April 2, 2007

Director, Regulatory Management Division

US Citizenship and Immigration Services

Department of Homeland Security

111 Massachusetts Ave. NW, 3^rd^ Floor

Washington, D.C. 20529

**RE: DHS Docket \# USCIS-2006-0044**

**Proposed Rule -- Adjustment of the Immigration and Naturalization
Benefit Application and Petition Fee Schedule**

On behalf of the Korean American Resource & Cultural Center (KRCC), I am
writing to strongly oppose the increase to immigration and
naturalization fees that US Citizenship and Immigration Services (USCIS)
proposed on February 1, 2007.

Founded in 1995 by a group of low-income, immigrant Korean American
youth, KRCC's mission is to empower the Korean American community
through education, social service, organizing/advocacy, and culture.
KRCC serves the Korean American community of greater Chicago, now
estimated at 100,000. KRCC is also an affiliate of the National Korean
American Service & Education Consortium, which was established in 1994
and seeks to project a national Korean American voice on immigrant
rights and civil rights issues.

The Korean community in the United States is largely immigrant;
according to the 2000 Census, approximately 78% of Korean Americans were
born outside of the US. Department of Homeland Security estimates
indicate that there are over 200,000 Korean American legal permanent
residents eligible to naturalize. We currently provide naturalization
application assistance to 150 prospective US citizens per year. These
community members have worked hard to establish lives for themselves in
the U.S., and yet Korean Americans are still nearly twice as likely as
non-Hispanic whites to live in poverty and Korean Americans' per capita
income is thousands of dollars less than the national average. The steep
fee increases proposed by USCIS -- which in some cases are double the
current fee -- would put the goals of gaining permanent resident status,
reuniting with family members, and ultimately becoming a US citizen
further out of reach. USCIS should be building bridges for immigrants to
move toward citizenship, not putting up walls.

The proposed fee for naturalization is particularly jarring. As recently
as 1998, the cost to apply for citizenship was \$95. The current fees
are typically \$400, a fourfold increase in the past eight years. Now
USCIS is proposing a further increase of 70%, to \$675. An individual
working at a minimum-wage job would need to work for more than three
weeks and save all of her or his earnings in order to pay this fee.

Even more startling is the proposed cost of filing for adjustment of
status, which for many immigrants is the first step on the road to US
citizenship. That application has risen from \$130 in 1998 to a total of
\$400 today. Under the proposed rule, the total price will rise to
\$985. In other words, it will cost nearly \$1,000 for an immigrant to
apply for a green card and start the five-year countdown to citizenship.
A minimum-wage worker would need to save a full month's pay to afford
the proposed fee.

USCIS claims that the fee increase is necessary to improve service. We
are not disputing the fact that USCIS service requires improvement;
there exist continuing backlogs in application processing and
months-long (even years-long) delays. 77,000 Koreans -- and 1.5 million
Asians -- are caught in the family immigration backlogs, and Korean
American citizens must wait at least 3.5 years for their children and up
to 12 years for their siblings to join them in the US. Furthermore, in
October 2006 the Government Accountability Office reported that USCIS
had lost track of 110,000 files needed to process citizenship cases.
However, we question whether service improvements could be better
accomplished by improving the efficiency of the current application
processing procedures rather than increasing the application fees.

Moreover, we support the provision of the Citizenship Promotion Act of
2007 (H.R. 1379 and S. 795 respectively) which calls for a moratorium on
fee increases until the Department of Homeland Security can submit a
report justifying the need for such increases. This legislation mandates
that this report be based upon a comprehensive review of the direct and
indirect costs of immigration services and that these costs are to be
distinct from expenditures related to national security and border
enforcement.

USCIS also argues that it has no other option than raising fees if it
wants to cover its costs. However, there are no laws that require USCIS
to fund the entirety of its operations through application fees. Nothing
prevents USCIS from pursuing other sources of revenue, including asking
Congress for appropriations. In fact, USCIS has sought and received
Congressional funding several times in the past.

Most basically, immigration and citizenship are public goods that
benefit our entire country. Immigrants bring their talent and hard work
to our economy. They pay taxes, revitalize our communities, and
contribute to the cultural vibrancy of our nation. In becoming US
citizens, immigrants demonstrate their strong commitment to their new
home country by learning English, gaining knowledge about American
history and government, and swearing allegiance to the United States.
Given the net benefit that immigration provides to this country, USCIS
must move towards encouraging immigrants to become part of our community
by gaining legal status and becoming citizens, rather than set up
barriers that block their path to citizenship and exclude them from
becoming more active participants in US society.

The plan to increase immigration fees is misguided. I urge USCIS to
first justify the fee increase by conducting a thorough assessment of
its current policies and procedures -- with particular regard to the
efficiency of its application processing and background checks -- and
seek other sources of funding before proceeding with the proposed fee
increase. Thank you for your consideration.

Sincerely,

Becky Belcore

Executive Director