GSA Must Reinstate the POST API Feature on Regulations.gov

September 12, 2025 | Download PDF

Acting Administrator Michael Rigas
U.S. General Services Administration
1800 F St. NW
Washington, DC 20024

Director Russell Vought
U.S. Office of Management and Budget
725 17th St. NW
Washington, DC 20503

Dear Acting Administrator Rigas and Director Vought,

We, the undersigned groups and individuals, are writing in response to the General Service Administration’s (GSA) dismantling of the POST Application Programming Interface (API) feature on Regulations.gov on August 8, 2025. Many of us have relied on the POST API feature to ensure that consumers, workers, and all individuals from across the United States are able to effectively participate in the federal regulatory process and have their voices heard. We are deeply concerned that the removal of this capability substantially stymies the ability of interested individuals to communicate with agencies about specific rules, an essential aspect of democratic participation in the regulatory process. We urge the immediate reversal of this decision and reinstatement of the POST API feature.

Public participation is the cornerstone of a fair, open, and inclusive regulatory process. This is why Congress made public participation a central feature of the Administrative Procedure Act (APA), the bedrock law governing the process that federal agencies must follow when issuing new regulations. Under the APA, federal agencies must typically allow an opportunity for the public to submit comments prior to issuing regulatory actions. Further, federal agencies must also consider and respond to those comments when finalizing a regulatory action.

Congress reaffirmed the importance of public access to government information and participation in rulemaking when it enacted the E-Government Act of 2002 to support agencies in making information available online. In accordance with the Act, GSA, in its current role managing the eRulemaking Program, launched the POST API tool to facilitate uploads of comments to Regulations.gov to improve the public’s ability to participate in the rulemaking process.

The POST API feature enhanced public engagement by enabling entities to solicit public comments through a website or email and submit those comments to the relevant agency, without the individual commenter needing to go directly to Regulations.gov. Yet, without explanation, GSA has now reversed course and disabled this public engagement tool.

By preventing the public from submitting comments through the POST API tool, GSA is fundamentally undermining congressional intent to provide the public a right to comment on regulations before they take effect. While regulated entities typically participate in the regulatory process on a regular basis and are familiar with the comment process, this is not true for most individual members of the public. Rather, the vast majority of people are unlikely to be aware of Regulations.gov, regularly check the Federal Register to identify regulatory actions that will impact them, or have the time and resources to draft and upload comments directly to Regulations.gov.

Given this reality, comments submitted using the POST API feature play an essential role in bridging the gap to allow individuals to participate meaningfully in the regulatory process by giving them the chance to weigh in with their views. In addition, if the POST API tool is permanently dismantled, federal agencies will be deprived of basic and critical information from the public on how regulatory actions will benefit or harm individuals, their families, their livelihoods, and their communities.

Ultimately, the legitimacy of the regulatory process depends on robust participation from the public, particularly individuals and not just regulated entities. If GSA continues to block participation in the regulatory process by disabling comments submissions through the POST API tool, it will deeply damage the process’s integrity.

We, the undersigned groups, demand that GSA immediately restore the POST API feature on Regulations.gov to allow the public to once again submit comments on pending regulatory actions via the entities that share their viewpoints. Further, we demand that the Office of Management and Budget (OMB) direct all agencies to extend any public comment periods that were impacted by the removal of access to the POST API tool.

Thank you for your consideration.

Sincerely,

350.org
Accountable.US/Accountable.NOW
AdvocacyAI
Advocates for Trans Equality
Allegheny County Clean Air Now
Alliance for Democracy
Alliance of Nurses for Healthy Environments
American Atheists
American Civil Liberties Union
American Federation of State, County & Municipal Employees
American Governance Institute
Americans United for Separation of Church and State
Attorneys for Animals
Autistic Women & Nonbinary Network
Beaver County Marcellus Awareness Community (BCMAC)
Better Path Coalition
Black Hills Preservation Project
Breathe Project
CAARMA
Carnivore Coexistence Lab
Center for Oil & Gas Organizing
Center for Progressive Reform
Center for Reproductive Rights
Center for Science in the Public Interest (CSPI)
CenterLink
Change the Chamber
Civic Shout
Clean Air Council
Clean Elections Texas
Clean Water Action
Climate Reality Project: Susquehanna Valley PA Chapter
Coalition for Sensible Safeguards
Coalition on Human Needs
Conservation Congress
Consumer Action
Consumer Federation of America
Consumers for Auto Reliability and Safety
Data Rescue Project
Demand Progress Education Fund
Earthworks
EDF Action
Electronic Privacy Information Center (EPIC)
Energy Alabama
Environmental Policy Innovation Center
Equitable Health Solutions, LLC
Evergreen Action
Fight for the Future
Food & Water Watch
FOUR PAWS USA
FracTracker Alliance
Free Government Information (FGI)
Friends of Buckingham
Gallatin Wildlife Association
Government Information Watch
GreenFaith
Greenpeace USA
Guardians of the Wolves
Human Rights Campaign
Ibis Reproductive Health
Impact Fund
International Marine Mammal Project of Earth Island Institute
Izaak Walton League, Rapid City, South Dakota Chapter
Kettle Range Conservation Group
League of United Latin American Citizens (LULAC)
Lobos of the Southwest
Maryland United for Peace and Justice
MassCOSH
National Consumer Law Center (on behalf of its low-income clients)
National Employment Law Project
National Health Law Program
National Women’s Law Center
Natural Resources Defense Council
New Jersey Third Act
Next 100 Coalition
No False Climate Solutions PA
Oceana
Ohio State Chair, National Association of Consumer Advocates
Open Environmental Data Project
Oregon Consumer League
People Power United
Physicians for Social Responsibility Pennsylvania
Plan B to Save Wolves
Planned Parenthood Federation of America
Plastic Pollution Coalition
Prairie Hills Audubon Society (of Western South Dakota)
Preserve Montgomery County VA
Proposition One Committee
Protect Our Water, Heritage, Rights
Protect PT
Public Citizen
Resource Renewal Institute
RootsAction
SafeWork Washington
Save our Susquehanna
Secure Elections Network
Shriver Center on Poverty Law
Silvix Resources
Southern Environmental Law Center
Stand.earth
TeamEXtension
The Cougar Fund
The International Wildlife Coexistence Network
The Last Plastic Straw
The PEGI Project: Preservation of Electronic Government Information
The Value Alliance
The Wilderness Society
Third Act Union
Turtle Island Restoration Network
UAW
UltraViolet Action
Union of Concerned Scientists
United Church of Christ Media Justice Ministry
Valparaiso Resistance
Western Watersheds Project
Wilderness Watch
Wildlife for All
William E. Morris Institute for Justice
WisCOSH, Inc
Women’s International League for Peace & Freedom US
Worksafe
Wyoming Wildlife Advocates
Xerces Society for Invertebrate Conservation
Yaak Valley Forest Council

Individuals:

Alice Freund
Bernie Gerard
Christine Morales
Claudia Farber
Daniel Brister
Elise Pechter
Kathleen Krebs
Lisa Naughton
Ryan Treves
Alejandro Camacho, Chancellor’s Professor of Law, University of California Irvine, School of Law (Institution for identification only)
Joshua I. Schwartz, Prof. Emeritus, George Washington University Law School (Institution for identification only)
Laura Punnett, Sc.D., Professor Emerita & Distinguished University Professor (2013-16), University of Massachusetts Lowell (Institution for identification only)
Samuel Estreicher, Dwight D. Opperman Professor of Public Law & Director, Institute of Judicial Administration, NYU School of Law (institution for identification only)
Susan Rose-Ackerman, Yale University Law School (institution for identification only)