Comment Submitted by Ariel Thelander
AnonymousOpposeIndividual
Summary: An individual opposes the proposed fee increase for Form I-246, arguing that the agency does not rely on this specific fee for operations and should instead manage its own budget. The commenter contends that high fees create a barrier to discretionary relief and that the financial burden of enforcement costs should not be shifted to applicants.
To Whom It May Concern:
I oppose DHS’s proposed rule to raise the Form I-246 fee from $155 to $755, and I encourage the agency to consider waiving the fee entirely.
The existing fee has remained unchanged since 1989, despite inflation exceeding 150%. This proves the agency does not rely on the income from this fee for any of its functional operations, else they would have long run on a massive deficit. Consider using the funds DHS had proposed to use for signing bonuses for new employees to cover any difference in the balance sheet that may appear from keeping the fee flat.
A stay of deportation or removal is a form of discretionary relief from an otherwise valid removal order. Adding a fee makes it no longer discretionary for all, and instead available only to those with funding. Deportation is not avoidable through compliance with immigration law, as we have seen in several recent high profile cases of citizens and legal permanent residents being deported with no criminal history.
Lawfully immigrating persons should not bear the financial burden of costs resulting from poor management by DHS of its immigration enforcement budget & programs. In light of the elevated risk to applicants of illegal deportation, rejected applications, and illegal detention, DHS should aim to contain its enforcement costs rather than shifting them to applicants without the means to pay.