MM2 Comment Submitted by Mary Johnson

I am writing to submit a public comments regarding the Department of Homeland Security (DHS) Notice of Proposed Rulemaking to increase the fee for Form I-246, Application for a Stay of Deportation or Removal, from $155 to $755. I strongly oppose this drastic fee increase for the following reasons: 1. It Creates a Severe and Uncalled for Financial Difficulty Increasing the filing fee by $600 imposes an often-insurmountable financial burden on individuals who are already facing removal from the United States. For low-income individuals and families, a $755 fee pushes an essential legal option out of reach. This forces many vulnerable individuals to be unable to file a stay of removal, resulting in irreparable harm without consideration of their circumstances. Additionally, while fee waivers do exist, there is no clear historical records for the rates of success and attainability to ensure that this important legal option will be accessible. 2. It is an Unjustified Increase While ICE notes that the fee has not been adjusted since 1989, a jump of nearly 400% is extreme and disproportionate to cumulative inflation over the last 37 years. It is particularly unreasonable to impose such an exponential spike without demonstrating a corresponding agency need or an improvement in the processing times or adjudication efficiency of these urgent applications. For these reasons, I urge DHS to reconsider and withdraw this proposed rule and maintain the current $155 fee.