In Visual Rulemaking, Prof. Elizabeth G. Porter and Prof. Kathryn A. Watts challenge agencies to break free of dense text and to explore a new universe of “visual rulemaking.” Citing colorful examples from the past few years, the authors urge agencies to make greater use of videos, images, and social media to promote transparency and expand public engagement. The authors also fully acknowledge the legal risks of pouring such new wine into old wineskins. And so they invite legal scholars, courts, and agency attorneys to help move administrative law toward a warmer embrace of these dynamic new practices. In this Comment, an agency attorney with decades of experience in rulemaking analyzes their proposals in relation to agencies’ responsibilities under the Administrative Procedure Act.