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The Brief

The most important stories for you to know today
  • We break down the process and costs
    NPR spoke to immigration experts and lawyers and reviewed government documents to break down the steps of the U.S. deportation process and its cost.
    NPR spoke to immigration experts and lawyers and reviewed government documents to break down the steps of the U.S. deportation process and its cost.

    Topline:

    Here's how immigration experts and lawyers who reviewed government documents break down the steps and associated costs of the U.S. deportation process.

    Why now: President Trump kicked off his second term vowing to deport a record number of people from the U.S. But deportation is typically a cumbersome process generally involving an arrest, detention, a removal order from a judge and finally a flight out of the U.S. and can take months or years.

    What's next: Trump has taken steps to change how law enforcement officials track, find, detain and remove those in the country without legal status. He's also broadened the categories of people eligible for deportation.

    Keep reading... for details on each step of the process.

    President Trump kicked off his second term vowing to deport a record number of people from the U.S. But deportation — a cumbersome process generally involving an arrest, detention, a removal order from a judge and finally a flight out of the U.S. — can take months or years.

    "Each of those pieces can be extremely difficult and complicated depending on where someone is, who they are, what types of protection claims they might have, what types of resources the U.S. government has," said Kathleen Bush-Joseph, lawyer and policy analyst with the U.S. Immigration Policy Program at the Migration Policy Institute, a nonpartisan think tank.

    Much like his predecessors, Trump has taken steps to change how law enforcement officials track, find, detain and remove those in the country without legal status. He's also broadened the categories of people eligible for deportation.

    "The sands are shifting underneath our feet," said Eric Welsh, partner at Reeves Immigration Law Group in Los Angeles, which represents individuals and businesses on issues related to immigration status and visas.

    NPR spoke to immigration experts and lawyers and reviewed government documents to break down the steps of the U.S. deportation process and its cost. This is meant as a general breakdown of the process and not a rule for each individual's circumstances. 


    Step 1: Identifying who is removable

    In March, Immigration and Customs Enforcement told reporters it had arrested 32,000 people since Trump took office. 

    Those at risk for arrest include people without legal status because they may have entered the country illegally, overstayed a work or student visa, or violated the terms of their green card, including by committing a crime.

    But immigration law experts add that federal law officials do not have to prove someone committed a crime to deport them — as recent examples of revoked student visas show.

    Trump's latest moves include ending programs that granted legal status to migrants from certain countries. The administration said it would not renew Haitians and Venezuelans' Temporary Protected Status, a program that grants citizens of certain countries permission to live and work in the U.S. The White House also said it would end a Biden-era humanitarian program that granted two-year permits to live and work in the U.S. to Cubans, Haitians, Nicaraguans and Venezuelans who had fiscal sponsors in the United States.

    There is pending litigation that has paused plans to end the protections, but if they lapse, once-eligible people who remain in the U.S. would be in the country without legal status and thus eligible for deportation.

    Former President Joe Biden had a focus on border-region enforcement as the number of border encounters increased during his tenure. This second Trump administration has seen a low in border encounters compared to last year and has pivoted its enforcement to the interior of the country.


    Step 2: Arrests

    Those at risk for arrests include people without legal status because they may have entered the country illegally, overstayed a work or student visa, or violated the terms of their green card, including by committing a crime.
    Those at risk for arrests include people without legal status because they may have entered the country illegally, overstayed a work or student visa, or violated the terms of their green card, including by committing a crime.
    (
    Ana Galvañ for NPR
    )

    Since taking office, Trump and Homeland Security Secretary Kristi Noem have tapped law enforcement in other federal agencies to assist with arrests to meet an aggressive quota pushed by Trump's officials.


    In January, ICE officers were assigned a quota of 75 arrests per day for each of the 20 field offices.

    The FBI, U.S. Marshals Service and Drug Enforcement Administration are now assisting in investigations and arrests. But those "at-large arrests" — done directly by federal agents — have constituted a minority of all ICE arrests in most years, according to the Migration Policy Institute; they were just 29% of all arrests in fiscal year 2024. Typically, most arrests come from local law enforcement.

    Often, that involves the Criminal Alien Program, which takes people who are in local jails and prisons and transfers them to ICE custody, and a provision known as 287(g), which allows local police and jails to conduct limited immigration law enforcement.

    Immigration detention can come at any point from arrest to a final decision in court. The cost can range and DHS also uses government contracts with private prison operators to expand available space. One recent contract is estimated to generate $180 million in annual revenue for CoreCivic. Alternatives to detention, such as ankle monitors and regular check-ins with ICE, can also be used.

    Immigration lawyers explain that sometimes immigrants may ignore a notice to appear, or miss the notice altogether due to filing glitches. But a failure to appear results in a final order of removal.

    Trump has also sought to skip the court process, relying on programs like "expedited removal," which allows anyone in the country for under two years without legal status to be deported quickly, and the "Alien Enemies Act," which the government has claimed allows it to deport people it deems members of Venezuelan gangs without due process, an assertion under intense legal scrutiny in federal courts.


    Step 3: Immigration court system

    A person is required to appear in court for a judge to decide whether they are removable.
    A person is required to appear in court for a judge to decide whether they are removable.
    (
    Ana Galvañ for NPR
    )

    Immigration law decisions, including whether someone gets a final removal order, fall under the Executive Office for Immigration Review within the Justice Department. That office had more than 4 million pending cases in the last quarter of 2024.


    "People referred to the immigration courts might end up waiting years before they have a hearing determining their case," said Bush-Joseph, from the Migration Policy Institute. "And when someone files for asylum, those cases can actually take even longer because of the complex nature of the claims."

    If a person is found to be removable by a judge, a judge may find them "removable as charged," which is not a final order of removal but kicks off the rest of the process. The person does not lose their status at this point, if they have it.

    "It's just like any other form of litigation. You can say 'I deny that' and the government has to prove that you are removable," said John Conrace, an immigration attorney in Mississippi. "People who get orders of removal, those are often generated because they are afraid to go to their initial hearing."

    If they appear in court, people have the right to ask for time to seek legal representation, though most people don't have lawyers.

    Immigration lawyers say they often look for two numbers to prepare for the next step: if the person has been here for less than one year or more than 10. Less than one year allows a person to potentially claim asylum. More than 10 can stave off final removal if people can prove there is a relative who will suffer extreme hardship if the person is deported, or if they have a U.S. citizen spouse or children. But this is hard to win — and never grants a pathway to legal status.

    Those in the country between one and 10 years can try to withhold removal based on other claims, such as risk of persecution or humanitarian relief.

    The case of Kilmar Armando Abrego Garcia is a good example: the El Salvador immigrant was able to stave off deportation by arguing, in part, that it was more likely than not that he would be persecuted by gangs in El Salvador. The government later said it deported him by mistake, prompting a lawsuit and a judge's order to bring him back.


    Step 4: Removal

    If a person's claims to stave off deportation fail, the judge issues a final order of removal.
    If a person's claims to stave off deportation fail, the judge issues a final order of removal.
    (
    Ana Galvañ for NPR
    )

    If people's claims to stave off deportation fail, the judge issues a final order of removal. That's also appealable. People can also choose to "voluntarily depart," which is not a formal deportation and does not reflect on a person's future immigration record.


    Appeals of removal are filed with the DOJ's Board of Immigration Appeals and could reach circuit courts and then the Supreme Court.

    "That takes a wildly varied amount of time. If you are not detained and you are free, it could be years before the BIA gets to resolving the issue that was appealed," Conrace said, adding that it is not common for cases to make it up to the highest court.

    In fiscal year 2024, immigration courts issued 666,177 initial case decisions, with a plurality being removal orders.

    As of the last quarter of 2024, there were 1.5 million pending asylum cases in immigration court and 1 million with the U.S. Citizenship and Immigration Services.

    "The current pace of work means that it would take a lot more resources, a lot more immigration judges and asylum officers, to be trying to work through these applications at a faster pace than is currently happening," Bush-Joseph said.

    About 1.4 million people have pending deportation orders, according to ICE, but there are challenges to sending many back to their home countries. One reason is that their home countries have not agreed to accept them.

    The Biden administration carried out deportations to 192 countries in the last fiscal year — nearly every country in the world. The Trump administration is aiming to make inroads with others to be "third-party countries" that can take in deportees.

    Estimates on total cost to deport one person vary depending on where someone is apprehended, how long they are in detention and the length of their legal battle. DHS' budget for ICE is $8 billion, the Customs and Border Protection budget is $20 billion and U.S. Citizenship and Immigration Services budget, which is covered by the fees people pay to apply for citizenship and other benefits, is $865 million. Not all this money goes to immigration law enforcement.

    "Overall, the U.S. immigration system remains extremely overwhelmed, under-resourced and outdated," Bush-Joseph said. "It's going to take congressional action to really update and reform the system and bring it into the 21st century to meet modern migration challenges."

    That reform, though, has proved a challenge — decades of reform efforts have died in Congress. A promising bipartisan effort came together early last year after months of careful negotiation, but fell apart less than a day after it was made public — as then-candidate Trump pressured Republicans to oppose the deal in order to keep border security alive as an issue in the presidential election.

    Now, the administration is hoping that Congress can provide $175 billion for border security in the budget reconciliation process later this year.

    Copyright 2025 NPR

  • Dodgers fans grapple with loyalty ahead of it
    A man with medium skin tone, wearing a blue Dodgers shirt, speaks into a microphone standing behind a podium next to others holding up signs that read "No repeat to White House. Legalization for all" and "Stand with you Dodger community." They all stand in front of a blue sign that reads "Welcome to Dodger Stadium."
    Jorge "Coqui" H. Rodriguez speaks at a press conference outside Dodger Stadium on Wednesady to demand the Dodgers not visit the White House following their 2025 World Series win.

    Topline:

    Less than 24 hours before season opener, longtime Dodgers fans demand the team divest from immigration detention centers and decline the White House visit.

    More details: More than 30 people joined Richard Santillan on Wednesday morning for a press conference held near 1000 Vin Scully Drive to convey a message directly to the team. “We are demanding that the Dodgers stop participating in funding of inhumane treatment of families and do not go to the White House to celebrate with the criminal in chief,” Evelyn Escatiola told the crowd. “Together we have the power to make a change.”

    The backstory: The team’s 2025’s visit to the White House drew ire from the largely Latino fan base, citing the Trump administration’s ongoing attacks on immigrants. In June, the team came under further scrutiny when rumors swirled online that federal immigration agents were using the stadium’s parking, which immigration authorities later denied in statements posted on social media accounts.

    Read on ... for more on how some fans are feeling leading up to Opening Day.

    This story first appeared on The LA Local.

    Since 1977, Richard Santillan has been to every Opening Day game at Dodger Stadium. 

    “The tradition goes from my father, to me, to my children and grandchildren. Some of my best memories are with my father and children here at Dodger Stadium,” Santillan told The LA Local, smiling under the shade of palm trees near the entrance to the ballpark Wednesday morning. He was there to protest the team less than 24 hours before Opening Day.

    Santillan, like countless other loyal Dodgers fans, is grappling with his fan identity over the team’s decision to accept an invitation to the White House and owner Mark Walter’s ties to ICE detention facilities.

    More than 30 people joined Santillan on Wednesday morning for a press conference held near 1000 Vin Scully Drive to convey a message directly to the team. 

    “We are demanding the Dodgers stop participating in funding of inhumane treatment of families and do not go to the White House to celebrate with the criminal in chief,” Evelyn Escatiola told the crowd. “Together, we have the power to make a change.”

    Escatiola, a former dean of East Los Angeles College and longtime community organizer, urged fans to flex their economic power by “letting the Dodgers know that we do not support repression.”

    Jorge “Coqui” Rodriguez, a lifelong Dodgers fan, spoke to the crowd and called on Dodgers ownership to divest from immigration detention centers owned and operated by GEO Group and CoreCivic.

    A man with medium skin tone, wearing a blue Dodgers t-shirt, speaks into a microphone behind a podium.
    Jorge Coqui H Rodriguez speaks at a press conference outside Dodger Stadium on March 25, 2026, to demand the Dodgers not to visit the White House following their 2025 World Series win.
    (
    J.W. Hendricks
    /
    The LA Local
    )

    In a phone interview a day before the protest, Rodriguez told The LA Local he did not want the Dodgers using his “cheve” or beer money to fund detention centers. 

    “They can’t take our parking money, our cacahuate money, our cheve money, our Dodger Dog money and invest those funds into corporations that are imprisoning people. It’s wrong,” Rodriguez said. 

    Rodriguez considers the Dodgers one of the most racially diverse teams and said the players need to support fans at a time when heightened immigration enforcement has become more common across L.A.

    The team’s 2025’s visit to the White House drew ire from the largely Latino fan base, citing the Trump administration’s ongoing attacks on immigrants. 

    In June, the team came under further scrutiny when rumors swirled online that federal immigration agents were using the stadium’s parking, which immigration authorities later denied in statements posted on social media accounts.

    The team again came under fire after not releasing a statement on the impacts of ICE raids on its mostly Latino fan base at the height of immigration enforcement last summer. The team later agreed to invest $1 million to support families affected by immigration enforcement.

    When he learned the Dodgers were pledging only $1 million to families in need, Rodriguez called the amount a  “slap in the face.” 

    “These guys just bought the Lakers for billions of dollars and they give a million dollars to fight for legal services? That’s a joke,” Rodriguez said. “They need to have a moral backbone and not be investing in those companies.”

    According to reporting from the Los Angeles Times, former Dodgers pitcher Clayton Kershawsaid last week that he is looking forward to the trip.

    “I went when President [Joe] Biden was in office. I’m going to go when President [Donald] Trump is in office,” Kershaw said. “To me, it’s just about getting to go to the White House. You don’t get that opportunity every day, so I’m excited to go.”

    The Dodgers have yet to announce when their planned visit will take place. 

    Santillan sometimes laments his decision to give up his season tickets in protest of the team. His connection to the stadium and the memories he has made there with family and friends will last a lifetime, he said. On Thursday, he will uphold his tradition and be there for the first pitch of the season, but with a heavy heart.

    “It’s a family tradition, but the Dodgers have a lot of work to do,” he said.

  • Sponsored message
  • Warmer weather has caused more biting flies
    A zoomed in shot of a fuzzy black fly with some white spots.
    The warmer weather and high water flow are causing an early outbreak of black flies in the San Gabriel Valley.

    Topline:

    The warmer weather and high water flow are causing an early outbreak of black flies in the San Gabriel Valley, according to officials.

    What are black flies? Black flies are tiny, pesky insects that often get mistaken for mosquitoes. The biting flies breed near foothill communities like Altadena, Azusa, San Dimas and Glendora. They also thrive near flowing water.

    What you need to know: Black flies fly in large numbers and long distances. When they bite both humans and pets, they aim around the eyes and the neck. While the bites can be painful, they don’t transmit diseases in L.A. County.

    A population spike: Anais Medina Diaz, director of communications at the SGV Mosquito and Vector Control District, told LAist that at this time last year, surveillance traps had single-digit counts of adult black flies, but this year those traps are collecting counts above 500.

    So, why is the population growing? Diaz said the surge is unusual for this time of year.

    “We are experiencing them now because of the warmer temperatures we've been having,” Diaz said. “And of course, all the water that's going down through the river, we have a high flow of water that is not typical for this time of year.”

    What officials are doing: Officials say teams are identifying and treating public sources where black flies can thrive, but that many of these sites are influenced by natural or infrastructure conditions outside their control.

    How to protect yourself: Black flies can be hard to avoid outside in dense vegetation, but you can reduce the chance of a bite by:

    • Wearing loose-fitted clothing that covers the entire body. 
    • Wearing a hat with netting on top. 
    • Spraying on repellent, but check the label. For a repellent to be effective, it needs to have at least 15% DEET, the only active ingredient that works against black flies.
    • Turning off any water features like fountains for at least 24 hours, especially in foothill communities.

    See an uptick in black flies in your area? Here's how to report it

    SGV Mosquito and Vector Control District
    Submit a tip here
    You can also send a tip to district@sgvmosquito.org
    (626) 814-9466

    Greater Los Angeles Vector Control District
    Submit a service request here
    You can also send a service request to info@GLAmosquito.org
    (562) 944-9656

    Orange County Mosquito and Vector Control
    Submit a report here
    You can also send a report to ocvcd@ocvector.org
    (714) 971-2421 or (949) 654-2421

  • Rent hike to blame
    A black and brown dog lays down on a brown sofa on the foreground. In the background, a man wearing a plaid shirt sits.
    Jeremy Kaplan and Florence at READ Books in Eagle Rock.
    Topline:
    Local favorite mom and pop shop READ Books in Eagle Rock is facing displacement due to a steep rent hike. The owners say they’re just one of several small businesses along Eagle Rock Boulevard struggling to keep up with lease increases.

    The backstory: Over the past 19 years, many in the neighborhood have come to love READ Books for its eclectic collection of used titles and their shop dog Florence.

    What happened? The building where Kaplan and his wife Debbie rent was recently sold and the rent increased by more than 130% to $2,805 a month, Kaplan said. He told LAist it was an increase his small business simply could not absorb.

    What's next? While he looks for a new spot, Kaplan says he’s forming a coalition of local businesses and activist groups to see what can be done to help other small businesses facing similar displacement. He wants to address the displacement issue for businesses like his, which have made Eagle Rock the distinctive neighborhood that it is today.

    Read on... for what small businesses can do.

    A local favorite mom-and-pop bookshop in Eagle Rock is facing displacement due to a steep rent hike. The owners say theirs is just one of several small businesses along Eagle Rock Boulevard struggling to keep up with lease increases.

    Over the past 19 years, many in the neighborhood have come to love READ Books for its eclectic collection of used titles and shop dog Florence.

    Co-owner Jeremy Kaplan said it’s been a delight to grow with the community over the years.

    “Like seeing kids come back in, who were in grade school and now they’re in college,” Kaplan said.

    But the building where Kaplan and wife Debbie rent was recently sold, and the rent increased by more than 130% to $2,805 a month, Kaplan said. He told LAist it was an increase his small business simply could not absorb.

    Kaplan said he originally was given 30 days notice of the rent increase. After some research, assistance from Councilmember Ysabel Jurado’s office and some pro-bono legal help, Kaplan said he pushed back and got the 90-day notice he’s afforded by state law.

    California Senate Bill 1103 requires landlords to give businesses with five or less employees 90 days’ notice for rent increases exceeding 10%, among other protections.

    Systems Real Estate, the property management company, did not immediately respond to LAist’s request for comment.

    What can small businesses do? 

    Nadia Segura, directing attorney of the Small Business Program at pro bono legal aid non-profit Bet Tzedek said California law does not currently allow for rent control for commercial tenancies.

    Outside of the protections under SB 1103, Segura said small businesses like READ Books don’t have much other recourse. And even then, commercial landlords are not required to inform their tenants of their protections under the law.

    “There’s still a lot of people that don’t know about SB 1103. And then it’s very sad that they tell them they have these rent increases and within a month they have to leave,” Segura said.

    She said her group is seeing steep rent hikes like this for commercial tenants across the city.

    “We are seeing this even more with the World Cup coming up, the Olympics coming up. And I will say it was very sad to see that also after the wildfires,” Segura said.

    Part of Bet Tzedek’s ongoing work is to advocate for small businesses, working with landlords who are increasing rents to see if they are willing to give business owners longer leases that lock in rents.

    What’s next 

    After READ Books posted about their situation on social media, commenters chimed in to express their outrage and love for the little shop.

    While he looks for a new spot, Kaplan says he’s forming a coalition of local businesses and activist groups to see what can be done to help other small businesses facing similar displacement. He wants to address the displacement issue for businesses like his, which have made Eagle Rock the distinctive neighborhood that it is today.

    Owl Talk, a longtime Eagle Rock staple selling clothing and accessories in a unit in the same building as READ Books, is facing a “more than double” rent increase, according to a post on their Instagram account.

    Kaplan said he’s been in touch with the office of state Assemblywoman Jessica Caloza and wants to explore the possibility of introducing legislation to set up protections for small businesses like his, including rent-control measures or a vacancy tax for landlords. Kaplan said he also reached out to the office of state Sen. Maria Durazo.

    By his count, Kaplan said there are about a dozen businesses within surrounding blocks that are at risk of closing their doors or have shuttered due to rent increases or other struggles.

    When READ Books was founded during the Great Recession, Kaplan said he knew it was a longshot to open a bookstore at the same time so many were struggling to stay in business.

    “It was kind of interesting to be doing something that neighborhoods needed. That was important to me growing up, that was important to my children, that was important to my wife growing up,” Kaplan said.

    “And then somebody comes in and says, ‘We’re gonna over double your rent.”

  • Ballots to be sent out
    A person sits in the carriage of a crane and places solar panels atop a post. The crane is white, and the number 400 is printed on the carriage in red.
    A field team member of the Bureau of Street Lighting installs a solar-powered light in Filipinotown.

    Topline:

    The Los Angeles City Council approved a plan in a 13-1 vote on Tuesday to send ballots to more than half a million property owners asking if they are willing to pay more per year to fortify the city’s streetlight repair budget, most of which has essentially been frozen since the 1990s. The item still requires L.A. Mayor Karen Bass’ signature, but her office confirmed to LAist on Wednesday that she’ll approve it.

    Frozen budget: Most of the city’s Bureau of Street Lighting budget comes from an assessment that people who own property illuminated by lights pay on their county property tax bill. The amount people pay depends on the kind of property they own and how much they benefit from lighting. A typical single-family home currently pays $53 annually, and in total, the assessments bring in about $45 million annually for the city to repair and maintain streetlights. Changing the amount the Bureau of Street Lighting gets from the assessment requires a vote among property owners who benefit from the lights.

    Ballots: L.A. City Council’s vote gives city staff the green light to prepare and send out those ballots. Miguel Sangalang, who oversees the bureau, said at a committee meeting earlier this month that he expects to send out ballots by April 17. Notices about the ballots will be sent out prior to the ballots themselves.

    Near unanimous vote: L.A. City Councilmember Monica Rodriguez was the only “No” vote on Tuesday, saying she wanted to see a more current strategic plan for the bureau. Sangalang said the bureau developed a plan in 2022 that lays out how money will be spent. Councilmember Imelda Padilla was absent for the vote.

    Vote count: Votes will be weighted according to the assessment amount. Basically, the more you’re asked to pay yearly to maintain streetlights, the more your vote will count. Ballots received before June 2 will be tabulated by the L.A. City Clerk.

    How much more money: According to a report, the amount needed in assessments from property owners to meet the repair and maintenance needs of the city’s streetlighting in the next fiscal year is nearly $112 million.

    Use of the money: Sangalang said at a March 11 committee meeting that the extra funds would be used to double the number of staff to handle repairs and procure solar streetlights, which don’t face the threat of copper wire theft. That would all potentially reduce the time it takes to repair simple fixes down to a week. Currently, city residents wait for months to see broken streetlights repaired.The assessment would come with a three-year auditing mechanism.

    Topline:

    The Los Angeles City Council approved a plan in a 13-1 vote Tuesday to send ballots to more than a half-million property owners asking if they are willing to pay more per year to fortify the city’s streetlight repair budget, most of which essentially has been frozen since the 1990s. The item still requires L.A. Mayor Karen Bass’ signature, but her office confirmed to LAist on Wednesday that she’ll approve it.

    Frozen budget: Most of the city’s Bureau of Street Lighting budget comes from an assessment that people who own property illuminated by lights pay on their county property tax bill. The amount people pay depends on the kind of property they own and how much they benefit from lighting. A typical single-family home currently pays $53 annually, and in total, the assessments bring in about $45 million annually for the city to repair and maintain streetlights. Changing the amount the Bureau of Street Lighting gets from the assessment requires a vote among property owners who benefit from the lights.

    Ballots: L.A. City Council’s vote gives city staff the green light to prepare and send out those ballots. Miguel Sangalang, who oversees the bureau, said at a committee meeting earlier this month that he expects to send out ballots by April 17. Notices about the ballots will be sent out prior to the ballots themselves.

    Near unanimous vote: L.A. City Councilmember Monica Rodriguez was the only “No” vote Tuesday, saying she wanted to see a more current strategic plan for the bureau. Sangalang said the bureau developed a plan in 2022 that lays out how money will be spent. Councilmember Imelda Padilla was absent for the vote.

    Vote count: Votes will be weighted according to the assessment amount. Basically, the more you’re asked to pay yearly to maintain streetlights, the more your vote will count. Ballots received before June 2 will be tabulated by the L.A. City Clerk.

    How much more money: According to a report, the amount needed in assessments from property owners to meet the repair and maintenance needs of the city’s streetlighting in the next fiscal year is nearly $112 million.

    Use of the money: Sangalang said at a March 11 committee meeting that the extra funds would be used to double the number of staff to handle repairs and procure solar streetlights, which don’t face the threat of copper wire theft. That would all potentially reduce the time it takes to repair simple fixes down to a week. Currently, city residents wait for months to see broken streetlights repaired. The assessment would come with a three-year auditing mechanism.