Who Actually Comments on Federal Regulations? | Federal Regulatory Tracker

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Published March 2026 · Data snapshot: March 27, 2026

This analysis presents quantitative data from the Federal Register. No legal inferences or policy conclusions are drawn.

The Administrative Procedure Act requires agencies to give the public a chance to comment on proposed rules. In theory, anyone can participate. In practice, a tiny number of organizations show up again and again — and the industry that dominates the list isn't Wall Street, Big Pharma, or Big Oil.

It's aviation.

The Numbers

FRTracker identified 636,688 distinct organizations or individuals who submitted comments on 31,604 federal rulemakings. The distribution is radically uneven:

539,017 entities commented on a single rule and never came back. Only 581 organizations commented on more than 20 rules. The regulatory comment process isn't a town hall — it's a small club of repeat players, and one industry towers above the rest.

The Top 15 Most Active Commenters

Organizations ranked by number of distinct federal rulemakings commented on. Boeing and Delta variants consolidated across name spellings. Individuals and spam accounts excluded.

Seven of the top 15 are aviation companies, unions, or trade groups. The Air Line Pilots Association alone commented on 938 distinct rulemakings — more than 3.7 times the most active environmental group (Center for Biological Diversity, 251) and 6.5 times the U.S. Chamber of Commerce (145).

Why Aviation?

The answer is structural, not political. The FAA produces far more individual rules than most agencies — every airworthiness directive, every airspace redesignation, every equipment standard is its own rulemaking with its own comment period. Airlines, pilots, and manufacturers have to monitor and respond to each one. A single airline might face dozens of ADs per year affecting its fleet.

The result: aviation entities collectively commented on 2,067 distinct rulemakings in our dataset. Environmental organizations (8 major groups combined) commented on 619. Major industry lobbies (8 groups including the Chamber of Commerce, API, and NAM) commented on 586.

The Comment Distribution Is Extreme

The distribution of commenting activity follows a steep power law:

The top 26 organizations — less than 0.005% of all commenters — are the only entities that engage with federal rulemaking as a sustained, ongoing practice. Everyone else is a one-time participant. The regulatory comment process is formally open to all, but functionally shaped by a few hundred organizations that show up consistently.

Which Agencies Get the Most Organizational Comments?

HHS draws the most distinct commenters (121,885) despite having fewer rules than Transportation — because individual healthcare rules attract mass-comment campaigns. Transportation has the most rules with comments (7,914) because of the FAA's high-volume rulemaking output. The CFPB is notable: only 267 rules but 32,629 distinct commenters — the highest commenter-to-rule ratio of any agency, driven by consumer finance campaigns.

The Individual Super-Commenters

Several individual citizens also stand out. Christopher Lish commented on at least 208 distinct rulemakings under various name formats. Michael Ravnitzky commented on at least 144. These individuals participate at rates exceeding most major trade associations. The regulatory comment process has its regulars.

Methodology

Data snapshot: All numbers in this case study are fixed as of March 27, 2026 and are not dynamically updated. This ensures citability — the numbers you see are the numbers we verified. Each figure was independently queried against FRTracker's database and confirmed.

What "636,688 entities" means: This count includes organizations, individuals, and unresolved name strings extracted from regulations.gov comment metadata. It is not a count of unique legal entities — the same organization may appear under variant names (e.g., "Boeing Commercial Airplanes" and "The Boeing Company" are separate entries before manual consolidation). The total also includes individual citizens and some spam entries. Where we say "organizations" in the narrative, we mean the subset that are identifiable organizations.

Consolidation: Boeing variants ("Boeing Commercial Airplanes," "Boeing Commercial Airplane," "The Boeing Company," "Aviation Partners Boeing," and typographic variants) were consolidated by manual review into a single count of 492 distinct rules. Delta Air Lines variants similarly consolidated to 369. All other entries use their single normalized name. Consolidated counts will differ from individual FRTracker org pages, which show per-name-variant counts without cross-variant consolidation.

Sector totals: "Rules" means distinct Federal Register document numbers. Sector labels are editorial. The aviation total (2,067 rules) counts ALPA, Boeing, United, Delta, American, Southwest, FedEx, Small UAV Coalition, NAAA, and AOPA. Environmental total (619) counts CBD, EDF, NRDC, Sierra Club, Earthjustice, NWF, SELC, and American Lung Association. Industry lobby total (586) counts Chamber of Commerce, ACC, NAM, API, ABA, AAI, MBA, and BIO. Individuals and obvious spam accounts were excluded from the top-commenter ranking but remain in the headline entity count. See our full methodology for org extraction details.

Do Your Own Research

All underlying data is browsable on FRTracker. Note: the live pages below use per-name-variant counts, so numbers may differ from the consolidated figures in the table above.

Source: Federal Register API via FRTracker. Methodology →