Naturalization Application Fee Adjustments

The League of Women Voters of Houston respectfully opposes the proposed rule raising fees for Form N-400 and Form N-336 and eliminating fee waivers and the reduced fee option for both forms. We are a nonpartisan, nonprofit civic organization working in Harris County, Texas. We do not support or oppose any political party or candidate. Our members register voters and provide voter education across the Houston region, and we conduct voter registration for newly naturalized citizens on a recurring monthly basis. We are writing because that work puts us in the room at the exact moment this rule is about, when someone becomes a citizen and, minutes later, becomes a voter. This is not a new concern for the League. In March 2023, the League of Women Voters of the United States submitted a comment to USCIS opposing proposed increases to immigration and naturalization fees, including a 19 percent increase to the Form N-400 fee. The League's national office urged the agency to withdraw that rule, warning that higher fees would price eligible people out of programs they qualify for, and stating plainly that a voting rights organization must oppose financial barriers standing between community members and full participation in our democracy. The present proposal is substantially more restrictive. It raises the same fee by approximately 75 percent rather than 19 percent. And where the 2023 rule preserved fee waivers, this one eliminates them, along with the reduced fee option. The concerns the League raised then apply with considerably greater force now. Our volunteers meet new citizens immediately after the oath ceremony. In our experience, many people register to vote that same hour, in the same building, still holding their certificate. They do not treat the vote as a distant or secondary benefit of citizenship. For a great many of them, it is the reason they applied. We mention this because the proposed rule reasons that the privileges naturalization adds, voting in federal elections, serving on a jury, are less critical to applicants than other immigration benefits, and describes the resulting civic participation as uncertain and diffuse. We would ask the agency to weigh what we observe against that assumption. The people we register are not uncertain about why they came. Naturalization is the only way an adult lawful permanent resident can ever cast a ballot in this country, and a fee that puts naturalization out of reach puts the ballot out of reach with it, not temporarily, but for as long as the applicant cannot pay. Raising the paper filing fee for Form N-400 from $760 to $1,330 is a large increase for households that are often supporting several applicants at once. Families we encounter frequently save for years to file, and they save for more than one person, a spouse, a parent, an adult child. The proposed fee applies per person, but a family's budget does not. Eliminating the fee waiver concerns us most. Today, an applicant who receives a means-tested benefit, or whose income is near the poverty line, or who is facing genuine hardship, can still apply. Under this rule, that person would have no option at all. Not a longer timeline, not a smaller payment, not a hardship review, no path. This would be true even for someone who has already done everything the law asks: years of lawful residence, a clean background check, and passing the English and civics tests. We do not think the last step toward citizenship should be the one that depends on income. We also note that filings under the reduced fee rose more than tenfold after eligibility was expanded in 2024, from roughly 0.3 percent of applications to 3.2 percent. The rule treats that as a small number. We would read it as evidence that a real group of eligible people had been waiting for an affordable way to apply, and found one. Removing it would return them to where they were. Finally, the same increases would apply to Form N-336, which is how an applicant asks t…