The Immigrant Legal Advocacy Project, (ILAP), respectfully submits the following comments regarding the interim final rule (IFR), Appellate Procedures for the Board of Immigration Appeals (Docket No. EOIR-26-AB37; RIN 1125-AB37). We recommend the rule be rescinded in its entirety as it severely undermines access to due process in the U.S. immigration system without legitimate justification, with particularly harmful impacts on the most vulnerable people navigating the system.