Comment Submitted by Morrie P. Nourian

The Rule proposes a fee on the replacement of I-551 cards, without an expiration date unfairly, and without considering the fact it is not the alien's choice. the aliens were issued these cards for which a fee was paid, and if USCIS intends to replace them, it should do so without a filing fees. Additionally,I-90 fees was revised at least seven times since 1989, and no finger printing fees was required to replace an I-551 card until 2003, and the rule comes now after new fee increase is in effect after July30, 2007 which also is unfair, since the USCIS had notice of the cards without expiration dates prior to 1989 and could have issued the rule to replace I-551 without expiration dates since 1989, and therefore if a fee is required to be collected should not be more than what the legacy INS would have charged in 1989 without a biometric fees.