REMI

What it decides

The name belongs to the company, not the product: the Department of Energy, announcing its State Energy Program evaluation on 16 November 2011, wrote that its assessment of direct and indirect job impacts "will use a 51-region (State) Regional Economic Models, Inc. (REMI) Policy Insight simulation model." Policy Insight is the model. EB-5 practice has collapsed the firm's initials into the model's name, which is why job studies speak of a REMI analysis. Its place in EB-5 rests on market practice alone. No provision of 8 U.S.C. 1153(b)(5), no paragraph of 8 CFR 204.6 and no chapter of USCIS Policy Manual Volume 6, Part G names REMI, RIMS II, IMPLAN or any other model. What those authorities require is generic. 8 U.S.C. 1153(b)(5)(E)(v)(I) lets an investor rely on "economically and statistically valid methodologies." 8 CFR 204.6(j)(4)(iii) and (m)(3)(v) accept multiplier tables, feasibility studies and other economically or statistically valid forecasting devices. Do not read the silence as meaning the choice is unreviewable. Under USCIS Policy Manual Volume 6, Part G, Chapter 2, an investor relying on an economic input-output model must demonstrate that the methodology is reasonable, and USCIS analyzes whether the multipliers and the assumptions about the project's geographic impact are reasonable, weighing factors such as the area's demographic structure, its contribution to the project's supply chains, and its socioeconomic connectivity. No model is pre-approved and none is barred. The brand on the report is not what decides the petition; the inputs and the geography are.

Governed by 76 FR 70994, 70995 (16 November 2011), Department of Energy, Energy Efficiency and Renewable Energy, "Proposed Agency Information Collection," naming the "51-region (State) Regional Economic Models, Inc. (REMI) Policy Insight simulation model" (https://www.federalregister.gov/documents/2011/11/16/2011-29603/proposed-agency-information-collection). No EB-5 authority names REMI or any competing model: verified against 8 U.S.C. 1153 (uscode.house.gov), 8 CFR 204.6 (ecfr.gov) and all eight chapters of USCIS Policy Manual Volume 6, Part G. Generic methodology standards at 8 U.S.C. 1153(b)(5)(E)(v)(I) and 8 CFR 204.6(j)(4)(iii), (m)(3)(v). Reasonableness, multiplier and geographic-impact review at USCIS Policy Manual Volume 6, Part G, Chapter 2, "Evidence of Job Creation" (https://www.uscis.gov/policy-manual/volume-6-part-g-chapter-2).