Regulations.gov is a website that US government agencies use to inform their regulatory decision making. Congress writes laws and Federal agencies digest those laws into specific rules. Those regulatory choices are often informed by public commenting periods seeking input from anyone with a web browser and an opinion on the matter. To tweak Lawrence Lessig's model, if law is code, then this process could be thought of as shitposting on GitHub pull requests.
I have submitted over 100,000 public comments on regulations.gov as a software developer at the American Civil Liberties Union. I maintain The Public Comment Deliverator, a tool that submits public comments to regulations.gov, sourced from ACLU mailing list subscribers. My paper describes a case study in maintaining niche civic infrastructure software, challenges that come from scaling that process up, and includes observations on the ethics of using automation in this capacity.
A core challenge of The Deliverator is in its adversarial relationship to the system it engages with. Each choice made by the public sector team who maintains regulations.gov must be met with a considered response on the submission side. Each Deliverator robot must consider each required field, each step in the flow, and handle errors gracefully. When a robot detects it’s been throttled by the website it stops delivery, waits for a bit, and then resumes its deliveries once its ban has been lifted.
While this cat-and-mouse dynamic may cast doubt on the legitimacy of the operation, I argue that we are using regulations.gov as intended. Each ACLU-affiliated submission is fully in line with the intended use of the website. We are careful about tracking the delivery status of each individual submission, flagging them as originating from a third-party, and having the capacity to audit the deliveries associated with each submission campaign.