DHS is well aware that this rule is going to be struck down in court, so they don't even bother to do a defensible regulatory analysis.
For example, their estimate of costs that this rule will impose on the public over 10 years is a range between $241 million to $29 billion.
This morning, DHS released a new proposal for large new fees on Optional Practical Training (OPT), to be paid by schools:
$70,000 for one year of OPT, plus another $30,000 for the STEM extension.
DHS assumes that for STEM grads, there will be ZERO change in participation.