Comment on FR Doc # 2026-11692

July 13, 2026 Executive Office for Immigration Review Department of Justice Submitted through https://222.regulations.gov Re: Executive Office for Immigration Review Proposed Rule regarding EOIR Fees RIN 1125-AB41 EOIR Docket No. EOIR-26-AB41 The Berkeley Society of Friends (Quakers), through the Racial Justice Action Team of its Social and Environmental Action Committee, writes to express our strong opposition to the changes the Executive Office for Immigration Review (EOIR) proposes to fees assessed by EOIR as set forth in the Federal Register notice published June 11, 2026. The proposal should be withdrawn because it would require the payment of excessive fees that would penalize persons seeking immigration benefits. While H.R. 1 appeared to authorize these fee increases, they constitute penalties that will deprive otherwise deserving persons from meeting their obligations in order to obtain those benefits. The Berkeley Society of Friends (Quakers, “Berkeley Friends Meeting”), through its Immigrant Accompaniment Team has been engaged in the support and accompaniment of immigrants to the San Francisco Bay Area since 2018. We work with other religious groups to help immigrants meet their own goals, comply with the complex legal requirements they face, and learn to live in a society and economy that is often very different from the one from which they come. The Updated Fee Amounts are Unfair and Punitive Imposing these additional fees on top of fees that already meet the cost of providing the services for which they already pay is excessive and unnecessary. Motions to reopen and reconsider should not be subject to these excessive penalties. This is definitely a new fee obligation, in contrast to the statement in the notice that it is not a new fee. The Imposition of an Annual Asylum Fee is Unfair and Unnecessary The imposition of an annual asylum fee for each year that an asylum application is pending is also punitive and unfair. The length of time required to process asylum applications is the result of the manner in which the government handles these applications. It is not caused by action or inaction by an applicant. The rejection of an asylum application for failure to pay these fees is also extremely unfair. Asylum applicants can fail to receive notice of the fee assessment for many reasons. Adding both the initial additional application fee and the annual fee is patently unfair and prejudicial to the efforts of asylum applicants to comply with the required procedures for their asylum cases to be considered and adjudicated. Requiring Separate Fees for Multiple Applications Filed Together is Punitive and Prejudicial Finally, requiring a separate fee for each application when an applicant is filing multiple applications is also unfair and prejudicial to the applicant’s ability to obtain a fair hearing. Conclusion EOIR has not demonstrated that the additional fees are fair, reasonable, and proportional to the costs of adjudicating the cases of the persons filing these applications.. The Berkeley Society of Friends therefore strongly urges EOIR to withdraw the proposed rule imposing these additional fees and to ask Congress to repeal the portions of HR 1 imposing these exorbitant, punitive fees. These proposed fees would undermine the ability of immigrants and their families to access vital services and benefits for which they are eligible. Thank you for the opportunity to comment on this important matter. Sincerely, Accompaniment Team, Social and Environmental Action Committee, and Racial Justice Action Team Berkeley Society of Friends