currently, the U.S. Citizen and Immigration Services (USCIS) is experiencing an extraordinary backlog of applications.² Requiring potentially hundreds of thousands of students to apply for extensions to complete their studies will exacerbate that backlog. Not considering the time to process extensions will increase the likelihood that applicants will exceed their automatic extension of 240 days, creating unnecessary additional administrative burdens on students and USCIS.  

The proposed changes – especially the time limits – could also interfere with or eliminate a student’s ability to change their course of study, even if it’s clear that an emerging area of research would better serve public interests. The U.S. relies on global talent for emerging science and technology areas deemed critical to national security and economic prosperity. In 2021, international students made up the majority of Ph.D. candidates in computer and information sciences (59%), engineering (60%), and mathematics and statistics (54%),³ all of which contribute to artificial intelligence and quantum information services. Not only would an inability to change programs detract from the global talent that the U.S. depends on, requiring students to rapidly exit from the country decreases the change for the U.S. to benefit from these skill sets.  

America became a global leader in research, development, and technology creation in large part because of the global talent we attract and often retain. While AGU recognizes that these categories of visas are non-immigrant visas, students and researchers coming to the United States do build professional connections and careers that enable them to establish permanent residency in the United States. With a notable shortage of STEM professionals in the United States, we should be incentivizing and attracting talent from around the world not discouraging them. 

For these reasons, AGU opposes the proposed changes to the Duration of Status and extension of stay policies and asks the Department not to move forward with them.