At both the state and federal levels of government, rules that are freshly drafted and released must be available for comment. Generally, agencies welcome feedback on drafted rules. It is best to sit down with attorneys who have working knowledge of the rulemaking process and have them work with you to first analyze precisely how the rule will impact your business or organization. They can then help you draft the most persuasive sets of comments on the proposed rules.
The Kegler Brown team has a strong track record of providing comments on an array of state and federal rules that were factored into final versions of rules and sometimes help result in rules being withdrawn by regulators.