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TIPS FOR SUBMITTING EFFECTIVE COMMENTS*

Overview

A comment can express simple support or dissent for a regulatory action. However, a constructive, 

information-rich comment that clearly communicates and supports its claims is more likely to have an 

impact on regulatory decision making.

These tips are meant to help the public submit comments that have an impact and help agency policy 

makers improve federal regulations.

Summary

 Read and understand the regulatory document you are commenting on

 Feel free to reach out to the agency with questions

 Be concise but support your claims

 Base your justification on sound reasoning, scientific evidence, and/or how you will be 

impacted

 Address trade-offs and opposing views in your comment

 There is no minimum or maximum length for an effective comment

 The comment process is not a vote – one well supported comment is often more influential 

than a thousand form letters

Detailed Recommendations

1. Comment periods close at 11:59 ET on the date comments are due - begin work well 

before the deadline.

2. Attempt to fully understand each issue; if you have questions or do not understand a 

part of the regulatory document, you may ask for help from the agency contact listed in 

the document. 

Note: Although the agency contact can answer your questions about the document’s meaning, official comments 

must be submitted through the comment form.

3. Clearly identify the issues within the regulatory action on which you are commenting. If 

you are commenting on a particular word, phrase or sentence, provide the page 

number, column, and paragraph citation from the federal register document.

a. If you chose to comment on the comments of others, identify such comments 

using their comment ID’s before you respond to them.
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4. If a rule raises many issues, do not feel obligated to comment on every one – select 

those issues that concern you the most, affect you the most, and/or you understand the 

best.

5. Agencies often ask specific questions or raise issues in rulemaking proposals on 

subjects where they are actively looking for more information. While they will still accept 

comments on any part of the proposed regulation, please keep these questions and 

issues in mind while formulating your comment.

6. Although agencies receive and appreciate all comments, constructive comments (either 

positive or negative) are the most likely to have an influence.

7. If you disagree with a proposed action, suggest an alternative (including not regulating 

at all) and include an explanation and/or analysis of how the alternative might meet the 

same objective or be more effective.

8. The comment process is not a vote. The government is attempting to formulate the best 

policy, so when crafting a comment it is important that you adequately explain the 

reasoning behind your position.

9. Identify credentials and experience that may distinguish your comments from others. If 

you are commenting in an area in which you have relevant personal or professional 

experience (i.e., scientist, attorney, fisherman, businessman, etc.) say so.

10.Agency reviewers look for sound science and reasoning in the comments they receive. 

When possible, support your comment with substantive data, facts, and/or expert 

opinions. You may also provide personal experience in your comment, as may be 

appropriate. By supporting your arguments well you are more likely to influence the 

agency decision making. 

11.Consider including examples of how the proposed rule would impact you negatively or 

positively. 

12.Comments on the economic effects of rules that include quantitative and qualitative data 

are especially helpful.

13.Include the pros and cons and trade-offs of your position and explain them. Consider 

other points of view, and respond to them with facts and sound reasoning.

14.Keep a copy of your comment in a separate file – this practice helps ensure that you will 

not lose your comment if you have a problem submitting it using the Regulations.gov 

web form.
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Form Letters

Organizations often encourage their members to submit form letters designed to address issues 

common to their membership. Organizations including industry associations, labor unions, and 

conservation groups sometimes use form letters to voice their opposition or support of a proposed 

rule. Many in the public mistakenly believe that their submitted form letter constitutes a “vote” 

regarding the issues concerning them. Although public support or opposition may help guide 

important public policies, agencies make determinations for a proposed action based on sound 

reasoning and scientific evidence, not a majority of votes. A single, well-supported comment may 

carry more weight than a thousand form letters. 

* Throughout this document, the term “Comment” is used in place of the more technically accurate term “Public Submission” in order to 

make the recommendations easier to read and understand.

Disclaimer: This document is intended to serve as a guide; it is not intended and should not be considered as legal advice. Please 

seek counsel from a lawyer if you have legal questions or concerns.