Proposal for ACUS Project on Petitions for Rulemaking
Policy Integrity submitted a proposal to the Administrative Conference of the United States (ACUS) for the development of recommendations on citizens’ petitions for rulemaking.
Petitions for rulemaking, when used effectively, can improve the implementation of public policy and the government’s responsiveness to its citizens. Recent academic literature finds problems with the petition process and suggests potential reforms. The public’s involvement in the process is rapidly increasing through the help of innovative government platforms. The issue is vital as the right to petition federal agencies is backed by the Constitution, as well as federal law.
Policy Integrity proposes that ACUS study the use of petitions, their potential to improve the government’s responsiveness to citizens’ concerns, and best practices for facilitating submission and guiding agency responses.
We suggest that the following topics be studied: legal background and literature review; empirical analysis; case studies and interviews; stakeholder viewpoints; and potential reforms.
We previously submitted comments to ACUS suggesting ways to improve its draft statement on the broader regulatory review process by the Office of Information and Regulatory Affairs. We’ve also addressed the role of citizens in rulemaking in our comments to government agencies by requesting improved facilitation of the public’s involvement in the rulemaking process.