By Nick Blake Last week, we learned that the Trump administration suddenly ended support for accepting public comments on proposed regulatory changes via the federal government’s API.
This abrupt change cuts off one of the most popular mechanisms for Americans to make their voices heard. It skirts the federal government’s responsibility to solicit and evaluate input from the public before finalizing regulatory decisions that impact us all.
Users of EveryAction, just one technology platform used to deliver public comments via this API, are being met with the following message inside their system:
One of the advocacy organizations we work with said it best:
“Our members submit tens of thousands of public comments each year. The public API ensures that the federal government hears their voice and that its actions are accountable to them. Shutting it down is a blatant attempt by the Trump administration to silence us and weaken our ability to mobilize.”
Why is this happening?
Officially, the Trump administration has not provided an explanation for this decision.
However, Trump and his cabinet have repeatedly ignored due process requirements and lashed out when the courts have forced them back into compliance. Secondly, Trump has tasked the so-called “Department of Government Efficiency” or “DOGE” with reviewing “all regulations … for consistency with law and Administration policy,” promising a massive campaign of deregulation and right-wing policy shifts that should be subject to public input.
Public comment periods are one of the few ways for the public to have an impact on executive branch policymaking. Unlike Congress, executive branch agencies often have broad leeway to interpret and enforce the law as they see fit. By law, many of these executive branch decisions must consider input from the public and affected interest groups before making significant changes. When the federal government falls short of that duty, its decisions can be challenged in the courts.
Frankly, it’s hard to interpret this decision as anything other than an attempt to further silence dissent of the Trump administration’s policies. If we had to speculate, the administration is hoping to reduce dissenting comments in hopes that the courts will not require them to consider input they don’t receive. (If you’ve ever turned your phone off to avoid a tough conversation, you’ll be familiar with the strategy.)
What should advocacy organizations do now?
It remains the law of the land that the Trump administration must continue to solicit and weigh public comments before issuing regulatory decisions. They’re trying to play cute with the rules — that means advocacy organizations seeking to influence the federal government’s decisions will need to get creative, too.
We’ve talked to experts from across the advocacy, nonprofit technology, and open government communities. Based on those conversations and our own strategizing at M+R, here are a few recommendations for how advocacy organizations can continue to engage with public comment periods in spite of this setback:
Back to basics
Regulations.gov, the federal government’s website that powered its public API, remains online. That means you can continue to direct supporters to relevant public comment periods to make their voices heard. (For instance: if you disagree with the Trump administration’s move to rescind the EPA’s duty to limit greenhouse gas emissions under the Clean Air Act, you can let them know here.)
The challenge with this approach is that it asks a lot of supporters. Compared to simple and easy-to-use advocacy forms powered by the now-defunct API, organizations should expect fewer supporters to take action. Tracking which and how many of your supporters take action will also be much more difficult as these actions won’t write back to your advocacy database.
One option you might consider is collecting supporters’ comments and submitting them in bulk via the Regulations.gov site. Officially, many agencies will consider this as “one comment,” but this solution could allow you to continue collecting petition signatures at scale, avoiding the dropoff in conversions we’d otherwise expect when directing supporters to the site one-by-one.
Go analog
The federal government’s duty to collect public comments predates popular use of the internet. That means that many government agencies still accept offline comments, or even comments via email. Here are all the official submission options for the EPA ruling we referenced above, straight from agency:
- Federal eRulemaking Portal: https://www.regulations.gov/ (our preferred method). Follow the online instructions for submitting comments.
- Email: a-and-r-Docket@epa.gov. Include Docket ID No. EPA-HQ-OAR-2025-0194 in the subject line of the message.
- Mail: U.S. Environmental Protection Agency, EPA Docket Center, OAR Docket, Mail Code 28221T, 1200 Pennsylvania Avenue NW, Washington, DC 20460.
- Hand Delivery or Courier: EPA Docket Center, WJC West Building, Room 3334, 1301 Constitution Avenue NW, Washington, DC 20004. The Docket Center’s hours of operations are 8:30 a.m.-4:30 p.m., Monday-Friday (except Federal Holidays).
We know: many of these alternatives are a pain. They take more time, effort, and budget to collect and submit at scale, especially compared to the public API.
But if it’s any consolation, what’s a pain for your organization is also a pain for the Trump administration. Federal agencies ultimately won’t want to collect, scan, and catalog thousands of paper comments any more than you’ll want to produce them. If your goal is to make yourself impossible to ignore, this might be the way to go. And who knows, maybe the administration will find a newfound love for the public API if its alternatives prove more burdensome?
Keep an eye out for new tech solutions
Organizing and advocacy have always relied on finding ways to overcome barriers and speak truth to power — especially when power doesn’t want to listen. Innovation in the advocacy space won’t stop just because the Trump administration flips a switch to silence dissent. Many of the technologists we’ve spoken to are already cooking up solutions to help you and your advocates make their voices heard.
We won’t go into too much detail here, lest those solutions become the administration’s next target, but let’s keep in touch!