Best Practices

Create a mobile version of is only configured for desktops and laptops; the screen is not smartphone friendly. A mobile-friendly site would lower participation barriers for those that would use the site while communiting on buses and subways. Android and iPhone apps would also be helpful.


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  1. Comment

    I am a big fan of the concept of electronic rulemaking and have been one for more than a decade. I think many improvements need to be made to to encourage thoughtful citizen participation. This is not one I would rank highly at the moment.

    Commenting on federal regulations is not a spur of the moment activity. It requires analysis and thought. These are not activities I normally associate with mobile apps.

    In stating this reservation I would emphasize that I do not think spam commenting is a downside to online rulemaking. But, I do not think that a priority modification to needs to be a feature that would undoubtedly promote more spam submittals than thoughtful commentary.

    In this context I would recommend considering Professor Balla’s report to the ACUS rulemaking comments committee and the recommendations that the staff are drafting.

    Barbara Brandon

  2. Comment
    sterling.whitehead ( Idea Submitter )

    I respectfully disagree with your points bbrandon. Commenting on federal regulations with "analysis and thought" can easily take place in under 5 minutes. I see it in government-oriented online communities all the time such as GovLoop (which I access by smartphone). As an example, it took me under 2 minutes to create this counter argument.

    Spam commenting will not necessarily result from more mobile commenting. There is no evidence offered to sugges this. Rather, it is an unbacked claim.

    On GovLoop, dedicated public servants offer comments all the time -- many of them coming quickly from smartphones. I do it all the time. A spam comment will rarely slip through; but those are quickly deleted. The dedication of the community is the important part.

  3. Comment


    I again want to offer a respectful dissent. I have defended EPA regulations and challenged OSHA and EPA regulations in the federal courts. In both contexts I have read large parts of rulemaking records.

    The comments that form the crux of this litigation are detailed, thoughtful and often long. They are not short off-the-cuff exchanges like we are having here.

    In addition, I have authored comments on behalf of clients. This is a painstaking process that requires time to analyze the NPRM and its background materials. The first draft of a meaningful comment is far from the last version that is submitted.

    I believe that lots of public input during a rulemaking is desirable. I support the public submitting short undetailed comments in a rulemaking because I strongly support public participation. But, I don't think anything either of us said here rises to the level of a significant comment in a rulemaking. is a deeply flawed site and much needs to be done to improve it to make it more citizen- friendly and to encourage meaningful public participation. This remains very low on my list of reforms because it is not likely to lead to the type of commentary that will advance broader public participation in the rulemaking process.

    I would suggest that you look at Professor Balla's report to understand how the commenting process needs to be improved.


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