Democracy Strangled

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Democracy Strangled Second Wall of Barriers to Citizenship Risks Preventing Hundreds of Thousands of Immigrants from Naturalizing and Becoming Voters in Presidential Election of 2020

Issue Brief February 2019

Contents

I. Trump Administration Constructs Second Wall of Barriers to Citizenship ...... 1

A. Growing Backlog of Citizenship Applications and Processing Times Prevent Over 750,000 Immigrants from Naturalizing and Prevents Their Civic Engagement, Including Voting ...... 1 B. Proposed Fee Waiver Regulation Will Cut off Access to Citizenship Based on Wealth and Class ...... 2 C. Proposed Changes to Citizenship Application Will Make Naturalization Unnecessarily More Burdensome for Applicants, Legal Services Providers, and USCIS Adjudicators ...... 3 D. New Policy Guidance Makes it More Difficult for Applicants with Disabilities to Apply for Citizenship ...... 4 E. USCIS Escalates Practice of Denaturalizing Citizens ...... 4 F. Recent USCIS Policies and Practices are a Part of Larger Administrative Trend to Limit Access to Citizenship ...... 5

II. National Partnership for New Americans, Our Member Organizations, and Partners Committed to Tearing Down the Second Wall and Encouraging One Million Citizens by 2020 ...... 6

Appendix ...... 8

Access to citizenship has been a central challenge of this nation’s democracy since its birth. Slavery and the exclusion of African Americans were at the center of the Civil War and led to the 14th and 15th Amendments to the United States Constitution. Exclusion of women was at the center of the Women’s Suffrage movement and led to the 19th Amendment of the U.S. Constitution. Naturalization is the process through which the U.S. formally welcomes immigrants after years, in many cases decades, of immigrants being an integral part of the country, working towards their dreams of a better life, and contributing to their families and future. The process of naturalization was envisioned by the founders of this country, created by the Constitution, and codified in federal law and regulations.1 Though there are low points in our history, such as when the federal government utilized naturalization laws to exclude people based on race, ethnicity, and country of origin, access to citizenship has generally represented a core national value of welcoming immigrants and building a democracy with equality for all.2

I. Trump Administration Constructs Second Wall of Barriers to Citizenship

During the past two years the Trump administration has taken numerous steps to systematically strangle access to citizenship and voting for immigrants, especially for elderly, disabled, poor, and working poor immigrants and refugees, disproportionally disenfranchising immigrants from Latin America, Africa and the Middle East. The Trump administration is effectively building a “Second Wall” to prevent eligible lawful permanent residents (LPRs) from becoming U.S. citizens with full voting rights. Skyrocketing backlogs in citizenship applications; increasing processing delays by U.S. Citizenship and Immigration Services (USCIS); a series of insidious proposed regulatory changes affecting elderly, disabled, and poor immigrants and refugees; and a new emphasis on denaturalization all delay and make more difficult the ability of eligible LPRs to naturalize.

A. Growing Backlog of Citizenship Applications and Processing Times Prevent Over 750,000 Immigrants from Naturalizing and Prevents Their Civic Engagement, Including Voting

According to data available from USCIS, as of June 2018 the backlog of citizenship applications pending before the agency is 750,793.3 This backlog has doubled from 367,000 in late 2015 to the current backlog of over 750,000, with the majority of this skyrocketing increase happening under the current administration.4 The National Partnership for New Americans (NPNA) believes that this is a clear case of malevolent incompetence, designed to disenfranchise aspiring U.S. citizens.

1 U.S. Const. Art. I, § 8, cl. 4; 8 U.S.C. §§ 1103, 1421, 1423, 1427, 1443, 1447, 1448; 8 C.F.R. §§ 103, 310, 312, 316, 332, 336, 337. 2 An Act to Establish an Uniform Rule of Naturalization, 1 Stat. 103, 1 Cong. Ch. 3 (1790); Chinese Exclusion Act, ch. 126, 22 Stat. 58 (1882); Immigration Act of 1917, Pub. L. No. 301, 39 Stat. 874 (February 5 1917); “Chapter 1: The Nation’s Immigration Laws, 1920 to Today,” Pew Research Center, p. 14, September 25, 2018, http://assets.pewresearch.org/wp-content/uploads/sites/7/2015/09/2015-09-28_modern-immigration-wave_REPORT.pdf; content/uploads/sites/7/2015/09/2015-09-28_modern-immigration-wave_REPORT.pdf; 28 Act of May 19, 1921, Pub. L. No. 5, 42 Stat. 5; Immigration Act of 1924, Pub. L. No. 139, 43 Stat. 153 (1924); Cobb, Jelani, “Trump’s Move to End DACA and Echoes of the Immigration Act of 1924,” The New Yorker, September 5, 2017, https://www.newyorker.com/news/daily-comment/trumps-move-to-end-daca-and-echoes-of-the-immigration-act-of-1924. 3 “Number of Form N-400, Application for Naturalization, by Category of Naturalization, Case Status, and USCIS Field Office Location, April 1 - June 30, 2018,” U.S. Citizenship and Immigration Services, accessed February 6, 2019, https://www.uscis.gov/sites/default/files/USCIS/Resources/Reports%20and%20Studies/Immigration%20Forms%20Data/N aturalization%20Data/N400_performancedata_fy2018_qtr3.pdf. 4 “Data Set: Form N-400 Application for Naturalization,” U.S. Citizenship and Immigration Services, accessed February 6, 2019, https://www.uscis.gov/tools/reports-studies/immigration-forms-data/data-set-form-n-400-application-naturalization. 1

The delays in USCIS processing citizenship applications has also increased, almost doubling since 2015 and reaching “crisis-level delays in the agency’s processing of applications and petitions for immigration benefits,” according to the American Immigration Lawyers Association.5 The processing times range widely between and within USCIS Field Offices and Service Centers and in some cities reach as high as 31 months.6 According to USCIS estimates as of February 8, 2019, some of the most extreme examples include regions such as:

● Las Vegas, Nevada, where processing times range from 15.5 to 31 months; ● Atlanta, Georgia, where they range from 14.5 to 29 months; ● Minneapolis-St. Paul, Minnesota, where they range from 16 to 25 months; ● New York City, New York, where they range from 12 to 24.5 months; ● Miami, Florida, where they range from 15.5 to 22.5 months; and ● Houston, Texas, where they range from 17 to 21.5 months.7

In all of these cities, some eligible lawful permanent residents who have already submitted their citizenship applications will be subject to processing times that are so long that they already will be prevented from naturalizing and subsequently registering to vote in time to participate in the Presidential election of 2020. This underscores the necessity for advocates, specifically those interested in immigrants’ civic engagement, to expand their work in encouraging eligible LPRs to apply as soon as possible.

B. Proposed Fee Waiver Regulation Will Cut off Access to Citizenship Based on Wealth and Class

In addition to the increasing backlog and processing times for citizenship applications, USCIS has proposed several policy changes that will begin to make citizenship less accessible as early as February 2019. This includes the fee waiver regulation proposed by USCIS and the Department of Homeland Security (DHS) on September 28, 2018.8 For many years, poor and working poor immigrants have been eligible for a waiver from all or part of the $725 naturalization application fee. The purpose of these fee waivers is to prevent U.S. citizenship from being a privilege limited to wealthy immigrants. The proposed regulation, if implemented, will cut off access to citizenship by removing the receipt of a means-tested benefit as a basis for receiving a fee waiver for the citizenship application.

5 “Historical National Average Processing Time for All USCIS Offices,” U.S. Citizenship and Immigration Services, accessed February 6, 2019, https://egov.uscis.gov/processing-times/historic-pt. 6 “AILA Policy Brief: USCIS Processing Delays Have Reached Crisis Levels Under the Trump Administration,” American Immigration Lawyers Association, January 30, 2019, https://www.aila.org/infonet/aila-policy-brief-uscis-processing- delays?utm_source=AILA%20Email&utm_medium=COAL. 7 “Check Case Processing Times,” U.S. Citizenship and Immigration Services, accessed February 6, 2019, https://egov.uscis.gov/processing-times/. 8 Agency Information Collection Activities; Revision of a Currently Approved Collection: Request for Fee Waiver; Exemptions, 83 Fed. Reg. 49,120 (proposed September 28, 2018), https://www.govinfo.gov/content/pkg/FR-2018-09- 28/pdf/2018-21101.pdf. 2

In calendar year 2017, 926,260 immigrants applied for citizenship.9 Almost 40 percent of those applicants, approximately 370,500, filed with a fee waiver request.10 By some estimates, two-thirds of those applicants, over 244,000 in 2017 alone, requested a fee waiver based on their receipt of a means- tested benefit, rather than based on their income level or financial hardship.11 The public comment period ended on November 27, 2018 and the regulation may go into effect as early as Spring 2019, disproportionately impacting hundreds of thousands of elderly and working poor immigrants.12

This is an insidious attack on the ability of poorer immigrants to become U.S. citizens, under the guise of an unnecessary bureaucratic change in the documentation process for fee waivers. The proposed regulation would reverse a fee waiver policy that NPNA and allies fought for and won during the Obama administration.

C. Proposed Changes to Citizenship Application Will Make Naturalization Unnecessarily More Burdensome for Applicants, Legal Services Providers, and USCIS Adjudicators

On November 21, USCIS and DHS proposed regulations that will revise the application for citizenship, the Form N-400.13 The revision adds questions to Form N-400, which, if implemented, will prompt unnecessary, irrelevant, and duplicative information from applicants.

For example, applicants will also be required to submit birth certificates of their children with their N-400, which is not currently required. This is an unnecessary burden that would be cumbersome for immigrants from places like Norway, but difficult if not impossible for refugees from places like Syria or Somalia.14 A proposed new question will require applicants to include information about an arbitrary arrest or detention, which can be the basis for an asylum claim, and for which documentation can be difficult or impossible to obtain. This question, like a series of other ones, will prompt answers that have nothing to do with good moral character. Additional tax returns will be required in all cases and must be submitted with the application, as opposed to bringing them to the interview in some cases, as is currently done. There will also be confusing and contradictory instructions on whether documentation of certain traffic fines should be included.

The revisions will make the naturalization process much more burdensome for applicants and their legal representation to submit and USCIS adjudicators to process applications, creating additional

9 “Data Set: Form N-400 Application for Naturalization,” U.S. Citizenship and Immigration Services, accessed February 6, 2019, https://www.uscis.gov/tools/reports-studies/immigration-forms-data/data-set-form-n-400-application-naturalization. 10 “Annual Report 2018,” Office of Citizenship and Immigration Services Ombudsman, 27, June 28, 2018, https://www.dhs.gov/sites/default/files/publications/DHS%20Annual%20Report%202018.pdf. 11 Timmons, Patrick, “U.S. Seeks to Reduce Waivers for Immigration Fees,” UPI, October 4, 2018, https://www.upi.com/US-seeks-to-reduce-waivers-for-immigration-fees/3231538595416/. 12 Agency Information Collection Activities; Revision of a Currently Approved Collection: Request for Fee Waiver; Exemptions, 83 Fed. Reg. 49,120 (proposed September 28, 2018), https://www.govinfo.gov/content/pkg/FR-2018-09- 28/pdf/2018-21101.pdf. 13 Agency Information Collection Activities; Revision of a Currently Approved Collection; Application for Naturalization, 83 Fed. Reg. 225 (proposed November 21, 2018), https://www.govinfo.gov/content/pkg/FR-2018-11-21/pdf/2018- 25345.pdf. 14 See Public Comment from Jeanne Atkinson, Executive Director, Catholic Legal Immigration Network, Inc. to Samantha Deshommes, Chief, Regulatory Coordination Division, U.S. Citizenship and Immigration Services (January 16, 2019), https://cliniclegal.org/sites/default/files/advocacy/CLINIC-Comment-on-Proposed-Changes-to-N-400-and-Instructions_16- JAN-2019.pdf. 3 barriers for eligible LPRs and contributing to the already-increasing levels of backlogs and processing times. Additionally, for those who do apply, the revised application questions will place them in greater danger of receiving a Notice of Intent to Deny or Request for Information from USCIS, having the overall impact of discouraging citizenship applicants and making it more difficult for those who do apply.15 Applicants who are denied forfeit their $725 application fee, a significant burden for less affluent immigrants.

D. New Policy Guidance Makes it More Difficult for Applicants with Disabilities to Apply for Citizenship

On December 12, 2018, USCIS issued an alert of new policy guidance on Form N-648, which became effective on February 12, 2019.16 Form N-648 is the process through which a naturalization applicant can request an exemption from English and civic testing requirements based on a physical or developmental disability or mental impairment. The policy guidance creates the requirement that a Form N-648, which requires a certification from a licensed medical professional under penalty of perjury, must be submitted by the applicant along with their citizenship application. In the past, USCIS permitted an applicant to submit a Form N-648 at the time of their citizenship interview, using the months between submission of their application and their interview to gather the needed substantiating documents. Under the new policy, applicants who do not submit their citizenship application concurrently with the Form N-648 will be suspected of fraud by USCIS adjudicators.17 The practical impact of this change will be delays in eligible LPRs submitting their applications and higher scrutiny of eligible LPRs with disabilities or impairments. This negatively impacts the ability of elderly and disabled immigrants to become U.S. citizens.

E. USCIS Escalates Practice of Denaturalizing Citizens

USCIS has also committed unprecedented amounts of resources towards stripping naturalized citizens of their citizenship status, in some cases decades after they obtained it. In June 2018, the agency announced that it was hiring several dozen attorneys and immigration officers to form an office dedicated to denaturalization in their Los Angeles, California district office.18

The federal government has previously used the practice of revoking citizenship as a tool against naturalized as well as U.S.-born citizens.19 In the past, the government used the practice for political purposes, such as targeting those associated with communists and women who married foreign-born men, but it has since been largely limited by judicial oversight.20

15 Ibid. 16 U.S. Citizenship and Immigration Services Policy Alert, Sufficiency of Medical Certification for Disability Exceptions (Form N-648), December 12, 2018, available at https://www.uscis.gov/policymanual/Updates/20181212- N648MedicalCertification.pdf. 17 Ibid. 18 Taxin, Amy, “US Launches Bid to Find Citizenship Cheaters”, Associated Press, June 12, 2018, https://apnews.com/1da389a535684a5f9d0da74081c242f3. 19 Wesslet, Seth Freed, “Is Denaturalization the Next Front in the Trump Administration’s War on Immigration?”, New York Times, December 19, 2018, https://www.nytimes.com/2018/12/19/magazine/naturalized-citizenship-immigration- trump.html. 20 Ibid. 4

In recent history, denaturalization has been much less common. From 2014 to 2016, there was an average of 46 denaturalization cases each year. In each of the last two years, that number has nearly doubled.21 USCIS together with Immigration and Customs Enforcement are currently scrutinizing over a million cases that the agencies are considering referring to the Department of Justice for denaturalization, highlighting a multi-agency approach to making citizenship less accessible.22

F. Recent USCIS Policies and Practices are a Part of Larger Administrative Trend to Limit Access to Citizenship

The recent administrative policies and practices within USCIS come on the heels of signals from the agency that it is moving away from its public service mission to one that is increasingly part of the Trump administration’s aggressive enforcement agenda. This includes the February 2018 decision by USCIS to remove the “nation of immigrants” reference from its mission statement.23 It also includes policy guidance from Summer 2018 that expands the circumstances in which USCIS officials commence removal proceedings against applicants who are applying for benefits, and directs agency officials to deny applications for benefits, instead of requesting additional information or sending out a notice of intent to deny, in certain cases.24

There are also policy developments within USCIS that indirectly impact access to citizenship. For example, the proposed public charge regulation, once implemented, will not apply to citizenship applicants, but by limiting those who are eligible for lawful permanent residence status, it will in effect limit the pool of LPRs who are ultimately eligible for citizenship.25 Additionally, the interim final rule prohibiting asylum for those who arrive in the United States outside of a port of entry, which was eventually struck down in federal court, limited asylum seekers to applying for withholding of removal and relief under the Convention Against Torture.26 For the few weeks that this policy was in effect, it limited those eligible from applying for asylum, and in doing so, limited their eventual path to citizenship based on that form of relief.27

21 Wesslet, Seth Freed, “Is Denaturalization the Next Front in the Trump Administration’s War on Immigration?”, New York Times, December 19, 2018, https://www.nytimes.com/2018/12/19/magazine/naturalized-citizenship-immigration- trump.html. 22 Ibid. 23 Gonzales, Rich, “America No Longer a ‘Nation of Immigrants,’ USCIS Says,” NPR, February 22, 2018, https://www.npr.org/sections/thetwo-way/2018/02/22/588097749/america-no-longer-a-nation-of-immigrants-uscis-says. 24 U.S. Citizenship and Immigration Services Policy Memorandum, Updated Guidance for the Referral of Cases and Issuance of Notices to Appear (NTAs) in Cases Involving Inadmissible and Deportable Aliens, June 28, 2018, available at https://www.uscis.gov/sites/default/files/USCIS/Laws/Memoranda/2018/2018-06-28-PM-602-0050.1-Guidance-for- Referral-of-Cases-and-Issuance-of-NTA.pdf; U.S. Citizenship and Immigration Services Policy Memorandum, Issuance of Certain RFEs and NOIDs; Revisions to Adjudicator’s Field Manual (AFM) Chapter 10.5(a), Chapter 10.5(b), July 13, 2018, available at https://www.uscis.gov/sites/default/files/USCIS/Laws/Memoranda/AFM_10_Standards_for_RFEs_and_NOIDs_FINAL2.p df. 25 Inadmissibility on Public Charge Grounds, 83 Fed. Reg. 51,114 (proposed October 10, 2018) (to be codified at 8 CFR Parts 103, 212, 213, 214, 245 and 248), https://www.govinfo.gov/content/pkg/FR-2018-10-10/pdf/2018-21106.pdf. 26 Aliens Subject to a Bar on Entry Under Certain Presidential Proclamations; Procedures for Protection Claims, 83 Fed. Reg. 55,934 (proposed November 9, 2018) (to be codified at 8 CFR Parts 208, 1003 and 1208), https://www.govinfo.gov/content/pkg/FR-2018-11-09/pdf/2018-24594.pdf. 27 Ibid. 5

II. National Partnership for New Americans, Our Member Organizations, and Partners Committed to Tearing Down the Second Wall and Encouraging One Million Citizens by 2020

NPNA is a national multiethnic, multiracial partnership. We represent the collective power and resources of the country’s 39 largest regional immigrant and refugee rights organizations in 31 states. Almost all of our members assist their community members in submitting citizenship applications and have witnessed first-hand the positive impacts that newly-naturalized citizens and their communities experience, from economic benefits to New Americans being more active members of our democracy.

Accordingly in July 2018 we launched the Campaign the Tear Down the Second Wall with the objectives of substantially lowering the backlog of citizenship applications, reducing the processing times of applications, mobilizing our communities against attacks on citizenship, and encouraging eligible LPRs in our communities to apply for citizenship. We launched the campaign and released our report, “Tearing Down the Second Wall: Ending USCIS Backlog of Citizenship Applications and Expanding Access to Naturalization for Immigrants,” which analyzed data released by USCIS on the backlog of applications. 28 The campaign has since resulted in over 50 Congressional members scrutinizing USCIS over the backlogs; nearly 50 Mayors and County Executives condemning the growing backlogs and processing times; and a City Council Resolution demanding action from the agency.29

In August 2018, NPNA filed a Freedom of Information Act request to uncover the reasons for the backlog and demand transparency and accountability from USCIS, represented by the Center for Human Rights and Constitutional Law and the Coalition for Humane Immigrant Rights, and joined by UnidosUS, CASA, Michigan United, Mi Familia Vota, New York Immigration Coalition, and OneAmerica.30 Based on a lack of response from the agency, we filed suit against USCIS in the United States District Court for the Central District of California, Western Division, on Citizenship Day, September 17, 2018.31 We continue to suspect that racial, ethnic, and/or religious bias, as well as intentional voter suppression strategies, are motivating the backlog of citizenship applications and increasing processing delays, and will continue to pressure USCIS from within and outside the courts to release the requested information.

In response to the numerous regulatory changes limiting access to citizenship, NPNA has submitted public comments and worked with our networks to inform immigrants and their advocates of

28 Iñiguez-López, Diego, “Tearing Down the Second Wall: Ending USCIS Backlog of Citizenship Applications and Expanding Access to Naturalization for Immigrants,” National Partnership for New Americans, July 2, 2018, https://drive.google.com/file/d/0B82AwIa7WIa_RmtxM3BUZEtOcV9vdVdwVU85U2hwbHd1QmVj/view. 29 Letter from Representative Zoe Lofgren, et al. to L. Francis Cissna, Director, U.S. Citizenship and Immigration Services (June 29, 2018), https://drive.google.com/file/d/0B82AwIa7WIa_NTF5MGNzY3RqaTM1ekJnM1dSMXE4dS1HQVJB/view; Letter from Mayor Rahm Emanuel, et al. to L. Francis Cissna, Director, U.S. Citizenship and Immigration Services (July 30, 2018), https://drive.google.com/file/d/0B_RDXQk6QObAZU1VQmZXUFVFTjhfSW5sWF9yRmN4VVlLREFB/view; City of Seattle Resolution 31832 (2018), https://seattle.legistar.com/View.ashx?M=F&ID=6584585&GUID=E4AC5DDB-E016- 4FD3-A62F-002C5AA36DB0. 30 Macias Jr., Martin, “Feds Sued Over Citizenship Processing Backlog,” Courthouse News, September 17, 2018, https://www.courthousenews.com/feds-sued-over-citizenship-processing-backlog/. 31 Ibid. 6 policy changes.32 On February 22, 2019, we will be testifying before the Colorado State Advisory Committee for the U.S. Commission on Civil Rights, as it examines the backlog of naturalization applications, the cause of the backlog, the impact it has had on applicants, and potential solutions. We will also be advocating for stronger Congressional oversight of USCIS.

As the processing delays of citizenship applications grows and continues to limit immigrants’ civic engagement, NPNA remains committed to working with our member organizations and networks to escalate efforts to encourage eligible LPRs to apply for citizenship. This includes encouraging one million eligible LPRs to apply before 2020. Despite obstacles, eligible LPRs can and should apply. It may take longer and they may need more help, but NPNA members and others stand willing and able to help them apply for citizenship, fully participate in our economy for the benefit of all, protect themselves and their families, and have their voices heard.

32 Public Comment from Joshua Hoyt, Executive Director, National Partnership for New Americans to Samantha Deshommes, Chief, Regulatory Coordination Division, U.S. Citizenship and Immigration Services (November 27, 2018), https://www.regulations.gov/document?D=USCIS-2010-0008-1193. 7

Appendix

USCIS Office, Processing Delay, Voter Registration Deadline by Mail, and the Date when Eligible Lawful Permanents who have Submitted Citizenship Application Risk Not Being Processed and Naturalized and Then Missing the Opportunity to Register to Vote in Time for Presidential Election of 2020

Processing Delay (in months) (according to Voter USCIS data as of Registration Cut off USCIS Office January 18, 2019) Deadline Date Agana, Guyana 11.5-18.5 N/A N/A Albany, NY 11.5-18.5 10/10/2020 3/25/2019 Albuquerque, NM 5 to 14 10/7/2020 8/7/2019 Anchorage, AK 11.5 to 18.5 10/3/2020 3/26/2019 Atlanta, GA 16 to 23 10/5/2020 11/5/2018 Baltimore, MD 13 to 16.5 10/13/2020 5/28/2019 Boise, ID 11.5 to 18.5 10/9/2020 3/25/2019 Boston, MA 5.5 to 16 10/14/2020 6/14/2019 Brooklyn, NY 14.5 to 20.5 10/10/2020 1/26/2019 Buffalo, NY 6 to 18.5 10/10/2020 3/26/2019 Charleston, SC 3.5 to 12 10/4/2020 10/4/2019 Charlotte, Amelie VI 11.5 to 18.5 N/A N/A Charlotte, NC 8.5 to 14.5 10/9/2020 7/25/2019 Chicago, IL 9.5 to 15 10/6/2020 7/6/2019 Christiansted VI 11.5 to 18.5 N/A N/A Cincinnati, OH 5.5 to 19.5 10/4/2020 2/20/2019 Cleveland, OH 4 to 13 10/4/2020 9/4/2019 Columbus, OH 5 to 17.5 10/4/2020 4/20/2019 Dallas, TX 17 to 20 10/4/2020 2/4/2019 Denver, CO 13.5 to 19 10/26/2020 3/26/2019 Des Moines, IA 11.5 to 18.5 10/19/2020 4/4/2019 Detroit, MI 8 to 16 10/4/2020 6/4/2019 El Paso, TX 11.5 to 18.5 10/4/2020 3/20/2019 Fort Myers, FL 15 to 20 10/5/2020 2/5/2019

Fort Smith, AR 11.5 to 18.5 10/4/2020 3/20/2019 Fresno, CA 7 to 13.5 10/19/2020 9/5/2019 Greer, SC 5.5 to 16 10/4/2020 6/4/2019 Harlingen, TX 14.5 to 18.5 10/4/2020 3/20/2019 Hartford, CT 8.5 to 16.5 10/27/2020 6/13/2019 Helena, MT 11.5 to 18.5 10/4/2020 3/20/2019 Hialeah, FL 6 to 15 10/5/2020 7/5/2019 Honolulu, HI 11.5 to 19 10/5/2020 10/5/2019 Houston, TX 17 to 20.5 10/4/2020 1/20/2019 Imperial, CA 11.5 to 18.5 10/19/2020 4/5/2019 Indianapolis, IN 5.5 to 9.5 10/5/2020 12/21/2019 Jacksonville, FL 4.5 to 15.5 10/5/2020 6/21/2019 Kansas City, MO 5.5 to 15 10/7/2020 7/7/2019 Kendall, FL 8 to 16.5 10/5/2020 5/21/2019 Las Vegas, NV 15 to 18 10/3/2020 4/3/2019 Lawrence, MA 6 to 16.5 10/14/2020 5/30/2019 Long Island, NY 6.5 to 17 10/10/2020 5/10/2019 Los Angeles, CA 10.5 to 17 10/19/2020 5/19/2019 Los Angeles County, CA 9 to 16.5 10/19/2020 5/5/2019 Louisville, KY 5 to 14 10/5/2020 8/5/2019 10/21/2020 (deadline is not uniform throughout Manchester, NH 11.5 to 18.5 state) 4/7/2019 Memphis, TN 12 to 20.5 10/4/2020 1/20/2019 Miami, FL 16 to 21.5 10/5/2020 12/21/2018 Milwaukee, WI 8 to 12.5 10/14/2020 9/30/2019 Minneapolis-St. Paul, MN 15.5 to 23 10/13/2020 11/13/2018 Montgomery, AL 13.5 to 21 10/19/2020 1/19/2019 Mount Laurel, NJ 5 to 18 10/13/2020 4/13/2019 Nashville, TN 13.5 to 15.5 10/4/2020 6/20/2019 Newark, NJ 12 to 16 months 10/13/2020 2/13/2019 New Orleans, LA 13.5 to 20.5 10/4/2020 1/20/2019

New York City, NY 11.5 to 22 10/10/2020 12/10/2018 Norfolk, VA 8.5 to 12 10/12/2020 10/12/2019 Oakland Park, FL 14 to 19.5 10/5/2020 2/21/2019 Oklahoma City, OH 8.5. to 20.5 10/4/2020 1/20/2019 Omaha, NE 6.5 to 16 10/16/2020 6/16/2019 Orlando, FL 9.5 to 17.5 10/5/2020 4/21/2019 Philadelphia, PA 9 to 20.5 10/4/2020 1/20/2019 Phoenix, AZ 14.5 to 18 10/5/2020 4/5/2019 Pittsburgh, PA 11.5 to 18.5 10/4/2020 3/20/2019 Portland, ME 11.5 to 18.5 10/13/2020 3/29/2019 Portland, OR 6.5 to 13.5 10/13/2020 8/29/2019 Providence, RI 11.5 to 18.5 10/4/2020 3/20/2019 Queens, NY 12.5 to 20 10/10/2020 2/20/2019 Raleigh, NC 5.5 to 11.5 10/9/2020 10/25/2019 Reno, NV 11.5 to 18.5 10/3/2020 3/19/2019 Sacramento, CA 9 to 15.5 10/19/2020 6/5/2019 Saint Albans, VT 11.5 to 18.5 11/3/2020 4/19/2019 Saint Louis, MO 8.5 to 18.5 10/7/2020 3/23/2019 Salt Lake City, UT 15 to 19 10/4/2020 3/4/2019 San Antonio, TX 13 to 20 10/4/2020 2/4/2019 San Bernardino, CA 5.5. to 14 10/19/2020 8/19/2019 San Diego, CA 11.5 to 18.5 10/19/2020 3/5/2019 San Fernando Valley, CA 11.5 to 15 10/19/2020 7/19/2019 San Francisco, CA 13 to 16.5 10/19/2020 6/5/2019 San Jose, CA 9 to 15 10/19/2020 7/19/2019 San Juan, PR 11.5 to 18.5 N/A N/A Santa Ana, CA 13 to 15.5 10/19/2020 7/5/2019 Seattle, WA 15 to 17 10/5/2020 5/5/2019 Spokane, WA 11.5 to 18.5 10/5/2020 3/21/2019 Tampa, FL 5 to 14.5 10/5/2020 7/21/2019 Tucson, AZ 6.5 to 16.5 10/5/2020 5/21/2019 10

Washington, D.C. 9.5. to 16 10/13/2020 6/13/2019 West Palm Beach, FL 5.5 to 19 10/5/2020 3/5/2019 Wichita, KS 6.5 to 13.5 10/13/2020 8/29/2019 Yakima, WA 11.5 to 18.5 10/5/2020 3/21/2019