Comment Submitted by Pangea Legal Services

Summary: Pangea Legal Services, a non-profit immigration defense organization, opposes the proposed fee increase for Form I-246, arguing that the 387% hike will create insurmountable financial barriers for vulnerable families facing medical emergencies and humanitarian hardships. They contend that the rule lacks a rational connection to the facts, fails to provide evidence that fee waivers are a viable safeguard, and threatens due process by pricing individuals out of critical legal remedies.