Submitted via regulations.gov on September 29, 2025

Office of Regulatory Affairs and Policy
U.S. Immigration and Customs Enforcement
Department of Homeland Security
500 12th Street SW
Washington, DC 20536

RE: CAJ submission to the consultation on the revision to the I-Visa Program for
Representatives of Foreign Media

This submission speaks to the striking concerns of Canadian news organizations, labour groups, and individual journalists and media workers, regarding the proposed revisions to the I- visa program.

We urge the Department of Homeland Security (DHS) to reconsider these unnecessary restrictions and maintain a system that allows Canadian foreign correspondents to do their jobs effectively.

The changes resulting from 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, 90 Fed. Reg. 42070 will have deleterious impacts on the ability of Canadian reporters, who have worked in the United States freely for generations, to explain the intricacies of American life.

Earlier this month, the Canadian Association of Journalists (CAJ), as well as several Canadian media organizations, signed a joint statement expressing our collective opposition to the changes proposed by DHS. In that letter, we expressed that the U.S. has been a global norm entrepreneur vis-a-vis freedom of expression and a strong independent press. In this submission, we urge the U.S. to consider how these proposed changes will serve to undermine this legacy.

But this proposal does more than signal a shift in America’s global values. It is one that will actually hurt Americans.

Canadian news organizations, and foreign correspondents, contribute to the American economy. They pay taxes. They travel domestically. They purchase goods and services. They recreate. These are all facts that support the bottom line of the U.S. economy.

Foreign bureaus, as other media-related stakeholders have pointed out in these submissions, also hire American-born staff to assist in the gathering and dissemination of news and information.

We are deeply concerned that this proposed change is not being evaluated based on evidence. We note, for example, how the Proposed Rule 90 Fed. Reg. at 42,080 fails to cite specific reasons to think that holders of I-visas pose a risk to national security or any other government interest.

We would like to, moreover, emphasize our disagreement with Proposed Rule, 90 Fed. Reg. at 42,099, which states that eight months (240 days) is the “appropriate” amount of time it takes foreign reporters to do their work. This proposal is incongruent with the realities of journalistic practice that require media workers to have a deep understanding of America, its people, and its institutions to properly do their jobs.

Lastly, Proposed Rule, 90 Fed. Reg. at 42,076, states that “the number of representatives of foreign information media has nearly doubled” since 1985, when the existing framework was introduced. We believe resources to vet journalists have nearly doubled during that period as well and the current program already includes strict accountability, transparency and compliance by tying each visa to a specific journalist and their employer.

Next year marks a hallmark anniversary in America – the 250th anniversary since the signing of the Declaration of Independence. The semi-quincentennial should provide Americans with an opportunity to reflect upon its long-held ideals of advancing democracy. The anniversary should also serve as an inflection point, where Americans are afforded the opportunity to reflect and reconcile a quarter century of history – both good and bad.

Journalists will play a vital role in documenting these important debates. Erecting barriers to exclude Canadian journalists and media workers from participating in these events, however, runs counter to our longstanding bilateral relationship and shared history as friends and allies.

We the undersigned,

Brent Jolly, president, Canadian Association of Journalists (CAJ)
Angie Seth, president, RTDNA Canada
Brodie Fenlon, general manager & editor-in-chief, CBC News; Luce Julien, general manager, news and current affairs, French services, Radio-Canada
Canadian Journalism Forum on Violence and Trauma
Canadian Journalists for Free Expression (CJFE)
Carmel Smyth, president, CWA Canada
Centre for Free Expression (CFE)
Coalition for Women in Journalism
CTV News
Duff Jamison, CEO, Great West Media LP
Éric Trottier, vice-president 98,5 et des stations parlées, Cogeco Media
François Cardinal, deputy publisher, information vice-president, La Presse
J-Source
Jean-Philippe Pineault, general manager, News, Bell Media
Jennifer Moreau, North American representative on the executive board of the International Federation of Journalists
La Coopérative nationale de l’information indépendante (CN2i)
Metroland Media
News Media Canada
TFO
Toronto Star
Unifor
United Photojournalists of Canada
Winnipeg Free Press
Women Press Freedom

N.B. This submission addresses solely the proposed revisions to the regulations governing I-visas for international media representatives, and takes no position on the other visa categories addressed in the proposal.

The Canadian Association of Journalists is the country’s largest professional organization that serves to advance the interests of journalists from coast to coast to coast. The CAJ’s primary roles are public-interest advocacy work and professional development for its members.

For further information: Brent Jolly, president, Canadian Association of Journalists, brent@caj.ca

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