Comment Submitted by Jeff Wendland, Asian Counseling and Referral Service

Asian Counseling and Referral Service is recognized by the Board of Immigration Appeals and serves over 800 individuals per year through our Citizenship and Immigration services. Ninety-Five percent of those receiving services are below 200% of the federal poverty level, yet many are not on a means-tested public benefit and therefore do not typically qualify for a USCIS application fee waiver. For these clients, especially, the current fees applied to immigration services are prohibitive and do not support the empowerment and integration of immigrants. It is our sincerest belief that higher fees for these services will have a negative impact on immigrants’ ability to participate in our community. We disagree with all fee increases and will continue to advocate for decreases to fees for USCIS immigration services. We believe that this should be a public service and that the weight of the program cannot rest on the shoulders of low-income refugees and immigrants.