In a new, 60-second radio ad airing in New Hampshire and Iowa, ex-MA Gov. Mitt Romney once again tries to use "Sanctuary Cities" as a way of distinguishing himself from Rudy Giuliani.

Romney hasn't yet accused Giuliani of supporting amnesty; the very concept of Sanctuary Cities implies an amnesty from the law.

The Republican candidates give the least attention to the arguably the most difficult part of the immigration question: what they'd do with those illegal immigrants who haven't committed additional crimes? Deport them? Imprison them? "Regularize them?"

Both Giuliani and Romney insist they oppose amnesty, but because immigration hardliners have defined amnesty so broadly, it's hard to see how any regularization or normalization proposal would pass muster with talk radio hosts and the Tancredo wing of the party.

Here's what Romney has said:

Speaking on's video interview program 'PostTalk,' Romney said he had no desire to 'round them up as one big group' and try to send illegal immigrants back to their native countries. Instead, he said the idea is 'to take people who are here today and working here and replace them gradually and humanely with our own citizens as well as with legal immigrants who come in to take their place

In the back of their minds, some (not all) Giuliani sympathizers believe that Romney is making a coded appeal to the anti-elitist bent of the Republican base. "Newark, San Francisco and New York City," in this view, are proxies for urban disorder and cultural permissiveness.

Script For "Exceptional" (Radio:60):

ANNOUNCER: "Immigration laws don't work if they're ignored.

"That's the problem with cities like Newark, San Francisco and New York City that adopt sanctuary policies.

"Sanctuary cities become magnets that encourage illegal immigration and undermine secure borders.

"As Governor, Mitt Romney didn't wait on Washington. He acted to make our immigration laws work.

"Mitt Romney is the exceptional Governor who took a stand so State Police could enforce federal immigration laws.

"Mitt Romney said 'No' to drivers' licenses for those here illegally.

"Mitt Romney insisted on teaching our kids in English.

"And as President, Mitt Romney will cut back federal funds to cities that provide sanctuary to illegal immigrants."

GOVERNOR MITT ROMNEY: "Legal immigration is great. But illegal immigration, that we've got to end. And amnesty is not the way to do it."

ANNOUNCER: "Mitt Romney – an exceptional leader for exceptional new challenges."

GOVERNOR MITT ROMNEY: "I'm Mitt Romney and I approved this message."

ANNOUNCER: "Paid for by Romney for President,"

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