Public Comments to APA "Informal" Section 553 Rule-making are potentially very important instruments in shaping law and regulation, particularly in environmental law. However, there have been relatively few articles discussing how one should craft these comments, given the legal environment surrounding administrative law. By using the controversial New Source Review proposal of the CAA from the Bush EPA, the four authors, environmental and administrative law experts independently craft comments, and then specify lessons and best practices for sec. 553 comments generally.