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02 Agency rulemaking

Your 40,000-comment campaign got one sentence in the preamble. The technical brief is in a different bucket.

54% of comments on federal rules did not match any dimension of the final rule change. Agencies weight sophisticated, individually-authored comments disproportionately — and bucket identical-language submissions as one.

GW Regulatory Studies Center, Are Agencies Responsive to Mass Comment Campaigns? · ACUS, Managing Mass, Computer-Generated, and Falsely Attributed Comments · regulations.gov v4

What appears on the public docket

regulations.gov · EPA-HQ-OAR-2025-0147
Public Submissions 40,214 received
  • Mass Comment Campaign — Group 1 SAMPLED +40,128 more · one representative posted
  • Comment by Environmental Defense Fund 312-page technical · posted individually
  • Comment by American Petroleum Institute 184-page technical · posted individually
  • Comment by State AG Coalition (17 states) joint filing · posted individually
  • Comment by J. Rivera (independent) 8-page individually-authored · posted individually
Mass-comment bucket collapses to one row. Individually-authored comments each get their own.

The docket officer's triage rule is the bucket. Your 40,000 signers are a count. The analytic lane is the individual-comment lane, and your submission never reaches it.

What the docket officer receives from Commons

Example packet · EPA-HQ-OAR-2025-0147 · Mar 2026

EPA-HQ-OAR-2025-0147 · Methane Rule Packet
Docket EPA-HQ-OAR-2025-0147
Rulemaking Oil & gas methane emissions · subpart OOOOb
Agency EPA, Office of Air and Radiation
Comment period Jan 15 – Mar 30, 2026
3,428 verified commenters
individually authored
Identity 2,891 gov ID · 537 address-matched
Authorship 2,612 individually composed · 816 shared templates (disclosed)
Proximate impact 2,104 in affected counties · 89 counties
Rule citations 1,844 reference specific rule sections
Geography 47 states · 312 counties
Screening One submission per person · duplicates removed
Cryptographic audit trail · independently verifiable

How each field answers the docket officer's triage question

Identity
answers the triage question:
“Is this an identified person or an auto-generated submission?”
ACUS, Managing Mass, Computer-Generated, and Falsely Attributed Comments (2021) · identity closes the triage question: is this a real, identified person or an auto-generated submission?
Authorship
answers:
“Is the body identical to 40,000 others, or individually composed?”
regulations.gov v4 · identical-language submissions collapse to a single “mass comment campaign” row with a sampled representative
Proximate impact
answers:
“Does this person live near the regulated activity?”
EPA public comments guidance, epa.gov/dockets · proximate-impact evidence differentiates a submission from the mass-comment bucket; agencies treat identical-language submissions as signals of political opinion, not technical input
Rule citations
answers:
“Does this comment engage the actual rule text?”
GW Regulatory Studies Center · technical-economic comments weighted disproportionately; generic support rarely moves a final rule
Screening
answers:
“Is this astroturf or falsely-attributed?”
Walker & Le, Socius 2023 · unverified submissions erode trust in legitimate advocacy orgs

Your existing comment tool sprays identical body language through a regulations.gov relay and lands in the mass-comment bucket. Commons delivers comments the docket officer reads individually — each verified, each proximate to the regulated activity, each citing the rule provision it addresses.

GW Regulatory Studies Center: 54% of comments did not match on any dimension of final rule change · regulations.gov v4 · ACUS 2021 recommendations on mass-comment triage

Individually-authored, identity-verified comments enter the rulemaking record as individual comments. Mass-comment campaigns enter the bucket.

Federal and state rulemaking dockets we cover

  • EPA-HQ-OAR (Air)
  • EPA-HQ-OW (Water)
  • FDA food labeling
  • HUD fair housing
  • DOE efficiency standards
  • DOL wage & hour
  • OSHA standards
  • CFPB rulemakings
  • California PUC
  • Oregon PUC (UM)
  • Hawaii PUC
  • Pennsylvania PUC

~300 federal agencies and sub-agencies on regulations.gov. 4M+ comments on high-profile dockets. Commons submits through the regulations.gov v4 API across federal rulemaking dockets; state PUCs onboarded selectively.

Plus state PUC / BOE / state-EPA dockets in OR, HI, CO, CA, PA — expanding. EPA's 2025 endangerment-finding reconsideration received 534,000 comments across 169 mass-comment campaigns; acknowledged but not individually addressed in the preamble.

regulations.gov v4 · U.S. Federal Register · Environmental Data & Governance Initiative (EDGI) docket workflow analysis

Mass comment campaigns don't move rules. Named commenters with substantive content do.

The platform-generated bulk comment — Quorum Grassroots, EngagingNetworks regulations.gov extensions, Phone2Action pipelines — produces volume that the docket officer collapses on ingestion. The workflow already exists to weigh individually-authored, technically-specific comments; the gap is producing enough of them to matter. That is the work Commons does.

GW Regulatory Studies Center (Lens 2) · ACUS 2021 · Walker & Le, Socius 2023 · regulations.gov v4 API documentation

The incumbent advocacy stack has changed hands four times this cycle. Docket officers have triaged the same form comment 50,000 times. Orgs are shopping.

Not $15/mo per seat.
Not $40,000/yr with a year-long implementation.
$0. 100 verified actions · 2 seats · no time limit

Starter tier published · enterprise by quote · Apr 2026

One verified action = one commenter, identity-proven, proximate-impact mapped, authored for you. Metered at submission, not at send.

Free $0 100 verified actions · 1,000 emails · 2 seats
Starter $10/mo 1,000 verified actions · 20,000 emails · 5 seats
Organization $75/mo 5,000 verified actions · 100,000 emails · 10 seats
Coalition $200/mo 10,000 verified actions · 250,000 emails · 25 seats

No demo required. No procurement review. Import your list from Action Network, EveryAction, NationBuilder, or any CSV export — a packet produced before the comment period closes, not a year from now.