Public comments matter. Under federal law, government agencies are duty-bound to read and take into account the entire public record when making a new regulation, and that includes your comments! If the government fails to reflect the public’s feedback in the final rule, it could be vulnerable to legal challenge under the Administrative Procedures Act. However, it is critical to personalize these comments with your perspective and unique voice—a single, well-supported submission may carry more weight than a thousand form letters.
Below find some tips to help organize your process and strengthen your final submission. If at any point you need some help, please reach out to UUSC staff at info [@] uusc.org.
Step 1: Find the proposed rule and comment period deadline
To find a proposed rule, you can search the Federal Register. The Federal Register is published every weekday and includes all proposed rules open for public comment. In addition to the full language of the rule, you will also find information on relevant deadlines and how to submit comments, for example electronically through regulations.govor mailed directly to an agency official.
Comment periods are often short, typically 30-60 days. In general, written comments postmarked on or before the listed deadline will be considered timely. Regulations.govwill accept comments before midnight eastern time of the last day of the comment period.
Step 2: Draft your comment
To get your message across, you need to frame your comment in a clear, concise, and convincing manner. It will be helpful to quickly outline or draft your comment before sitting down to type it into the portal.
Attempt to understand each issue fully. Gather background materials to familiarize yourself with the scope of the issue by reading the full rule. Their mission should drive federal agencies’ actions—strengthen your comment by examining how the rule will enhance or detract from the agency’s purpose. If you disagree with a proposal, suggest an alternative (including not regulating at all).
Comments can address one or two specific aspects of the proposed rule, fully address all points, or address the subject in a general manner. If you’re not sure where to start, select those issues which concern and affect you the most, or which you understand the best and focus on those. Use headings and subheadings to help organize your comment if it addresses multiple parts.
Make sure to distinguish between facts and misinformation and where possible, provide citations or sources to bolster your credibility.
Your comments can be brief or in-depth and well researched; there’s a 5,000-character limit within the text box in the regulations.gov portal, but longer comments can be submitted through the portal as an attachment, or printed and mailed in.
Commenting in a personal capacity
Establish your credibility in an opening sentence that shares who you are and provides a quick summary of the experiences that are relevant to the rule.
Focus on 1-2 specific aspects of your personal or family story that inform your opinion and perspective. These may include your family’s immigration story, personal experience working to advance human rights, and whether you have experience accessing a benefit or assistance program the rule would affect. Tell the official you are writing to why this proposed rule would hurt or benefit someone like you and how it goes against or honors the values you hold dear.
Commenting in a professional capacity
Describe your organization and your work. Provide a quick summary of what your organization does, the community it serves, and your role. Highlight relevant data about your connections to the issue and why your opinion on this rule is essential. Make sure to highlight any particular expertise or credentials, for example, “I have taught Civics in public school for 20 years.”
Do you have personal reasons to oppose this proposal? Even if you’re submitting comments in your professional capacity, don’t forget to include your unique perspective!
Step 3: Submit your comment
All comments are available as a matter of public record. To submit comments online, you will be required to provide your first and last name, city, state, and country.
After submitting your comment, you will be provided with a tracking number to review your comments after the appropriate agency has reviewed and posted them.
Adapted from materials from Reguations.gov, the Center for Effective Government, the Public Comment Project, and the MIRA Coalition.