shorter terms than one year, based on individual determinations.211 The underlying policy justification noted that limitations “often require an alien whose underlying status is longer than one year, or whose underlying application will remain pending with BCIS for longer than one year, to apply for renewal of the EAD every year, creating a burden on the applicant and an additional workload for BCIS.”212 Despite this interim rule, there is no standard practice for granting stateless individuals a multi-year EAD.213 Practice Point When requesting an EAD, consider submitting a request for a multi-year EAD citing to 8 C.F.R. § 274a.12(c)(18) or 8 C.F.R. 274a.12(c)(14), depending on the stateless individual’s situation. In addition to those factors typically included in a request for an EAD, highlight that because of an individual’s statelessness, there is a significant likelihood that she will remain indefinitely in the United States, and requiring her to annually renew the EAD creates hardships both in terms of expense and continuity of employment. According to the Interim Rule, validity periods would be based on criteria such as “The applicant’s immigration status, general processing time for the underlying application or petition, required background checks and response times for background checks by other agencies, as necessary; other security considerations and factors as deemed appropriate by BCIS.” NATIONAL IMMIGRATION LAW CENTER, Under New Interim Rule, USCIS May Issue EADs Valid for Longer or Shorter than One Year, 18 IMM. RTS. Update 5 (Aug. 9, 2004); see also 69 FR 45555. 212 69 FR 45555. 213 In both 2006 and 2008, the CIS Ombudsman recommended that USCIS start implementing the 2004 Interim Rule by issuing multi-year Employment Authorization Documents. See RECOMMENDATION FROM THE CIS OMBUDSMAN TO THE DIRECTOR, USCIS (Mar. 20, 2006); RECOMMENDATIONS ON USCIS PROCESSING DELAYS FOR EMPLOYMENT AUTHORIZATION DOCUMENTS, USCIS (Oct. 2, 2008). 211 50