Comptroller Stringer Sends Letter to DHS Opposing Proposed Changes to Citizenship Application Fees

(New York, NY) — Today, New York City Comptroller Scott M. Stringer sent a letter to Citizenship and Immigration Services at the U.S. Department of Homeland Security (DHS) urging the federal agency to not move forward with a proposed 61 percent increase in the citizenship application fee totalling $1,170. Comptroller Stringer’s letter noted that the exorbitant rise in the fee would present an undue financial burden on the costs of naturalization, particularly on those families who live on or below the Federal Poverty Guidelines (FPG). DHS is also proposing to eliminate fee waivers for applicants with a household income of less than 125 percent of the FPG, which would remove more than $360.1 million annually from immigrant communities in need of this subsidy. Comptroller Stringer urged DHS to reconsider these proposed changes as both would preclude thousands of immigrants from applying for citizenship, and thereby creating a barrier of entry to a sense of belonging, economic opportunity and achieving the American Dream.

Comptroller Stringer has been outspoken about protecting the rights of the city’s immigrant communities, including calling for the creation of a public-private New York City Citizenship Fund to help tens of thousands of legal immigrants cover the costs of the citizenship application, and releasing a report detailing how the soaring cost of naturalization and other barriers have created obstacles to obtaining citizenship for the nearly 670,000 immigrant New Yorkers who are eligible to apply.

The full letter is as follows:

Samantha Deshommes
Chief, Regulatory Coordination Division
Office of Policy and Strategy
U.S. Citizenship and Immigration Services
Department of Homeland Security
20 Massachusetts Avenue NW, Mailstop #2140
Washington, DC 20529

December 30, 2019

Dear Chief Deshommes: 

As the Chief Financial Officer for the largest city in the United Sates, I am writing today to vehemently oppose the Department of Homeland Security’s (DHS’) proposed adjustment to fees charged by U.S. Citizenship and Immigration Services (USCIS). New York City has long depended on the strength of immigrant communities to power our economy and strengthen our neighborhoods: nearly 3.5 million immigrants from more than 150 countries, totaling almost half of our City’s population and workforce, call the five boroughs home. By exacerbating the already steep barriers to becoming a citizen, the rule, as proposed, would have profound detrimental effects on New York City as well as communities across the nation.

In 2017, the Office of the New York City Comptroller (“this office”) documented the far-reaching contributions immigrants make to strengthen New York City’s economy. With more than $100 billion in annual earned income, immigrants earn 32 percent of total earnings in New York City, across virtually every industry.  Immigrants are employed at the same rate as U.S.-born residents and work as many or more hours per week and more weeks per year, compared to U.S.-born New Yorkers. They are entrepreneurs and homeowners, contributing $8 billion in annual New York City and State income taxes and $2 billion in New York City property taxes each year.

Providing an accessible and affordable path to citizenship is essential to maintaining these economic contributions and thriving communities, while keeping our families whole. Yet, the barriers to naturalization are immense. In New York City, the total costs of naturalization can easily exceed $2,000, including education classes, attorney fees, filing assistance, and USCIS application fees.  Given that more than half of the population eligible for naturalization live below 250 percent of the Federal Poverty Guidelines (FPG), these costs represent a significant hardship.  This office estimates that, due in part to its price, roughly 670,000 immigrants in New York City—20 percent of the total immigrant population in the city—are eligible to apply for citizenship but have not yet applied.

I am gravely concerned that the proposed rule in question will make this economic barrier insurmountable for far more immigrants eligible for naturalization. In 1985, the fee for naturalization was $35. If the application fee had risen with the pace of inflation, it would only be $85 today. However, as a result of allowing the USCIS to increasingly self-finance with ever larger fees, DHS’ proposed rule would increase the application fee by a whopping 61 percent to $1,170, nearly one week’s pay for the median household in New York City.

Making matters worse, the proposed rule would eliminate reduced fees for applications for naturalization and limit access to remaining fee waivers to applicants with household income of less than 125 percent of the FPG, which DHS estimates would cost applicants some $360.1 million annually, a substantial transfer of wealth out of immigrant communities. In addition, the rule institutes altogether new fees, including $275 for Deferred Action on Childhood Arrivals (DACA) renewal requests and, perhaps most cruelly, a new $50 fee on asylum seekers, or refugees who face persecution in their country of nationality, at an estimated cost to asylum seekers of $5.6 million. The Department itself notes that this would result in some applicants “no longer be[ing] able to apply for asylum.”  Meanwhile, USCIS has attempted to make the already cumbersome and challenging process of applying for a fee waiver even more difficult.

Given DHS’ multiple fee schedule increases over the past two decades, researchers at the University of Southern California have also concluded that “evidence suggests that the decision by an immigrant to naturalize is price sensitive.”  For reference, the number of citizenship applications surged to 1,383,275 in FY 2007, an increase of 89 percent from FY 2006 (730,642 applications), after it was announced that the form-filing fee would be increased from $400 to $675 at the end of July 2007.  Once this increase took effect, however, the number of applications fell precipitously. With the increase in effect, in FY 2008, only 525,786 applications were filed, a decrease of 62 percent from FY 2007 and 28 percent from FY 2006.

With this in mind, DHS stands to see an even more precipitous decline in applications should this proposed rule be finalized, precluding eligible applicants from fully participating in New York City’s economy and ultimately America’s democracy. Naturalization opens the door to increased wages in jobs reserved only for U.S. citizens, gives the opportunity to petition for family members to immigrate to the United States, eases fears of deportation or family separation, and paves the pathway to the ballot box.

Above all, this proposed rule will deprive many New Yorkers of the intangible benefits of citizenship—a stronger feeling of “belonging,” greater security, and a powerful sense of patriotism. Throughout history, with the towering Statue of Liberty holding her torch of freedom high, New York City has borne that moral responsibility to non-citizens:

“Give me your tired, your poor,
Your huddled masses yearning to breathe free,
The wretched refuse of your teeming shore.
Send these, the homeless, tempest-tost to me,
I lift my lamp beside the golden door!”

For the refugees arriving through Ellis Island, and the Dreamers still yearning for opportunity in the city that never sleeps, the words inscribed on Lady Liberty have defined the tradition of America: our diversity is what makes this nation great. It is a profound disservice when our government fails to live up to this promise. Accordingly, I implore you to publish a final rule that does not needlessly impose further economic hardships on those who long to be an American citizen.

Sincerely,

Scott M. Stringer
New York City Comptroller

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