Various factors can affect the impact that your comment will make. This guide outlines helpful tips to improve the relevance, readability, and ultimate effectiveness of your comments, and also contains links to other resources for writing public comments. While many of these recommendations make reference to or are geared towards those commenting on environmental rulemaking, they should be of help to anyone dedicated to writing effective public comments.
How to cite this guide:
Gehrke, G., & Paz, A. (2024). How to Write Effective Public Comments. Environmental Data and Governance Initiative. https://envirodatagov.org/how-to-write-effective-public-comments
Our Recommendations
- Decide whether submitting a public comment is right for your needs.
- There are many ways of influencing agency actions and engaging in participatory democracy. Agencies hold public meetings, request information on certain topics, react to pressure from U.S. legislators, and seek comment on guidelines and plans.
- See Beyond Public Comments: Other Ways to Engage With and Influence Federal Agencies for more information on how to decide what public input options best fit your situation.
- Provide specific arguments. Broad comments that address the general concept but do not speak to the specifics of the proposed rule or provide a rationale and evidence for their arguments will receive little consideration.
- Focus on providing original arguments or data, including a technical and/or legal rationale, which the agency has not considered.
- Your arguments should be specifically related to the proposed rule. Information included in a comment that is not directly relevant (e.g. writing about labor issues in intensive animal farming in a comment about effluent standards) might be ignored or not read by relevant agency staff.
- Where possible, include data and analyses that support your arguments.
- You may want to review the data analyses that are referred to in the proposed rule as well, such as in a ‘Regulatory Impacts Analysis’ or an ‘Integrated Science Assessment’. Doing so will help you verify your data and arguments are valid, relevant, and original. See Research Recommendations for Writing Informed Public Comments for more on finding this information.
- Ensure your comment is clear and easy to read: The EPA, for example, has to respond to so many comments it frequently uses contractors and specialized software to sort and review them. Contractors that read and sort comments will not be subject matter experts, so it is quite possible that subtlety or nuance that is not clearly articulated will be lost.
- Clearly identify the section(s) of the rule your comment is addressing.
- Make the section you are addressing clear at every point in your comment.
- Use the labels and linking features in the Federal Register to reference sections for additional clarity.
- You may also simply type in section numbers from the proposed rule or paste in questions that the agency has asked in its proposed rule front matter.
- Include references in your comments.
- Agencies are looking for data they have not considered.
- Format your references correctly so staff reading your comment can find your sources easily.
- If your comment references data that is not easily accessible online, either make this data available through a publicly accessible website you reference, or attach your data files in an accessible format.
- Make your comment stand out. Many organizations run mass letter campaigns that include the names of various signees or share templates for comments for members to copy and submit on their own. Agencies oftentimes count comments from these campaigns as a single comment for consideration and response. Mass comments can still be effective means of galvanizing public awareness and involvement in an issue, but they rarely influence the specific rule up for comment.
- Contact the agency staff member listed in the proposed rule document or the Unified Agenda if you are having trouble understanding the proposed rule. They can answer questions you may have about the rule.
Additional Resources
- Writing Effective Comments | Public Comments Project
- This includes guidance on structuring documents for public comments. It also has several templates you can use to build your comments.
- Submitting Public Comments | The Environmental Justice Green Book
- This extensive guide provides an overview of the notice and comment process, elements of an effective public comment, and types of commenting opportunities available to the public. It also includes guidance doing background research for a public comment and community organizing. Some of the information is geared toward matters affecting the state of Georgia and its government.
- How to Make an Effective Public Comment | Natural Resources Defense Council
- This online resource provides tips for individuals making public comments. The guide mostly focuses on making comments at virtual public hearings, but it also covers written public comments.
- Engaging in Agency Rulemaking: How to Submit Effective Public Comments | Johns Hopkins
- This video gives an overview on and provides guidance about the notice and comment process in rulemaking. It provides tips, geared towards public health professionals, on writing and submitting public comments.
- A Citizen’s Guide To The Federal Regulatory Process | Environmental Protection Network
- This guide was authored by former EPA staff and reviewed by experts from the Union of Concerned Scientists. It goes over the background regulatory processes relevant to commenting opportunities and other ways for interested members of the public to get involved.
- Commenting on EPA Dockets | US EPA
- This webpage contains tips on writing effective public comments for EPA proposed rules and actions. It also lists EPA-specific rules and restrictions about submitted comments.
- Regulations.gov | Tips for Submitting Effective Comments
- This document can be found on Regulations.gov, which is also a government platform for locating regulatory dockets, submitting comments, and accessing other submitted comments.
See something that needs changing or want to contribute to this work?
If you have feedback, comments, or would like to get involved, please contact Gretchen Gehrke at gretchen.gehrke@envirodatagov.org.