Comment on FR Doc # E7-11810

This comment is in reference to the proposed fee increases for the Exchange Visitor Program. I have no objection to the increase in fees for filing an application for exchange visitor status changes. These fees, in particular, are for services which are extraordinary for the Exchange Visitor Program, services which require additional time and resources from the Department of State for administration of the program. Most of these fees would be paid by the Exchange Visitor himself or herself for special services. I would even support somewhat higher fees for services to further dissuade Exchange Visitors and sponsors from casually relying upon these changes to correct or change a status. The fee to which I object is the excessive amount for redesignation. The redesignation process itself should be fairly straightforward for the Department of State. A form is submitted by the sponsor, attesting to the fact that the sponsor has performed appropriately and nothing significant has changed in regard to the structure of the institution. If this is true, as the sponsor has attested, under threat of imprisonment for falsification, the Department of State simply approves the redesignation. In this regard, a fee equal to the original designation fee is excessive. Many small exchange programs or programs within institutions which are struggling financially will simply not seek redesignation for their J program, if the increased fee proposed is instituted. This ultimately will curtail the educational and cultural exchange which the J program itself envisions. Exchange Visitors should be able to conduct exchange activities with small institutions and programs, as well as large. These programs are equally important to the vitality and effectiveness of the J Exchange Program, in some cases, even more so when the exchange visitor gets more personalized services and greater attention. Our institution charges no fees for the processing of DS-2019 forms, for the follow up support for exchange visitors, or for the specialized services we provide to exchange visitors sponsored by other agencies, such as IIE, LASPAU, Ford Foundation, IREX, and American Councils. If our small department were required to pay the redesignation fee proposed, we may find ourselves in need of charging a fee to inviting departments and sponsors to offset these costs. This would most certainly dissuade some departments from inviting unpaid exchange visitors who are financially sponsored by their own governments or institutions, by fellowships and scholarships, or by their own salaries during their sabbaticals. This would, in turn, reduce the level of educational and cultural exchange occurring on our campus and reduce the J program largely to an employment-type status for temporary post-doctoral researchers. I do not object to an increased designation fee for an initial application for a J program or for the addition of categories to an existing J program. I believe that the Department of State invests substantial time and resources in reviewing these actions. This is especially true of trainee, summer work/travel, and au pair programs. Perhaps an even greater fee is justified for these private sector programs which require greater levels of scrutiny from the Department of State and which routinely collect fees for their services from both the exchange visitor and the employer. In summary, it is my recommendation that the ?exchange visitor status change fees? be further increased, the initial designation (not redesignation) fee be increased as proposed, the private sector redesignation fee be increased at an amount higher than proposed, and the academic and government sectors redesignation fee be removed entirely from the proposal. In this way, I believe that academic programs will be able to retain the valuable unpaid educational and cultural exchanges happening on our campuses and smaller J programs will be able to continue to support their own important exchange activities. Increasing understanding among the U.S. and other countries, especially in an academic and community setting, is more important now than ever before. We should be building bridges to greater exchange, not barriers to the exchange which currently exists.