Office of the Mayor | 600 Fourth Avenue, P.O. Box 94749, Seattle, WA 98124 | 206-684-4000 | seattle.gov/mayor

May 22, 2019

Dear Director Cissna:

I am writing to express the City of Seattle’s deep concern about the possibility that United States

and the application for reduced fee (Form I-942) for the application for naturalization (USCIS Form N-

400) as part of the agency’s biannual fee review process through federal regulation.

The City of Seattle, through its Office of Immigrant and Refugee Affairs, funds and coordinates two

naturalization programs: the New Citizen Campaign (NCC) and the New Citizen Program (NCP). Together,

these help an estimated 75,000 Seattle-area legal permanent residents (LPRs) become U.S. citizens.

Since its inception in 1997, NCP has served over 19,000 people, provided naturalization assistance to

over 12,300 LPRs, successfully naturalized 9,500 LPRs, and provided over 90,000 hours of citizenship

instruction. NCC works with community partners to co-host citizenship clinics and workshops all over

Seattle that have to-date helped 1,701 legal permanent residents start on the path to citizenship.

reduced fee options would ostensibly block half of the estimated 8.8 million eligible LPRs from seeking

U.S. citizenship. It would also devastate the City’s citizenship services infrastructure and eliminate the

possibility of attaining U.S. citizenship for tens of thousands of local LPRs.

To enroll in NCP, participants must be low-income. In fact, 96 percent of the 573 NCP participants who

submitted an application in 2018 submitted a I-912 with their N-400 application. About 30 percent of

NCC participants, or 129 individuals who participated in 2018 clinics, submitted a I-912 or I-942 with

their applications.

Income is not and should never be a requirement of U.S. citizenship. For a single person living at 150

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Also, the local USCIS office has changed its longstanding practice of adjudicating employment-based

adjustment applications without an interview. This additional scrutiny, without clear justification, diverts

agency resources away from adjudicating N-400s.

I recognize that this is not the agency’s first effort to marginalize immigrants with low incomes or

undermine the fee waiver. The City of Seattle submitted public comments against USCIS’s proposed

changes to the public charge determination in December 2018. In November 2018, and again in May

2019, we responded to the government’s proposed changes to the Form I-912 and its elimination of

means-tested benefits as a basis for fee waiver eligibility.

simultaneously and significantly reduce the naturalization filing fee to prevent the unauthorized

implementation of an income requirement for naturalization.

Second, without demonstrating a clear tie between fee revenue and unimpeded application processing,

USCIS will be unable to justify any fee increases. The City of Seattle will not sit idly by if you choose to

increase fees without clearly and specifically demonstrating the use of past fee revenue, along with

significant action to reduce these delays and backlogs.

The City of Seattle demands USCIS accountability to our constituents and will make every effort to

ensure this accountability. We demand that USCIS maintain the fee waiver option for naturalization. And

Jenny A. Durkan

Mayor of Seattle

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1356 (m)-(n), which states that “fees for providing adjudication and naturalization services may be set at a level

that will ensure recovery of the full costs of providing all such services, including the costs of similar services

provided without charge to asylum applicants or other immigrants. All deposits into the ‘Immigration Examinations

Fee Account’ shall remain available until expended to the Attorney General to reimburse any appropriation the

amount paid out of such appropriation for expenses in providing immigration adjudication and naturalization

‘Immigration Examinations Fee Account’.”