Clients or agency leaders frequently ask for more detail about various comments during or after a comments analysis project. These requests could occur at any point in the rulemaking process. Furthermore, if there are hundreds or thousands of comments, responding to the questions could take hours, especially if teams have to pore through notes and mappings in Word docs or spreadsheets. However, a software tool like DocketScope®, designed for analyzing and organizing public comments, will make it much easier to satisfy these requests with just a few clicks of the mouse.
For example, several months after one team completed an analysis of public comments for a federal agency client, the client requested clarification about some of the submissions. The client identified 57 document identification numbers that did not appear in the Citation by Issue report for the analysis. The client asked the comments analysis team to review the cases and explain why they were not included.
Typically, this kind of question, coming months after the analysis was complete, would take hours to answer, but with DocketScope, analysts could log in and generate a Comment Characterization report, which, for each submission, provides:
• Document identification number
• Submitter name
• Status of the submission (open, in progress, complete)
• Classification (unique, form letter, duplicate, or not relevant)
• Whether substantive
• Commenter type.
The team could easily identify the 57 comments in question in the report. The report also showed that each one was a non-substantive comment. In other words, the commenter stated an opinion on a rulemaking, either generally agreeing with or generally disagreeing with the proposed rule, but did not provide data, research, or even detailed examples—anything that might change the proposal.
As these were non-substantive comments, no citations were mapped in DocketScope because, as a matter of best practice, the team only maps substantive comments that raise significant issues. Accordingly, these 57 document identification numbers did not appear in the Citation by Issue report.
Even though they were not mapped, the non-substantive comments were still documented in DocketScope, so retrieving and reviewing them for the client was a snap. Instead of hours or days of delay, the team could respond in a few minutes, and the client could rest easy that these comments were not accidentally overlooked, miscategorized, or misunderstood. With DocketScope, comments analysis teams save time, and agencies have peace of mind that the submissions were thoroughly reviewed and documented at each stage.