Dear Ms. Cribbs

I, David Bier, Associate Director of Immigration Studies at the Cato Institute, submit the following comments in connection with the above-referenced Department of Homeland Security (“DHS”) and U.S. Citizenship and Immigration Services (USCIS) Notice of Proposed Rulemaking (NPRM) seeking to amend the USCIS Fee Schedule and make certain other changes to immigration benefit requirements, as published in the Federal Register on January 4, 2023.

The Cato Institute is a nonpartisan public policy research organization. For more than four decades, Cato Institute scholars have published original research on immigration policy and proposed policy changes based on its findings that immigrants significantly benefit the United States. USCIS should carry out its statutory duties in a way that focuses on clearing away obstacles to legal status and residence in the United States.

Unfortunately, the NPRM focuses on increasing financial revenue for the agency, not streamlining inefficient agency processes that are requiring increased resources. The NPRM proposes massive increases in immigration fees with zero guarantees of better service for applicants. The NPRM will substantially burden legal immigration, incentivize illegal immigration, and harm the United States by keeping productive people from accessing the immigration benefits to which the law entitles them. USCIS should completely rethink this misguided rule.