Chertoff's action excluded the Department of Homeland Security from having to follow laws "protecting the environment, endangered species, migratory birds, the bald eagle, antiquities, farms, deserts, forests, Native American graves and religious freedom." In an editorial, the Times criticized Chertoff for his use of waiver authority, stating: "To the long list of things the Bush administration is willing to trash in its rush to appease immigration hard-liners, you can now add dozens of important environmental laws and hundreds of thousands of acres of fragile habitat on the southern border." A report issued by the Congressional Research Service, the non-partisan research division of the Library of Congress, said that the unchecked delegation of powers to Chertoff was unprecedented: After a review of federal law, primarily through electronic database searches and consultations with various CRS experts, we were unable to locate a waiver provision identical to that of §102 of H.R. 418—i.e., a provision that contains 'notwithstanding' language, provides a secretary of an executive agency the authority to waive all laws such secretary determines necessary, and directs the secretary to waive such laws. On June 23, 2008, the Supreme Court of the United States declined to hear a constitutional challenge to the 2005 law that gave Chertoff waiver authority. Actions regarding illegal immigration In September 2007, Chertoff told a House committee that the DHS would not tolerate interference by sanctuary cities that would block the "Basic Pilot Program," which requires some types of employers to validate the legal status of their workers. In 2008 it was reported that the residential housekeeping company Chertoff had hired to clean his house employed undocumented immigrants. Post-DHS career Since leaving government service, Chertoff has worked as senior of counsel at the Washington, D.C. law firm of Covington & Burling. He formed The Chertoff Group (TCG) on February 2, 2009, to work on crisis and risk management. The firm is also led by Chad Sweet; he served as the Chief of Staff of Homeland Security while Chertoff was Secretary and also had a two-year stint at the Directorate of Operations for the CIA. The firm also employs Charles E. Allen, Larry Castro, Jay M. Cohen, General Michael V. Hayden and other former high-ranking government employees and appointees. Chertoff was also elected as Chairman of BAE Systems for a three-year term, beginning May 1, 2012. Chertoff co-chairs the Bipartisan Policy Center's Immigration Task Force. Chertoff was part of