Things you can bring up as complaints in your comment:
This is invasive and a violation of privacy
This may in certain circumstances be a 4th Amendment violation
DHS border facilities collecting material do not have sufficient scientific quality to accurately evaluate what they’re attempting to measure
This will cause long administrative delays at the border due to sending samples off to be tested
This will overburden DHS staff and prevent them from addressing actual crime, trafficking, and other border security threats
In cases of intersex conditions, anyone needing to be detained will have to go to taxpayer-funded new facilities that will need to be built for those who can’t go to female or male facilities
How will documentation of assigned sex at birth help border agents visually identify adults against their identity documents, and be able to detain adults who are national security threats?
Will the forms needed to collect this be able to get Paperwork Reduction Act approval?
How expensive will the contract be to build a database to house this information?
What is your records plan for proper disposition according to schedules in the Federal Records Act?
How will you ensure PII is not inappropriately shared between databases within the various DHS functions?
Have you gotten Congressional appropriations that provide for the staffing, technology, contracts, facilities, and scientific equipment? What will the taxpayer burden be? Or is this whole idea an unfunded mandate?
In instances where this data needs to be shared with local, state, tribal, or federal law enforcement entities, do THEY have authorization to store the data? Have they all posted a System of Record Notice?
What is your plan for meeting Section 508 of the Rehabilitation Act requirements for accessibility in information and communications technology when dealing with people who are coming from all over the world speaking different languages? Do you have appropriated funds for meeting your accessibility requirements? Who is remediating the forms you’re giving out that you already need Privacy Act and Paperwork Reduction Act approval for?
That’s not an exhaustive or super nuanced list but if you want something to say that isn’t just “this is fascist actually” and bring up some topics that are serious administrative implementation roadblocks, there ya go, have some for free. If you want to learn more about being a stick in the mud pedantically reminding the government of its legal restrictions, I encourage you look at the wikipedia entries for anything I mentioned with capital letters on it.
Also don’t @ me that I’m not making trans issues as the most important thing here. We all know they are. We know what’s going on here. This list is about shit that requires an answer inside the bureaucracy. DHS divisions might not have multiple meetings on “are we being fair to trans people?” but they probably will on “is this going to violate the Paperwork Reduction Act?” and they definitely will on “hey is Congress actually going to PAY us to do literally any of this???”
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