Coalition influenced key provisions in draft federal rule
3/21/2025
Client: Confidential Industry Consortium
Members faced costly compliance timelines and ambiguous definitions. We organized a credible coalition and grounded comments in evidence.
Objective
Clarify definitions, mitigate unintended impacts, and secure a realistic implementation timeline.
Approach
- Mapped agency stakeholders, Hill offices, and credible third parties.
- Analyzed the draft rule against statutory authority and prior enforcement.
- Aggregated member data to quantify operational impact and costs.
- Drafted coalition comments and aligned member submissions to reinforce key points.
- Briefed reporters and validators to explain practical consequences and alternatives.
Outcome / Impact
- Final rule adopted clearer definitions that aligned with statutory language.
- Compliance timeline extended by 12 months.
- Agency guidance incorporated industry data and examples submitted by the coalition.
Services used
They kept the group disciplined and turned anecdotes into evidence the agency could use.
Background
The draft rule introduced new obligations with an aggressive schedule. Definitions created uncertainty that would have increased costs without improving outcomes.
What we did
We organized a credible group, aligned positions, and supported them with a shared evidence base. We translated operational details into clear, sourced recommendations that fit the statute and precedent.
Result
The agency adjusted definitions and schedule. Guidance cited examples that mirrored coalition submissions, and members gained time to comply without disruption.