Comment Submitted by Immigrant Legal Resource Center (ILRC)

Summary: The Immigrant Legal Resource Center (ILRC), a national non-profit organization, opposes the proposed fee increase for Form I-246, Application for a Stay of Deportation or Removal. They argue the 387% increase is arbitrary and capricious under the Administrative Procedure Act, as it lacks a reasoned justification, fails to account for the significant reliance interests of low-income immigrants, and creates a prohibitive financial barrier to life-saving legal relief.