Fair and equal treatment for Tinian and Rota

To Janna Evans of U.S. Citizenship and Immigration Services: First, thank you for your help with correcting the Federal Register website. It is reassuring that requests for change in the federal bureaucracy can actually be accomplished for the betterment of the CNMI. I hope this is a step in the right direction as we identify more inequalities in federal bureaucracy and we can work together to make those changes necessary to correct them.

One of the most important and eminent policy changes that are necessary for the residents of Tinian and Rota is for an equal and fair USCIS office to be established on Rota and Tinian. This is a major concern for residents and businesses of both Tinian and Rota islands.

Although I understand the policy position of resident numbers required to justify the opening of a USCIS office, I had earlier pointed out that a middle ground solution could be the opening of a temporary USCIS office on the outer islands. The USCIS/DHS Office would be set up for the first six months, just to service the initial heavy demand those islands would have. Once that demand has diminished, then USCIS could close the office and then service the outer islands on a weekly and/or bi-weekly “circuit ride” basis. It is imperative that DHS and USCIS understand and recognize the profound financial hardship that it will place on residents of Tinian and Rota. A single person traveling to Saipan from Tinian for a one-day trip would incur a cost of $310. A single person traveling to Saipan from Rota for a one-day trip would incur a cost of $440. This does not include repeated visits necessary to process USCIS paperwork, and it does not include costs for businesses to process paperwork for their staff, which would multiply these figures by the amount of employees the company has. For instance, the Tinian Dynasty has 600 employees, the Rota Resort has 80 employees. How could a company possibly survive if they were expected to send all their personnel to Saipan in order to process immigration paperwork over the course of several visits?

It is important to recognize some very crucial issues.

1. PL 110-229 established two ports of entry on the islands of Tinian and Rota. Those ports of entry deserve equal service and security measures given by USCIS/DHS that it grants to any other port of entry in the U.S., much less Guam and Saipan. If USCIS/DHS is saying that the population or the security concerns are not relevant enough to open an office on Tinian or Rota, then why did the public law identify two ports of entry on each of those islands? Are the residents of those islands less deserving of service and security protection than those on Guam and Saipan?

2. PL 110-229 also allows DHS to collect revenue for the expenses of operations in the CNMI from the fees it collects from administering the immigration program in the CNMI. This is very different from Guam and the US Virgin Islands, where those funds are required to be returned to those island governments, which incurs a deficit in the DHS operating budget. So, in all actuality, funding cannot and should not be a concern for DHS or USCIS because your agencies actually collect, and keep the funds earned in the CNMI for the processing of all immigration visas. There is no net loss to the DHS budget, because PL 110-229 actually allows you to keep the funds and not return those funds to the CNMI. As a result, the fees you would collect on Tinian and Rota would more than fund the operations of an office for only six months on each island.

3. Development of “circuit rides” to the outer islands will not provide enough processing time for the outer islands, with only three months until implementation, which is roughly 12 weeks. How would it be mathematically possible to service the needs of the outer islands based on the processing time DHS/USCIS requires for various immigration processing and paperwork? How many “appointments” will USCIS be able to offer to the residents of Tinian or Rota when they set up a circuit ride? Ten? Twenty? Per day? Based on the population of employees that the Tinian Dynasty has alone, you are looking at 30 days just to go through the appointments, much less administer the applications submitted and this does not address the over 1,000-2,000 other workers and immigration requests that will require appointments as well. The amount of time necessary and the short time of attention offered to the outer islands does not make it reasonably possible to provide the service required to those residents. At the very least, DHS/USCIS is setting themselves up for failure and a huge backlog of immigration processing that would be predominantly from the outer islands. Which means we would be treated as second class citizens and an after thought of ….”we’ll get to it as soon as we have finished processing Saipan and Guam.”

I implore you and your agency to do the right thing. Provide adequate, fair, and reasonable services by opening a temporary office for the residents of Tinian and Rota who as U.S. citizens and tax payers. We deserve nothing less.