Contents

Public Comment Toolkit

 
The Trump Administration issued a new policy^[1] that would make it easy to fire hundreds of thousands of federal employees and replace them with political loyalists. This would make it easier to purge the government of the people and services that hold corporations accountable, protect labor rights, ensure clean air and water, provide healthcare and Social Security benefits, and enforce the safety regulations that improve the lives of Americans. 

🇺🇸 We can stop them 🫵 You can help 🔥 
Use this guide to submit a comment by June 7, 11:59pm EDT^[2]

How: Trump’s Office of Personnel Management (OPM) is required to solicit public comments before the policy takes effect. OPM must review every public comment and respond to significant comments.^[3] If OPM does not follow these steps, federal courts can stop the policy. Commenting is your opportunity to make your voice heard and fight against this dangerous policy before it harms millions of Americans.

Comments helped fight previous policies and can do so again: For example, Health and Human Services (HHS) proposed reducing certain Medicare reimbursements for health care providers. Commenters pointed out errors with the studies cited by HHS. A court struck down the HHS rule because of the issues pointed out by comments.^[4] 

🟢 Use these Tips, FAQs, Arguments, Examples and ChatGPT prompts to start 🟢

How to craft your comment:

The best comments are unique and contain a mix of the elements listed below.^[6] Comments do not have to be long and do not have to address everything to be effective.

• 📩 Include required information. Your comment must include the proposal information: Agency name (OPM), Docket ID (OPM-2025-0004) and RIN (3206-AO80).
  
• ✍️ Personalize your comment. Comments should be unique and should not use generic text from comment campaigns. An example template^[7] and brief outline to start:

• Introduction: Explain why you are interested, your credentials and experience.
  If you are a federal employee, submit this in your personal capacity (see FAQs).
• Personal story: Write a personal narrative of how this will impact you. When possible, refer to the specific parts of the rule related to the impact.
• Other arguments: Select a few arguments that you can expand on.
• Conclusion: Summarize your arguments and propose alternatives to the policy.
  

• 👊 Challenge the policy. Courts will stop policies if their underlying policy judgments, reasoning, or factual premises are wrong or misleading. List problems with the proposal. Ask questions about the rationale and provide examples of why it’s wrong. If you can, include facts, data, and citations to bolster your argument (but this is not required).
  
• 🎯 Be clear and direct about the impact. What are the costs and benefits?^[8] How will the proposal impact you or your community? Describe the result of the policy.
  
• ↩️ Propose alternatives that can better-accomplish the stated policy goal. This can include maintaining the status quo. Recap your recommendations in the conclusion. Courts will stop policies if the agency has failed to consider an important problem or failed to consider reasonable alternatives.
  
• ✏️ Cite the proposed policy: If your comment refers to specific sections of the proposal, note the section heading and page number if relevant. When referring to regulatory text, note the subpart and section number.
  
• 🤖 (Optional) Use ChatGPT for help. See ChatGPT prompts to help draft your comment. Always review the output for accuracy.

What to avoid:

• Don’t submit generic text from comment campaigns. Near-duplicate text can be identified by software and grouped together for review, which provides little benefit and no new information. If you don’t have much time to write a comment, take a few minutes to add a personal paragraph to generic text.
• Don’t spend too much time making it very well-written. These are reviewed quickly. Imperfect grammar and spelling are okay.
• Don’t give confidential or sensitive information. These comments are made public.
• Don’t submit threats, insults, or content that is not related to the policy.
  

FAQs:

• Can I mention that I’m a federal employee when submitting my comment? Yes. You have the right to comment under the First Amendment^[9] but you must do so in your personal capacity. Below are some general guidelines to follow. If you’re unsure whether your position has special ethics considerations, check with your agency’s ethics office.

• Start your comment with “I am submitting this comment in my personal capacity.”
• Depending on your agency’s guidelines, you may or may not mention your job title and agency. If you do include your title and agency, make it clear that you are speaking in your personal capacity and not speaking on behalf of your agency or the government.^[10] Generally, making it clear that you are a union member allows you to speak more freely about your job title and agency.
• You may comment using your personal contact information.
• Do not use government property or time to work on your comment.
• Do not disclose nonpublic government information in your comment.
  

• Can I make my comment anonymous? Yes. Select “anonymous.” If you submit under a pseudonym, create a new email address if you want confirmation that your comment was received but do not want your primary email address in the public record. OPM is obligated to review your comment even if you submit it anonymously.
  
• Are there example comments I can work off of? Yes! See below for example comments. If you use these for inspiration, put it in your own words.
  
• Can I submit multiple comments? Yes. In fact, some commenters will submit their original comment, read other comments, and then submit new comments in response.
  
• How are comments reviewed? Many agencies manage the comment review process by using technology to group comments using near-duplicate text (e.g., that use generic text) for faster initial review. Unique comments (comments that do not use generic text) can’t be managed in this way and thus require individual review to determine if they are significant. Agency staff will review the comments, tag them by common topics, and draft responses to the significant issues raised.
  
• How much time will this take? This will vary by person. Comments do not need to be lengthy to be effective. If you have more time, go deeper with your arguments and proposed alternatives. Do not let perfection be the enemy of the good – your voice deserves to be heard!
  
• How do I submit a comment? Go to Regulations.gov (OPM-2025-0004-0001) and click “Comment”. Enter your comment text in the “Comment” box or upload a PDF of your comment in the “Attach Files” box. (Note: if you wish to remain anonymous, make sure any identifying metadata is scrubbed from the PDF before submission.) Under “Tell us about yourself!” select “Individual” if you wish to enter your information, or “Anonymous” if you prefer not to. You have the option to provide your email address to receive an email confirmation. You do not need to fill out “What is your comment about.” After you submit your comment, you will see a new page with your Comment Tracking Number.

Arguments you can make 

These are some examples to get you started; it is not a comprehensive list. Pick a few that are the most important to you to write on – you do not need to write on everything below. Start with your personal narrative. If you want to add more, you can include some high-level impacts (below). If you have expertise or experience in other technical areas, you can include those arguments as well. The most important thing is making your comment unique.

Personal narrative:

• Federal employees: Describe the impact of this proposed rule on your job.

• Looking back: Did civil service job protections and stability influence your decision to choose a federal job over the private sector? How would this policy have impacted your work if it was in place in prior administrations? Have you ever had to challenge leadership over a legal requirement, a required process, or a misunderstanding of facts and data? Have you had other reasons you needed your existing civil service protections?
• Looking forward: How could it impact your job going forward? How might this change management’s openness to hearing differing perspectives and evidence?  Would these changes make you fear providing your best judgment and feedback to leadership? 
• Impacts on the product or services for Americans: Would it change the quality of your work? Would this change the pace or efficiency of how work gets done?

• General public: Describe how partisan civil service would impact your lives.

• What public services (e.g., Social Security, healthcare, education, clean water, energy) do you and your family rely on that would be impacted if the President can fire federal employees at will? How would you be affected if experienced employees are discouraged from presenting balanced viewpoints or are fired every few years? How would you be impacted if critical government systems were maintained by people without the necessary experience?

High-level impacts:

• Exposes public services to increased political instability: Political loyalty would become more important than expertise, which will directly impact the services used by the American public: Social Security, Medicare and Medicaid, housing services, national security, national parks, and much more.
• Less experienced federal workforce: By making it easier to fire career civil servants, this proposal would drain the federal government of skilled and experienced workers necessary for the federal government’s complex and necessary work (cite).
• Hinders our country’s research and innovation: The proposed rule could put scientists and scientific research at risk. It would allow for political appointees to remove scientists at-will who present scientific findings that are at odds with the administration’s political agenda. Scientists might self-censor or avoid publishing findings out of fear of retaliation, which hinders scientific advancements that could benefit the public.
• Relies on “evidence” that does not support its conclusions: For example, the policy references federal employee surveys asking about perceptions of poor performance and misconduct (cite), and cites a poll and anecdotal cases as evidence of widespread “resistance” to Administration priorities. These sources do not constitute sufficient evidence to justify the proposed rule’s conclusions or its solutions. Contrary to what OPM claims, we expect these policies will lead to poor performance that is protected by political loyalty and to an increase in politically motivated and retaliatory firings under the guise of rooting out partisanship.
• Does not adequately justify rescinding and replacing the 2024 OPM rule: The Supreme Court has said agencies are “free to change their existing policies” but must “provide a reasoned explanation for the change,” “display awareness that [it] is changing position,” and “show that there are good reasons for the new policy.”^[11] Commenters could argue, for instance, that not enough time has passed between the passage of the 2024 rule and creation of the 2025 rule for OPM to have assessed the effectiveness of the 2024 rule.
• Contrary to existing civil service laws’ intentions: The Civil Service Reform Act and The Pendleton Act were meant to end the spoils system and to keep politics out of hiring and firing decisions. The proposed rule, while it purports to preserve merit hiring, is fundamentally opposed to this goal, because it will reclassify career civil servants as at-will employees for the express purpose of making them easier to fire, regardless of merit, if they are perceived as pushing back on Presidential directives (cite).

Costs and benefits:

• The proposed rule preliminarily estimates that 50,000 federal employees could be reclassified as Schedule P/C (cite). However, it’s likely that hundreds of thousands could be reclassified based on recent examples and OPM’s own guidance which show that agencies will likely attempt to apply this more broadly.
• OPM claims to identify benefits from improving federal employees’ performance and conduct, but cannot provide a reasonable estimate of this purported benefit (cite).
• OPM claims to find the 2024 Final Rule’s determination of costs and concerns about “reliance interests” largely misplaced (cite) but does not provide sufficient analysis to justify this claim. Moreover, OPM claims that “Employees who faithfully perform their jobs to the best of their ability have little to fear” (cite). However, the policy puts these employees at risk to be fired at-will if doing work to the best of their ability, such as providing balanced considerations, is inconvenient to those in charge.
• The Costs section of the proposed rule fails to mention other costs, including the decreased ability of Schedule P/C employees to follow lawful statutes or regulations without fear of retaliation if those statutes are deemed inconsistent with the priorities of the governing administration. Stripping over 50,000 federal workers of civil service protections and exposing the American public to increased instability in public service delivery are all concrete harms.
• OPM estimates that separating reclassified employees under Schedule P/C procedures will save the government money (cite), but fails to quantify costs from increased EEO complaints (cite) and potentially thousands of federal court complaints alleging constitutional due process and First Amendment violations. If Schedule P/C leads to large scale firings, this is likely to lead to a flood of federal court litigation.
• OPM claims that the policy will not cause recruitment and retention problems (cite). But it does not consider how strong an incentive for-cause removal protections are for federal employees who could make significantly higher salaries in the private sector. We also expect that the policy will increase politically motivated and retaliatory firings, which will in turn hinder recruitment of the highest-quality candidates. An increase in firings and subsequent hirings will unnecessarily cost the federal government more money over the long run.
• OPM repeatedly states that they would defer to the President’s determination of costs and benefits (cites 1, 2), flouting decades of applicable EOs, OMB guidance, and rulemaking practices. Moreover, while the President ordered OPM to issue a rule on the subject (cite), the President did not necessarily order this rule.

Legal and policy-related:

• Changes should be incremental in nature to be fair to both federal employees and the American public. This proposal presents very disruptive changes that overturn decades of norms and policy.
• The proposed rule will chill First Amendment protected activity. This is supported by the fact that OPM specifically calls out Harris voters as likely to be targeted for firing on the grounds that they are more likely to be insubordinate in the NPRM (cite). Employees could fear that their protected political speech outside of work would be used as a basis to target them for extra scrutiny.
• Ethical concerns: Some professionals, like attorneys, have ethical obligations to maintain high standards of honesty, integrity, and fairness to their clients. The proposed rule could force these employees to choose between meeting their ethical obligations or facing retaliation for not giving leadership the advice they want to hear.

• The proposed rule is likely to exacerbate the existing loss of experienced, competent employees that is already underway due to the administration’s other extreme actions, including the deferred resignation programs (DRPs), unprecedented layoffs (RIFs), and attempted termination of tens of thousands of probationary and term employees. This policy would provide another avenue for the administration to attempt to illegally dismantle agencies by rendering them inoperable by the removal of their staff (example).

CSRA and Chapter 75:

• Undermines the Civil Service Reform Act of 1978 (CSRA), which was enacted to prevent politicization of federal employee work and ensure a competent and impartial federal workforce.

• The term “partisanship” is not defined anywhere in the proposed rule, giving this and future administrations license to terminate or discipline a reclassified employee simply for being perceived to be pushing back on the policy preferences of the administration.  

• Although the proposed rule purports to limit reclassification to policy-affecting positions, it removes federal employees’ right to appeal their reclassification (cite). Under the proposed process, the President could reclassify any specific position as at-will (cite), and the only potential remedy would come from costly federal litigation, which may prove fruitless because of CSRA preemption.
• Congress granted statutory due process rights to federal workers by creating for-cause removal restrictions in the CSRA (cite). OPM’s rulemaking authority is insufficient to revoke a right that Congress created for career federal workers. Revoking such a right would require legislative action from Congress.
• While the CSRA intended to provide greater presidential control over federal employee removal, this was designed to be channeled through the Merit Systems Protection Board (MSPB), which the CSRA created. The Trump Administration, however, is attempting to bypass MSPB and, in so doing, deprive civil servants of their due process rights.
• Removing federal workers from Chapter 75 protections is also inconsistent with the CSRA’s scheme of channeling federal workers’ employment-related claims away from federal courts. Doing so can permit those employees to bring workplace claims in court, since Congress will not have provided alternative avenues for those employees to enforce their constitutional rights. That would be at odds with the statute’s goal of making sure federal courts are not overwhelmed with federal workers’ claims.
• Removing protections from these workers under 5 U.S.C. Chapter 75 may affect other workers’ protections like union rights. 

Alternative proposals:

• The comment period for this proposed rule should be extended to 60 days to give more time for the public to thoroughly consider and provide comment on the impacts.
• Withdraw the proposed rule, keeping the 2024 final rule in place.
• Request increased funding to MSPB to speed up appeals.
• Streamline rules concerning performance evaluations; request changes to MSPB rules.

Example Comments

Submitted comments can be found on Regulations.gov (OPM-2025-0004-0001). Below are just a few examples to help get you started, including examples of what good and bad comments look like.^[12] The most important thing is that you write your own unique comment.

• Good comments provide a personal narrative that describes the policy’s impact. They can also include detailed analysis with citations (examples: short, long^[13]).

• Example comments from federal workers: Link 1, Link 2.
• Example comments from the general public: Link 1, Link 2.
  

• Bad comments include content unrelated to the proposed rule, general statements without substance, or those that make a good point but need more supportive details. Examples:

• “It’s astounding how many clowns you can fit into a clown car.”
• “I strongly support this rule. That is all.”
• “This is an absolutely terrible idea. It will politicize the civil service and result in the opposite of accountability and competence.”

Good examples from civil servants on how to introduce your experience while speaking from your personal capacity:

• “As a federal employee commenting in my personal capacity, I strongly oppose the proposed rule. This policy would represent an unprecedented increase in the politicization of the federal workforce, threatening the integrity and effectiveness of the civil service. .... I work on scientific research aimed at improving clean air and clean water for all Americans. This work is grounded in evidence, guided by public health priorities, and intended to serve everyone—regardless of political affiliation. The ability to carry out this mission depends on a nonpartisan, merit-based civil service that values expertise and insulates scientific integrity from political pressures.”  (Link)
  
• “As an experienced government scientific manager, I have often been told that it is difficult to discharge govt employees for performance related issues. What is not stated in the summary is that, in my experience, this has virtually always applied to employees at lower levels, and not to those targeted by this proposed rule making. I concur that there are challenges in the Merit system and in the Civil Service system. I do not agree that these issues will be effectively addressed by this proposed rule.” (Link)

Good examples from the general public on specific impacted topics they can speak to:

• “My comment pertains to the supplementary information on page 17187 under the heading 2. Executive Order 14171 - "Substantive participation and discretionary authority in agency grantmaking…" … While I cannot speak to other sorts of grants, I do know that having political appointees be responsible for grantmaking decisions for scientific grants will be harmful for scientific progress. Policy may be informed on science, but science should never be informed on policy. The president and their politics should have no influence over what science gets funded. We are already seeing effects of politics disrupting science through the cancellation of highly successful study grants.” (Link)

ChatGPT Prompts

ChatGPT and other generative AI tools (Claude, Gemini, etc.)^[14] are a great way to help you summarize text, edit text for clarity, and generate ideas if you feel stuck. These tools can help to speed up the writing process but they should not be used to write the entire comment. It requires a human touch to ensure the final result is in your voice. Two notes of caution:

• Generative AI tools are known to generate hallucinations (made-up statements) and other unexpected results. Always review the output for accuracy before you use it.
• Do NOT put any confidential or sensitive information into these tools.

Pre-Prompting: It’s usually best to pre-prompt ChatGPT for better results because you’re giving it constraints on how to reply to your questions. An example of a pre-prompt:

I'm writing a public comment in response to this proposed rule: https://www.regulations.gov/document/OPM-2025-0004-0001. I would like you to help me write variations and clean up the language for what I'm aiming to write to make it unique and clear that I'm against the policy change. Bound this to the perspective of a United States citizen speaking in my personal capacity.

After you pre-prompt it, you’ll see a message from ChatGPT asking you to share a draft of your comment letter or the points you want to include.

Editing: You can ask for help to clarify your text, revise your thoughts, and change the tone or material you’d like to use. Examples:

• Make this more concise and easier to understand: [text]
• Summarize the following ideas into a single paragraph: [text]
• Rewrite the text in a more professional tone.
• Rewrite the letter, but refocus it on the impacts of the policy on [specific topic]
• Rewrite the paragraph on [topic], but provide more details about [subtopic]

Use tips from How to craft your comment for more ideas on how you can tailor your comment.

Spread the word 🗣️

• 🎉 Host a public comment party: Invite your friends over – ask everyone to bring a laptop and a snack to share. Walk through this guide, talk about the impacts, and write comment letters together. In a union or other social group? Offer to host a training.
  
• 💕 Share this guide with friends and family. Help them understand the implications of this policy by sharing your personal narrative and how you expect to be impacted.
  
• 🎤 Attend a public comment event: Click here to sign up for an online training or to attend an office hours (comment party 🎉). Check the link for NEW dates.

About FUN

The Federal Unionists Network (FUN for short) is an informal association of federal unionists and our allies organizing to support each other in strengthening our unions, improving our agencies and building solidarity across the federal sector of the labor movement. To learn more about or to join in the FUN, visit us at https://www.federalunionists.net/.

Please direct any questions to funpubliccommentproject@gmail.com.

This publication should not be construed as legal advice.

Links to external sources are not intended as an endorsement.