Column: When it comes to federal regulations, your 2¢ are priceless

January 27, 2020 3:04 pm
President Donald Trump

President Donald J. Trump talks to reporters on the South Lawn of the White House Wednesday, June 26, 2019, prior to boarding Marine One to begin his trip to Japan. | Official White House Photo by Joyce N. Boghosian via Flickr Public Domain

Over the last three years, President Donald Trump’s administration has proposed a spate of harmful administrative rules in furtherance of his cruel agenda. As he faces reelection in November, we can expect the hits to keep coming

Since these changes are being done administratively and without input or approval needed from Congress, the only real outlet for concerned residents and advocates to weigh in are the required public comment periods. Even though it may feel like an exercise in futility, here’s why it’s crucial to stay engaged and continue taking the time to comment on proposed changes to federal regulations:

We can minimize the harm bad rules do. Sometimes, agency decision-makers actually listen to the public’s concerns about their proposals and make positive changes.

We can establish a strong record. In a legal challenge, the court can block a rule if it’s shown that the agency failed to sufficiently address legitimate objections raised in public comments. Several recent rulings on Medicaid work requirements demonstrate the power of public comments to stop destructive administrative action.

We can delay the implementation of bad rules. Agency staff must read every comment submitted on a draft rule before issuing the final version. The more comments submitted, the longer it will take. This is especially important this year — if Trump is not reelected, a new administration with a more humane agenda can change course on bad rules initiated under his watch.

There’s strength in numbers. No one can possibly stay on top of and respond to all of the proposals our federal policymakers put on the table, but if each of us does whatever we can whenever we can, harmful rules are less likely to slip through the cracks without pushback.

Check out this guide to learn more about the federal regulatory process and how to submit public comments.

Additionally, advocate coalitions often mobilize quickly around significant proposed rules, making comment templates and online portals available so it’s easier for you to participate. Your comment must vary from any template you use by at least 30% in order to be counted as unique, so be sure to rephrase a few things in your own words and add any data or personal perspectives to illustrate how the draft rule would affect you, your family, and your community or state.

Also, stick to what you know. You don’t have to be a lawyer or a policy wonk to weigh in, and you don’t have to address every flaw of a particular rule. Focus on the points that are most important to you and on which you can speak knowledgeably. Expertise comes in many forms and all are valuable in educating our policymakers about the weight of their decisions.

Here are some sources of state and local data for use in your comments and other advocacy work:

If you’re all fired up about federal regulations now, there are a few really awful proposals floating around just begging for comments.

There are only a few days remaining until the Friday deadline to speak out against the Social Security Administration’s proposal to make it more difficult for people with disabilities to receive benefits. You can use this template and submission platform to enter your comment, and spread the word on social media with the hashtag #NoSocialSecurityCuts.

We also urge you to fight a draft rule to gut requirements that communities address housing discrimination and segregation. You can learn more about the proposed rule, find resources to assist you in crafting your comment, and submit it here.

Everyone deserves justice, health and economic security. We know that when we talk about the right of every person to have their basic needs met, we’re often preaching to the choir. But let’s make sure the choir keeps singing so loudly that they can hear us all the way down in Washington.

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Julie Cassidy
Julie Cassidy

Julie Cassidy is the Michigan League for Public Policy's senior policy analyst. Before that, she spent 14 years working as a legislative analyst for the nonpartisan Senate Fiscal Agency, where she specialized in health, energy and environmental issues.