"ICE has always represented to the public that participation in Secure Communities is predicated on a formal agreement between ICE and each state. But in a December 2008 Secure Communities weekly report, ICE admits to negotiating with Pennsylvania to proceed with implementation without requiring the state to sign an agreement and without having notice of a database “hit” go to local agencies. Effectively this means that the program was secretly imposed in Pennsylvania and operated for months before local communities even became aware of it. ICE further notes in the weekly report that it will be pursuing this same approach in other states. And the stealth character of the operation is no insignificant detail. Though the program is going on its third year, ICE has never issued regulations or guidelines for its operation. Indeed, written agreements with the state serve as the only formalization of a program that entangles local police in immigration enforcement and endangers community safety."