public-comment

Public Comment Skill

Agencies must review and respond to substantive comments — but only substantive ones move the needle. A

comment that cites the specific provision, brings evidence, and proposes concrete alternative language carries

far more weight than "I support/oppose this." This skill drafts that substantive comment.

Required Inputs

Ask for these only if they aren't already provided:

• The proposal — the rule/regulation/plan, ideally the specific sections or docket number.
• Your position & interest — support, oppose, or amend; and who you are (individual, business, org — it affects standing/weight).
• The substance — your reasons, and any data, expertise, or real-world impact you can cite.
• Desired outcome — the specific change you want (kill it, delay it, amend a provision).

Output Format

Public comment: [rule / docket]

Re / docket line — the proposal and docket/reference number, and your position in one line.

Who I am & my interest — brief; establishes standing and why your input is relevant.

Summary of position — what you support/oppose/want changed, up front.

Substantive comments — the core. Each point:

• Cites the specific provision (section/paragraph) it addresses,
• Makes the argument with evidence (data, expertise, precedent, real-world consequence),
• Proposes a concrete fix — suggested alternative language or a specific change, not just objection.

Number them so the agency can respond point by point.

Impact — the concrete effect (cost, burden, benefit, unintended consequence) on you/your community — this is what agencies weigh.

Conclusion & request — restate the specific action requested; offer to provide more info.

Quality Checks

• [ ] Each point cites the specific provision it addresses and is on-topic for the proposal
• [ ] Arguments are backed by evidence (data, expertise, precedent, concrete impact) — not just opinion
• [ ] It proposes concrete alternative language/changes, not only objections
• [ ] The real-world impact is made specific
• [ ] Position and the exact requested action are stated clearly up front and at the end

Anti-Patterns

• [ ] Do not submit a bare "I support/oppose" — agencies weigh substance, not vote counts
• [ ] Do not argue in generalities — tie every point to the proposal's actual text
• [ ] Do not just object — propose the specific alternative you want instead
• [ ] Do not omit evidence — unsupported assertions are easy to dismiss on the record
• [ ] Do not go off-topic — comments outside the proposal's scope carry no weight

Based On

Notice-and-comment rulemaking practice (substantive, provision-specific, evidence-based comments with proposed alternatives).