EB-3 Worldwide Unavailable: Visa Bulletin Algorithm is Wrong

eb3algorithm

New Member
Disclaimer: I take no responsibility for accuracy of information provided. Please use at your own risk. I am not an attorney.

The July 2005 Visa Bulletin showing the worldwide EB-3 category as unavailable is, in my opinion, based on an incorrect algorithm that assigns all available Q4 2005 EB-3 numbers to Schedule A.

My above assertion is based on the following assumption: the VO did not make the widely assumed mistake of releasing Q4 2005 numbers in the prior quarters. They have been doing the same math for many years now to go wrong this one time. In any event, even if for argument’s sake it is assumed that “the Employment Third and Third Other Worker categories have reached their annual limits” (i.e. 19% allotment for Q4 2005 has been erroneously used up in the prior quarters) still there will be unused EB-1 overflowing to EB-2 and unused EB-2 overflowing into EB-3 DURING Q4 2005. For this waterfall of unused numbers also to be “unavailable” to EB-3, EB-2 will have to have retrogressed for at least one country (i.e. EB-2 demand exceeds EB-2 supply), which is not the case. Remember, per country EB limits have been done away with under AC-21, thus creating a continuous linkage across quarters, countries, and EB categories.

The more likely scenario is the following: After the Real ID act was passed creating the 50,000 visas to be recaptured for Schedule A, the sub-algorithm that was created within EB-3 was as follows:
(i) if the applicant is Schedule A, and if EX category is current (which it is), then reserve a visa.
(ii) if reserved a visa in (i) above, then reduce that from current year’s EB-3 availability.

So suddenly, the EB-3 availability goes to 0!!!. Instead of retrogressing by 5, 10 or 15 years (i.e. demand exceeds supply) – it just becomes unavailable (i.e. total Schedule A demand is greater than allocated Q4 2005 EB-3 plus overflow Q4 2005 EB-3 availability, as created by that algorithm)

Of course, the correct algorithm would incorporate what has been publicly declared “when the regular EB-3 visa numbers are available for certain Schedule A EB-3 applicants, they will take out the numbers from the regular EB-3 numbers first.” Thus the correct algorithm should have been:
(a) for entire EB-3, determine the overall cut off date
(b) for any Schedule A applicant with priority date later than overall cut off, assign from EX quota.

The purpose of this analysis is to persuade some enterprising immigration attorney to file a request under Freedom of Information Act to be able to review the Visa Office algorithm. The amount of publicity such an action would lead to, and associated goodwill/new business generation potential, is tremendous.
 
I do wonder why we have unavailibility for EB3 in the last quarter. I thought we have certain percantage allotted for each quarter to avaoid unavailbility. Is DOS saying after alotting Visa to EB1 and EB2 , nothing is available for EB3. before start of the quarter?
I did not expect unavailibility at begining of a quarter. Can some reputed attorneys get the fact on what basis the EB3 become unavailable.
 
Hmmm...

No offence meant to you. You are attributing certain serious abilities like designing an algorithm to arrive at cut off dates or to make EB3 unavailable! One can better study particle physics than try to attribute intelligence and try to derive the algorithm based on their actions! Again, no offence meant to you. All my ire is against their misguiding pronouncements.

I agree with your waterfall or trickledown from EB1 to EB2 to EB3... Pl take a look at my yesterday's post or better look at the USCIS stats for 2002 and 2004, where both years' the EB1 and EB2 are almost fully used by the respective categories and almost nothing trickled down to EB3. So, there is a possibility that nothing is available, but the Visa Office is working based on 'projections' and are unable to run a query against their databases for a more reasonable date. Now, I am guilty of attributing to them a serious ability!!

Have a nice day!
 
i wonder if DOS didn't know what they were doing so they decided to dedicate the last quarter of 2005 to actually count the number of visas and evaluate how Schedule A affected the availability.

I am expecting the PD's to move to some month in 2003 starting October 2006 and within a few months the visa availability will again disappear as soon as we have more and more applications from the BEC getting approved.


Hanuman55 said:
No offence meant to you. You are attributing certain serious abilities like designing an algorithm to arrive at cut off dates or to make EB3 unavailable! One can better study particle physics than try to attribute intelligence and try to derive the algorithm based on their actions! Again, no offence meant to you. All my ire is against their misguiding pronouncements.

I agree with your waterfall or trickledown from EB1 to EB2 to EB3... Pl take a look at my yesterday's post or better look at the USCIS stats for 2002 and 2004, where both years' the EB1 and EB2 are almost fully used by the respective categories and almost nothing trickled down to EB3. So, there is a possibility that nothing is available, but the Visa Office is working based on 'projections' and are unable to run a query against their databases for a more reasonable date. Now, I am guilty of attributing to them a serious ability!!

Have a nice day!
 
Reply from VO Source

I received the following reply from an attorney, who forwarded the message from someone at VO. It appears to me that the concept of "visa numbers being released per quarter" is meaningless, since 27% were released for Q3 EB-3, and much more than 27% (27% plus 19% for Q4) were used up. How could USCIS grab more than the available numbers during a quarter is a mystery. I would have thought that there exists an up to the minute counter on availability and usage, and they revisit this counter just before issuing each month's bulletin. And the VO found out about this in the last 15 days of Q2, while publicly they were predicting "not too much movement either way" for PIC EB-3 is hilariously embarrasing.

=======
Reply:

I've got a friend who is close with the person at the State Department who does the number crunching and I passed your message along to him.

" On the ... attached, the writer is unaware of several things. He is correct in the way the added Schedule A visas should be handled--only tapped if a visa is not available from the EB-3 pool. And that is the way VO has interpreted it. If there is any doubt, a meeting or call with Charles Oppenheim would be the way to go. No FOI is needed. Charles is a straight shooter.

The e-mail is correct that there is substantial fall down from EB-5, -1, and -2. However, this is already accommodated in the projections. It is not precisely correct to say that AC21 eliminated country quotas. It made available all surplus worldwide numbers to all countries, but when there is no surplus in the worldwide number, the country quota kicks back in.

What has happened is that CIS has kept increasing the number of adjustments adjudicated and projected to be adjudicated. The total EB visas avaialble in FY2005 (w/o the 50k Schedule A) is 248k. CIS was doing over 20k per month for the first six months, causing the retrogression. But in the third quarter, this approached 30k per month. If they used over 120k through March and 210k through June, there are less than 40k left--less than 2 months supply. These are the old priority dates because they are I-485s based on labor certs. EB-1 and -2 remain current because they get first shot at what is left. But even they could go unavailable if the 40k are used.

I could go into more detail, but the bottom line is that I think VO has t right. But if CIS were to stop processing at this rate, there could be unused visas at the end. However, I do not think that VO is charging the Schedule A's against the 248k that are generally available. But everyone should want to recapture anything that does not get used along with the 91k that were left on the table in conference. "
 
Top