Profs. Porter and Watts’ article, Visual Rulemaking, explores the potential of visual images to “strengthen and further democratize” the rulemaking process by promoting transparency, accountability, and increased public participation. This Comment highlights some of the limitations associated with visual rulemaking, drawing upon the authors' experience participating in the Clean Water Rule: Definition of “Waters of the United States” (CWR) rulemaking effort, and offers several recommended guidelines for federal agencies to consider as they inevitably develop a framework to engage in visual rulemaking.