Federal agencies are legally required to accept public comment before finalizing rules — a democratic safeguard that, in practice, has been systematically engineered into a delay-and-capture machine by the industries being regulated. We trace exactly how sophisticated comment campaigns, litigation threats, and the quiet science of 'ex parte' meetings have turned the notice-and-comment process into a graveyard for inconvenient regulations — one that makes last week's consent decree problem look almost quaint by comparison.