I am making a post of this comment by Muzzled No More.
Could I suggest that Brockers make comments at the following link.
Comments on the fee-hikes for consular services are being accepted until Oct. 21.
I am unable to do so (still Muzzled in some regards) but if I could, my comment would be as follows:
“It is every American’s constitutional right to renounce his citizenship. As a right, renunciation of citizenship should be free of charge or, at worst, available at an extremely nominal fee, certainly no higher than the “user-pay” fee one would be charged for a passport. A $450 fee was bad enough. For many citizens, the new fee of $2350.00 has priced renunciation beyond their ability to pay. The $2350.00 fee effectively denies them their constitutional right to renounce.
“Renunciation of citizenship is a right guaranteed to all, not a privilege reserved for a few. As such, the US government *must* provide the necessary service at no or low cost. If a renunciation application actually costs the State Department $2350.00 then it is its responsibility to simplify its procedure thereby reducing those costs.
“Perhaps a lesson can be taken from the German government’s renunciation procedure. The application form is available online. The applicant fills out the form and mails it in with certified copies of a couple of documents. No fee. No in-person interviews. No fancy ceremonies. The renunciation is considered in effect when a certificate is received by the applicant. Simple. Efficient. Cost-effective. There is no need for the complexity with which the US State Department’s process is currently burdened.”
If anybody wants to submit that comment under their own moniker I’d be delighted!
At the site you mention one can submit a comment with complete anonymity. There is no requirement to give any name. I mention this in case anyone else has been put off from commenting by thinking it is necessary to give real identification. Take you chance.
I am inclined to feel trusting. I do not think they will be recording IP addresses and hunting down people whose comments they don’t like.
It surprises me that they are only showing 34 comments received.
Our DC attorney called the Department of State and was told that the deadline is “extended” until October 26. This is not stated on the website and perhaps refers only to emailed comments.
For those interested, I would send the comments to:
“E-Mail: firstname.lastname@example.org. You must include the RIN (1400-AD47) in the subject line of your message.”
“All comments should include the commenter’s name, the organization the commenter represents, if applicable, and the commenter’s address. If the Department is unable to read your comment for any reason, and cannot contact you for clarification, the Department may not be able to consider your comment.”
I suspect that DOS will wait until all of the comments are in, and then decide on those comments that are “appropriate” to post.
As of today, the page
shows 66 comments received. When I search for my tracking number, the result still shows “comment received but not yet posted.”
I know that more than 66 comments have been received (I sent in one as did the Alliance’s DC attorney on our behalf). Does anyone know whether ACAGF has been advising DOS on timelines?
Anyway, today I will call:
Celeste Scott, Special Assistant, Office of the Comptroller, Bureau of Consular Affairs, Department of State; phone: 202-485-6681, telefax: 202-485-6826; Email: email@example.com.
for an update on why our “lowest priority” comments have not yet been posted on:
Any thoughts you want me to pass on?
—Today (November 12, 2014) I called Celeste Scott at DOS.
I first asked her to correct by the end of business day today the number of comments that have been received (listed as only 66). She responded by saying that she “has no reason to believe” that that number is incorrect.
I then asked her for an estimate of the date the comments will be posted publicly. She asked me to send an email to her office requesting this information, which I did.
I will follow up on this and provide the response on this site.
Thanks for doing this, Stephen.
Speaking of ACAGF, I don’t yet have a reply to my latest request regarding sending the complete, unedited video on to you of the Toronto May 2014 Tax Forum.
Stephen and interested others,
I have just gotten a response from Anne Hornung- Soukup (who has been on vacation) that she will follow up with Marylouise Serrato on the status of the video we are all waiting for.
I did as Ms. Scott recommended and sent an e-mail to the DOS office. I received two replies:
Thank you for sending a comment to the CA Fee Rule Comments mailbox. Unfortunately, the period for submitting public comments has expired. Although we appreciate your interest, we can no longer accept public remarks on this rule.
Your email has been received at firstname.lastname@example.org. Please note that this inbox is intended for comments on proposed fee rules only. If you have questions about the amount of particular fees, or want to know when fee changes are announced, please consult your local U.S. Embassy or Consulate [I already tried that], or http://www.travel.state.gov where all news will be posted.
–If no response from a live person this week I will phone Ms. Scott again.
Only four unrelated comments on renunciation fee increase posted so far so I called Department of State for explanation (where are the 66 plus comments that were received?).
State blames Regulations.gov (hosts the website) for the lack of posting. Just called friendly Regulations.gov which advised that the problem is clearly with State and will try to contact these recalcitrant people on my behalf.
Will wait a week and try again.
Because State will not post comments it will appear to all that Americans abroad are not displeased with massive renunciation fee increase. Am not giving up just yet on shaming State into posting the comments.
I believe it will be confirmed that is the Department of State — anything we have tried to get from them has been like pulling teeth. Un-bloody-believable if it weren’t so believable!
And, they will try to put that message across — none of the Americans abroad have any worry or displeasure about the massive renunciation fee increase (because, of course, the perception they put forth are *they are all wealthy SOBs*).
Thanks for following up, Stephen.
Thanks for keeping on them, Stephen.
— Just spoke to Department of State person who finally provided to me reason why none of our complaints about renunciation fee increase were posted on the regulations.gov website:
The answer is that NO complaints SENT IN BY EMAIL will be posted.
I suppose the disclaimer below is sufficient to withhold ANY submission DOS does not like from posting (e.g., because of unpleasant PR), but I do not find the provocative word “email” mentioned.
“This count refers to the total comment/submissions received on this document, as of 11:59 PM yesterday. Note: Agencies review all submissions, however some agencies may choose to redact, or withhold, certain submissions (or portions thereof) such as those containing private or proprietary information, inappropriate language, or duplicate/near duplicate examples of a mass-mail campaign. This can result in discrepancies between this count and those displayed when conducting searches on the Public Submission document type. For specific information about an agency’s public submission policy, refer to its website or the Federal Register document.”
I want to scream. Is not posting them the same as not reviewing them?
Surprised? Why would we be surprised — the Department of State has never been forthcoming in its answers!
No complaints sent by email will be posted — isn’t that damn handy?
DOS — I don’t believe your statistics regarding expatriations either! What a whitewash.
DOS says that all submissions will be “reviewed” and “considered” but those emailed will not be posted. I actually suspect that submissions mailed in will also not be posted because these would not provide helpful PR for DOS.
—Do you remember not that long ago when we all made submissions to Canada Finance and after the submissions were told that any submission longer than five (?) pages (surprise!) would be destroyed…….?
ADCS DC lawyer’s law firm just contacted me and found 15 comments including ours. I will post on separate thread.
Just one more nail in the coffin of U.S. Government credibility. It’s hard for me to imagine being disillusioned about them further. I don’t think I have any illusions left after all that has been revealed in recent years.
BTW, I will contribute more to the ADCS/ADSC challenge in early January after I get by some December cash-flow constraints (nothing to do with holiday shopping). I’m looking forward to that succeeding in 2015 and to the Harper government being defeated.
Thanks, Stephen — looking forward to your new post.