The Petitioner, a plant researcher, seeks second preference immigrant classification as either an advanced degree professional or an individual of exceptional ability in the sciences, arts or business, as well as a national interest waiver of the job offer requirement attached to this EB-2 classification. See Immigration and Nationality Act (the Act) section 203(b)(2), 8 U.S.C. § 1153(b)(2). After a petitioner has established eligibility for EB-2 classification, U.S. Citizenship and Immigration Services (USCIS) may, as matter of discretion, grant a national interest waiver if the petitioner demonstrates: (1) that the foreign national's proposed endeavor has both substantial merit and national importance; (2) that the foreign national is wel I positioned to advance the proposed endeavor; and (3) that, on balance, it would be beneficial to the United Statestowaivetherequirementsofajobofferandthusofalaborcertification. MatterofDhanasar,26 l&N Dec. 884 (AAO 2016).
The Director of the Texas Service Center denied the petition, concluding that the record did not establish the national importance of the proposed endeavor or that awaiver of the requirement of ajob offer would be in the national interest. The matter is now before us on appeal. 8 C.F.R. § 103.3.
The Petitioner bears the burden of proof to demonstrate eligibility by a preponderance of the evidence. Matter of Chawathe, 25 l&N Dec. 369, 375-76 (AAO 2010). We review the questions in this matter de nova. Matter ofChrista's, Inc., 26 l&N Dec. 537, 537 n.2 (AAO 2015). Upon de nova review, we will dismiss the appeal.
Law
To establish eligibility for a national interest waiver, a petitioner must first demonstrate qualification for the underlying EB-2 visa classification, as either an advanced degree professional or an individual of exceptional ability in the sciences, arts, or business. Because this classification requires that the individual's services be sought by a U.S. employer, a separate showing is required to establish that a waiver of the job offer requirement is in the national interest.
Section 203(b) of the Act sets out this sequential framework:
(2) Aliens who are members of the professions holding advanced degrees or aliens of exceptional ability. -(A) In general. - Visas shall be made available ... to qualified immigrants who are members of the professions holding advanced degrees or their equivalent or who because of their exceptional ability in the sciences, arts, or business, will substantially benefit prospectively the national economy, cultural or educational interests, or welfare of the United States, and whose services in the sciences, arts, professions, or business are sought by an employer in the United States.
(B) Waiver of job offer -
(i) National interest waiver.... [T]he Attorney General may, when the Attorney General deems it to be in the national interest, waive the requirements of subparagraph (A) that an alien's services in the sciences, arts, professions, or business be sought by an employer in the United States.
Section 10l{a)(32) of the Act, 8 USC § 1101(a)(32), provides that "[t]he term 'profession' shall include but not be limited to architects, engineers, lawyers, physicians, surgeons, and teachers in elementary or secondary schools, colleges, academics, or seminaries."
The regulation at 8 C.F.R. § 204.5(k)(2) contains the following relevant definitions: Advanced degree means any United States academic or professional degree or a foreign equivalent degree above that of baccalaureate. A United States baccalaureate degree or a foreign equivalent degree followed by at least five years of progressive experience in the specialty shall be considered the equivalent of a master's degree. If a doctoral degree is customarily required by the specialty, the alien must have a United States doctorate or a foreign equivalent degree.
Exceptional ability in the sciences, arts, or business means a degree of expertise significantly above that ordinarily encountered in the sciences, arts, or business.
Profession means one of the occupations listed in section 101(a)(32) of the Act, as well as any occupation for which a United States baccalaureate degree or its foreign equivalent is the minimum requirement for entry in the occupation.
In addition, the regulation at 8 C.F.R. § 204.5(k)(3)(ii) sets forth the specific evidentiary requirements for demonstrating eligibility as an individual of exceptional ability. A petitioner must submit documentation that satisfies at least three of the six categories of evidence listed at 8 C.F.R. § 204.5(k)(3)(ii).
Furthermore, while neither the statute nor the pertinent regulations define the term "national interest," we set forth a framework for adjudicating national interest waiver petitions in the precedent decision Matter of Dhanasar, 26 l&N Dec. 884 (AAO 2016). In announcing this new framework, we vacated our prior precedent decision, Matter of New York State Department of Transportation, 22 l&N Dec. 215(Act.Assoc.Comm'r1998). Dhanasarstatesthatafterapetitionerhasestablishedeligibilityfor EB-2 classification, U.S. Citizenship and Immigration Services (USCIS) may grant a national interest waiver as matter of discretion. See also Poursina v. USCIS, 936 F.3d 868, 2019 WL 4051593 (9th Cir. 2019) (finding USCIS' decision to grant or deny a national interest waiver to be discretionary in nature). As a matter of discretion, the national interest waiver may be granted if the petitioner demonstrates: (1) that the foreign national's proposed endeavor has both substantial merit and national importance; (2) that the foreign national is well positioned to advance the proposed endeavor; and (3) that, on balance, it would be beneficial to the United States to waive the requirements of ajob offer and thus of a labor certification. See Dhanasar, 26 l&N Dec. at 888-91, for elaboration on these three prongs.
Analysis
The Director determined that the Petitioner qualifies for the underlying EB-2 classification. The issue on appeal is whether the Petitioner has established eligibility for a national interest waiver under the Dhanasar framework. While we do not discuss each piece of evidence individually, we have reviewed and considered each one.
The Petitioner plans to continue his research intol Iplant propagation. The record contains background materials about the benefits of plant propagation and how it has many applications, including to food security, pharmaceuticals, and the environment. Regarding the environment, plant propagation can assist in rapid reforestation, combatting invasive plants, pest control, and removing pollutants from the air. We conclude that research in this area has substantial merit. Nevertheless, the Petitioner has not established the national importance of his proposed endeavor.
Although the Petitioner provided substantial background on the process of plant propagation and what it is, he provided little information about his specific proposed endeavor. He stated that he will continue his research, but the Petitioner has not explained how this will occur. For instance, the record does not indicate whether the Petitioner plans to work for a pharmaceutical company, with a team on a farm, in a lab at a university, independently in his own backyard, or in some other capacity. In Dhanasar, we held that a petitioner must identify "the specific endeavor that the foreign national proposes to undertake." Id. at 889. Without sufficient information concerning the specific proposed endeavor, as opposed to the field of plant propagation as awhole, the impact of the proposed endeavor is difficult to ascertain. The Director explained that the Petitioner had not offered support for the claim that his individual work would have national implications. We agree.
As stated, the Petitioner highlighted the applicability and importance of plant propagation in various sectors, including food security, pharmaceuticals, and the environment. When determining national importance, the relevant question is not the importance of the industry or profession in which the individual will work; instead, we focus on the "the specific endeavor that the foreign national proposes to undertake." See id. at 889. To establish national importance, the Petitioner must demonstrate the proposed endeavor's impact, rather than relying upon the importance of plant propagation or its applicability. To illustrate by example, if the Petitioner researches independently using his own lab p. 4 and greenhouse, he would still need to establish how others in the research community would know about his results and would accept them as valid. The Petitioner has not established how his research adds information to the pool of knowledge already available in this area.
In Dhanasar, we noted that "we look for broader implications" of the proposed endeavor and that "[a]n undertaking may have national importance for example, because it has national or even global implications within a particular field." Id. at 889. To support a finding of national importance, the Petitioner submitted various letters of recommendation. While one author described the Petitioner's research methodology as "groundbreaking" and asserted that the Petitioner "developed protocols" for plant propagation, the evidence does not support these conclusions. Generalized conclusory statements that do not identify a specific impact in the field have little probative value. See 1756, Inc. v. US. Att'y Gen., 745 F. Supp. 9, 15 (D.D.C.1990) (holding that an agency need not credit conclusory assertions in immigration benefits adjudications). The evidence does not suggest that the Petitioner's methods or protocols differ from or improve upon those already in use. In other words, the evidence does not support a finding that his proposed endeavor will have any implications within a particular field.
The Petitioner has not provided sufficient information about his specific proposed endeavor. In addition, based on the record as currently constructed, the Petitioner has not established that his work stands to impact the broader field or otherwise have implications rising to the level of national importance. Therefore, he has not established eligibility for a national interest waiver.
Ill. CONCLUSION
The documentation in the record does not establish a specific proposed endeavor, nor does it establish the national importance of the proposed endeavor as required by the first prong of the Dhanasar precedent decision. Therefore, the Petitioner has not demonstrated eligibility for a national interest waiver. Further analysis of his eligibility under the second and third prongs outlined in Dhanasar would serve no meaningful purpose.
Because the identified reasons for dismissal are dispositive of the Petitioner's appeal, we decline to reach and hereby reserve remaining arguments concerning eligibility under the Dhanasar framework. See INS v. Bagamasbad, 429 U.S. 24, 25 (1976) ("courts and agencies are not required to make findings on issues the decision ofwhich is unnecessary to the results they reach"); see also Matter of L-A-C-, 26 l&N Dec. 516, 526 n.7 (BIA 2015) (declining to reach alternative issues on appeal where an applicant is otherwise ineligible).
As the Petitioner has not met the requisite first prong of the Dhanasar analytical framework, we conclude that he has not established he is eligible for or otherwise merits a national interest waiver. The appeal will be dismissed for the above stated reasons.
ORDER: The appeal is dismissed.