After the Comment

You submitted the comment. Now what?

Filing a comment on a proposed federal rule is only the beginning.

What happens after the comment period closes? How do you find out what the agency did with your concerns? What can you do when a final rule changes the landscape? When can you ask an agency to reconsider, amend, delay, or repeal a rule? And when does a rule become something you may need to challenge in court?

After the Comment is a practical, plain-English guide to what comes next.

Building on How to Comment on Federal Rules, Jarrett Paul Dudley takes readers beyond the comment period and through the next stages of federal rulemaking. You'll learn how to:

• Track a rule from proposal through final publication.
• Read the final rule and understand how an agency responded to public comments.
• Find the deadline that governs a potential challenge-and understand why different statutes can create different deadlines.
• Petition an agency for reconsideration, amendment, delay, or repeal.
• Use the Congressional Review Act and understand how Congress can review and disapprove certain rules.
• Understand standing, finality, venue, and judicial review when a final rule may need to be challenged.
• Recognize common legal arguments, including arbitrary-and-capricious review, logical outgrowth, major questions, and other administrative-law issues.
• Use FOIA, OIRA, congressional oversight, and coalition-building to continue the work after publication.
• Build a practical tracking and deadline system so important developments do not disappear into the Federal Register.

The book includes a step-by-step playbook, deadline map, petition template, rule-tracking worksheet, and deadline worksheet.

You do not need to be a lawyer to understand the process. But if your situation reaches the point where litigation may be necessary, this book helps you recognize when it is time to bring in counsel.

From the first comment to the final word, After the Comment shows you what happens after you speak up.

General information only. Administrative law, agency procedures, and litigation deadlines can change. Readers should confirm current requirements and deadlines with the applicable agency, statute, and qualified counsel.