Comment Submitted by Roots Reborn

Roots Reborn strongly opposes increasing the fee for individuals ordered in absentia. The changes proposed in this NPRM claim to “protect the integrity of immigration enforcement and help promote public safety.” Public safety is defined as the fundamental responsibility of the government to ensure the well-being, security, and protection of all people within its jurisdiction. Under the current administration, the institutional trust and integrity of immigration enforcement have been largely eroded. Increasing the fee for certain immigrants will not promote public safety but rather unnecessarily exacerbate the harms created by the current immigration policies. Last year, DHS received $170 billion dollars from Congress to fund immigration enforcement. Congress is now considering providing even more funding. Despite the significant spike in funds going to ICE and CBP, this proposal asks immigrants for additional money. Our organization strongly disagrees with this proposal. These funds are not and will not be allocated in ways that align with true public safety and the rights listed in the United States Constitution. Additionally, the significant fee increase will place an even heavier debt on individuals who are already struggling financially due to no fault of their own. The proposal states that “Aliens who evade final removal orders undermine the orderly administration of the immigration system and rule of law . . . which then heightens risks to DHS personnel and the public.” Immigrants are being asked to follow an immigration system and rule of law that is ever-changing, incongruent, and not being followed by its own rule makers. There are numerous claims and conclusory statements within this proposal that fail to acknowledge how the current immigration enforcement does not adhere to its own policies and regulations. We further disagree with DHS’s determination that this proposed action would not affect family well-being within the meaning of section 654 of the Treasury and General Government Appropriations Act. Section 654 requires executive agencies to prepare a Family Policymaking Assessment before implementing any regulations, rules, or policies that have the potential to impact the autonomy, integrity, and well-being of a family. Increasing the fee for an individual’s removal will ultimately decrease any income people earn to support their family and children. As stated in the proposal, “Executive Order 13045: Protection of Children From Environmental Health Risks and Safety Risks. E.O. 13045, Protection of Children from Environmental Health Risks and Safety Risks, requires agencies to consider the impacts of environmental health risks or safety risks that may disproportionately affect children.” DHS stated that they reviewed the proposed rule and determined there is no economic or environmental risk to health and safety that could disproportionately affect children without any further explanation. Exclusionary policies correlate to decreased overall health and poor birth outcomes, which directly create economic and environmental risks to the health and safety of children. To ensure that the U.S. immigration system remains transparent, just, and fair, we recommend that all of the current resources, time, and energy be redirected to restructure strategies by DHS and how immigrants are being treated. Additionally, policies, rules, and regulations that aim to support immigrants are more likely to decrease levels of poverty and improve socioeconomic status. Providing individuals with greater access to translators, guidance surrounding the court process, and establishing consistency across the immigration system will help individuals better understand what is being asked of them. We strongly oppose this new rule because the burden this would place on individuals would create additional barriers and worsen the inequities and hardships of our immigrant community.