Comment Submitted by National Immigration Project

Summary: The National Immigration Project, a national nonprofit membership organization, opposes the proposed fee increase for Form I-246, arguing that the nearly fivefold hike is unnecessary, arbitrary, and serves as a deterrent to noncitizens seeking stays of removal. They contend that the analysis in the Notice of Proposed Rulemaking is flawed, fails to account for recent Board of Immigration Appeals precedents, and ignores the fact that ICE is already heavily funded by congressional appropriations.