Mass, Computer-Generated, and Fraudulent Comments

This project seeks to identify agency best practices for handling mass, computer-generated, and fraudulent comments in rulemakings. Treating each type of comment separately, it examines both the legal and practical issues associated with processing and responding to such comments. It also considers whether there are certain types of rulemaking proceedings where such comments are especially likely to pose particular problems; what remedies are available to agencies in handling such comments; and how agencies might promote transparency, integrity, and consistency in their procedures for addressing such comments.

Contacts

Committee Chair
Cary Coglianese
Edward B. Shils Professor of Law
University of Pennsylvania Law School
Staff Counsel
202.480.2092
dschulkin@acus.gov
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Committee: 

Project Documents

Name Committee Type Date
Comment from 84 Advocacy Organizations and Individuals Rulemaking Public Comment May 11, 2021 Download
Comment from alternate Government Member William Piervincenzi (05-21-2021) Rulemaking Member Comment May 21, 2021 Download
Comment from Democracy Forward Rulemaking Public Comment May 24, 2021 Download
Comment from Free Press (05-21-2021) Rulemaking Public Comment May 21, 2021 Download
Comment from Friends of the Earth (05-21-2021) Rulemaking Public Comment May 21, 2021 Download
Comment from Government Member Helen Serassio with Noelle Green (05-27-2021) Rulemaking Member Comment May 27, 2021 Download
Comment from Government Member Robert F. Stone (05-18-2021) Rulemaking Member Comment May 18, 2021 Download
Comment from Liaison Representative Rebecca Orban (05-10-2021) Rulemaking Member Comment May 10, 2021 Download
Comment from Public Member Jack M. Beermann Rulemaking Member Comment June 13, 2021 Download
Comment from Senior Fellow Lon B. Smith (05-17-2021) Rulemaking Member Comment May 17, 2021 Download
Comment from Senior Fellow Nina A. Mendelson (04-28-2021) Rulemaking Member Comment April 28, 2021 Download
Comment from Senior Fellow Nina A. Mendelson (05-09-2021) Rulemaking Member Comment May 9, 2021 Download
Comment from Senior Fellow Nina A. Mendelson (05-21-2021) Rulemaking Member Comment May 21, 2021 Download
Comment from Senior Fellow Randolph J. May (04-19-2021) Rulemaking Member Comment April 19, 2021 Download
Comment from Senior Fellow Richard J. Pierce, Jr. Rulemaking Member Comment April 17, 2021 Download
Comment from Senior Fellow Richard J. Pierce, Jr. Rulemaking Member Comment April 3, 2021 Download
Comment from Senior Fellow Richard J. Pierce, Jr. (04-21-2021) Rulemaking Member Comment April 21, 2021 Download
Comment from Senior Fellow Richard J. Pierce, Jr. (04-28-2021) Rulemaking Member Comment April 28, 2021 Download
Comment from Senior Fellow Richard J. Pierce, Jr. (05-10-2021) Rulemaking Member Comment May 10, 2021 Download
Comment from Senior Fellow Richard J. Pierce, Jr. (05-22-2021) Rulemaking Member Comment May 22, 2021 Download
Comment from Senior Fellow Richard J. Pierce, Jr. (05-25-2021) Rulemaking Member Comment May 25, 2021 Download
Comment from Special Counsel Andrew Emery (04-28-2021) Rulemaking Member Comment April 28, 2021 Download
Committee Meeting Agenda - April 16, 2021 Rulemaking Agenda April 15, 2021 Download
Committee Meeting Agenda - April 29, 2021 Rulemaking Agenda April 28, 2021 Download
Committee Meeting Agenda - May 11, 2021 Rulemaking Agenda May 11, 2021 Download
Committee Meeting Agenda - May 24, 2021 Rulemaking Agenda May 23, 2021 Download
Draft Recommendation - Mass, Computer-Generated, and Fraudulent Comments Rulemaking Recommendation May 12, 2021 Download
Draft Recommendation - Mass, Computer-Generated, and Fraudulent Comments Rulemaking Recommendation April 27, 2021 Download
Draft Recommendation - Mass, Computer-Generated, and Fraudulent Comments Rulemaking Recommendation May 7, 2021 Download
Draft Recommendation - Mass, Computer-Generated, and Fraudulent Comments Rulemaking Recommendation April 13, 2021 Download
Final Report on Mass, Computer-Generated, and Fraudulent Comments Rulemaking Report June 1, 2021 Download
GSA Commenter's Checklist Rulemaking Member Comment May 24, 2021 Download
Mass, Computer-Generated, and Fraudulent Comments (Draft Report 4.2.21) Rulemaking Report April 2, 2021 Download
Mass, Computer-Generated, and Fraudulent Comments RFP RFP April 29, 2020 Download
Proposed Recommendation for Plenary - Managing Mass, Computer-Generated, and Malattributed Comments Rulemaking Recommendation June 2, 2021 Download
Recommendation from Committee on Rulemaking - Managing Mass, Computer-Generated, and Malattributed Comments Rulemaking Recommendation May 24, 2021 Download

Committee Meetings & Events