Templates Administrative Law Agency Rulemaking Petition (APA §553(e))
Agency Rulemaking Petition (APA §553(e))
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PETITION FOR RULEMAKING

To: [AGENCY NAME AND ADDRESS / E-FILING PORTAL]

Petitioners

[NAME/ENTITY], [CONTACT INFORMATION]

Relief Requested

Petitioners request that [AGENCY] initiate rulemaking to [ADOPT/AMEND/REPEAL] [CITATION OR SUBJECT], by issuing the proposed regulatory text below, or substantially similar language.

Proposed Regulatory Text (draft)

text
[INSERT PROPOSED RULE LANGUAGE OR REDLINE]

Summary of Basis and Purpose

  • Problem: [Describe current issue, harm, or gap].
  • Authority: APA §553(e); [Agency organic statute citations].
  • Solution: [Brief statement of how proposed rule addresses problem].
  • Benefits: [Public interest benefits, safety, compliance clarity, cost savings].

Supporting Legal and Policy Grounds

1) Statutory authority: [Cite organic statute provisions authorizing rule].
2) Consistency with existing framework: [Explain alignment or necessary revisions].
3) Preemption/interaction: [If applicable].
4) Economic/operational impacts: [Summarize data; attach exhibits].
5) Public interest factors: [Health/safety/consumer protection/fairness].

Evidence and Exhibits

  • Exhibit 1: Factual data/technical studies.
  • Exhibit 2: Economic analysis (cost/benefit summary).
  • Exhibit 3: Stakeholder letters/support.
  • Exhibit 4: Comparative jurisdiction/agency approaches.
  • Exhibit 5: Draft rule text markup.

Petitioners’ Request

Petitioners respectfully request that [AGENCY]:
1) Acknowledge this petition and docket it under APA §553(e).
2) Initiate rulemaking consistent with the proposed language or convene a public process to consider it.
3) Provide written response per agency procedures.

Signature

Date: [DATE]
[NAME/TITLE]
[ORGANIZATION]
[ADDRESS / EMAIL / PHONE]

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