Comment Submitted by Daniel Bair

I am writing to submit 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. Severe Financial Difficulty and Burden 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, additionally resulting in the harm that THIS FORM is intended to prevent. 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. Unjustified Increase Relative to Inflation 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. The fee of $155 in 1989 dollars is the same as about $416 in today's dollars, not $755. Even this number is sufficient to cause severe financial burden to any low-income individual or family. 3. Cost of Living Increases in the Past 14 Months $755 represents the lowest available monthly health insurance for a family of 4, a cost which many small companies who have previously paid for their staff are now pushing directly onto their employees. It represents two weeks of groceries for that same family. It also represents my biweekly take-home pay, and I am not considered low-income. 14 months ago, it would have covered my mortgage payment, but even without a variable-rate loan, that is no longer the case due to soaring property values. A $755 fee would financially ruin me, not even counting other filing fees and legal costs, which makes me glad to be a citizen and not an immigrant. For these reasons, I urge DHS to reconsider and withdraw this proposed rule and maintain the current $155 fee, or to choose a more reasonable and financially bearable amount, such as $410.