Many laws created by Congress and enacted by the President do not specify every detail of how they are to be implemented by federal agencies. Agencies use the rulemaking process, which seeks public comments, before implementing laws and policies.
When a federal agency decides to change or create a rule that has to do with law or policy, the agency must collect public comments on the rule and address concerns raised, according to the Administrative Procedures Act (APA).
“Public input is very important,” explained Barbara Bauer, associate for Environment and Natural Resources at Abt Associates, “and federal agencies value those perspectives and ideas.” In many cases, these agencies also must respond to each comment or group of related comments.
That is no problem when a proposed rule generates dozens or even hundreds of comments. But some rules attract millions of comments. Some of these public comments may be unique, but others are duplicates. Other comments address many issues at once. All of those comments matter, and they all must be read, analyzed, and addressed quickly to inform the final action.
To help clients meet this need, Abt Associates developed CommentCounts™, a web-based tool that enables federal agencies to manage any number of public comments and respond meaningfully and systematically. Led by Bauer, CommentCounts™ gives clients an easier way to organize, understand, and respond when time, transparency and insight matter.
“Technology has made it easy to submit comments to federal agencies on any given issue,” Bauer said. “CommentCounts™ helps clients rapidly understand the commenter issues and respond.”
How can a federal agency quickly sort through so many comments and apply this public input to their proposed rules?
Bauer’s team downloads the comments and manages duplicate entries that may have been submitted multiple times. They sort through the comments and categorize them which in turn feeds data visualization maps and filters that show clients what the issues and concerns are. Clients can use that information to draft responses.
For example, the Bureau of Land Management recently needed public input on proposed changes to regulations on how the venting and flaring of natural gas are handled on public and Indian lands. Natural gas is often wasted in oil and gas production, and these leaks are not only inefficient, but generate greenhouse gas. The proposed rule generated almost 334,000 comments.
CommentCounts™ handles all types of documents, links comments with associated responses, tracks progress, integrates communication tools for collaboration, and offers robust search and reporting functions. Clients include the U.S. Environmental Protection Agency, the Bureau of Land Management, the Federal Highway Administration, and the National Oceanic and Atmospheric Administration.
Clients appreciate that CommentCounts™ is secure and does not require a license, seat fees or any other hidden costs, Bauer said
“Federal agencies have to stretch budgets, too. We understand that when an agency proposes a rule, it may be hard to tell how many comments it will receive,” she said. “Abt excels at managing large number of complex comments efficiently. We get the comments organized, so clients can read through reports, understand the issues, and act.”
Acting upon comments is no small task. Agencies are required to consider all comments and respond to all pertinent issues. Bauer recounted a recent project where the client had 65 staffers addressing and preparing final responses to comments.
“We’re always looking for ways to improve the process and make it more efficient and less costly for clients,” said Bauer. “This is a practical tool where academic ideas and rigorous research meets the real world.”
Learn more about CommentCounts™.
Visit the CommentCounts™ web site.