5 Tech Solutions to Comment Period Hurdles

How Agencies Are Relying on Technology To Address Modern Challenges

Thomas Mullen
May 2, 2018

One of a free society's most fundamental attributes is the ability of citizens to interact directly with the people overseeing the public policies affecting their lives and environment.

Very often, this interaction takes the form of a public comment period, where citizens are invited to give their opinions on a regulatory proposal or Environmental Impact Report, with the understanding that their input will be considered and responded to during the decision-making process.

While public comment periods have become a critical part of citizen-governmental dialogue over the years, the process itself is going through its most drastic evolution ever thanks to a now-familiar catalyst: the internet.

While today's constantly connected digital capabilities have given the public unprecedented access to the country's decision-makers, they have also created a new set of baseline expectations around how regulators handle and respond to citizen concerns.

Last week, SmartComment had the opportunity to speak to a conference of the country's foremost environmental regulators about how the internet is affecting public engagement and the citizen-agency dynamic.

Below are some of the issues and trends that technology is bringing to the fore in this relationship, and how technology must also be the solution for regulators looking to ensure transparency, efficiency and accountability in the public comment process.

Improved Accessibility

In our discussions with regulators from some of the country's top environmental agencies, one thing was universally clear: making citizens write letters or emails to submit comments about the projects they care about is no longer going to cut it. With the internet serving as the go-to forum for most of our commercial interactions, agencies must allow citizens to submit electronic comments seamlessly and instantly via a dedicated digital interface. Not only does the failure to provide this baseline capability fly in the face of principled public engagement, it is also legally dubious--setting an agency up for a potential lawsuit based on a lack of open access in their process. The quickest solution? Set up a project page that allows citizens to submit comments with the click of a mouse or the tap of a smartphone--either in-house or by partnering with a public comment software provider. Here at SmartComment, agencies can establish a web-based project page that's ready to accept and store public comments in a matter of minutes. They can set their comment period to open and close on a given date or time, and even create a customized back-end process for managing and responding to the comments that accounts for multiple approval layers, a multi-department project team, outside consultants, and any other unique factors.

Form Letter Management

With its ubiquity and around-the-clock accessibility, the internet is an incredibly valuable tool for citizens to have their say on the projects affecting them. Some of this input invariably comes via nearly identical form letters from members of a large group or other organization with a direct interest in the subject of a request for comments. While this is a perfectly acceptable method for presenting a unified opinion about a given topic, it can give agencies on the receiving end headaches in managing their sheer number--which often reach into the tens of thousands. To properly gauge the content of these letters and respond to them efficiently and effectively, many agencies rely on comment management software to instantly identify form letters. With this method, agencies can accurately keep track of the total number of form letters in a way that demonstrates the pervasiveness of the sentiments expressed in them, while providing a response that addresses the letters as a whole. This is the ultimate win-win, ensuring citizens involved in submitting the letters have their sheer numbers accounted for, while preventing the comment management and response process from getting needlessly bogged down by having to manually sort and respond to thousands of identical submissions.

Comment Bots

Internet bots have become a well-known menace for any organization interfacing with the public online--infamous for their alleged role in spam campaigns that support repealing net neutrality. Essentially, bots are software applications that run automated tasks over the Internet at a much higher rate than would be possible for a human alone. But these futuristic-sounding scourges don't just target platforms like Facebook; they can also wreak havoc on your web-based comment period if you don't put the right protections in place. That's why SmartComment's proprietary code and captcha verification capabilities ensure that no bots hit your comment period with spam or misinformation. This ensures that bot-created noise never prevents or distracts your project team from managing and responding to actual feedback from the public and other stakeholders.

Public Disclosure Requests

With increased expectations from the public for government transparency, there's been a noticeable increase in recent years in public disclosure requests. This is when someone from the public basically says "Send me all of your comments." Obviously, wrangling thousands of letters and emails to answer such a request is incredibly difficult. But with SmartComment, it's as simple as clicking a button to export all the comments into whatever format works best for the requester. Not only does such responsive service indicate an act of good faith on the part of the agency, but it saves staff untold hours of manually printing and collecting comments held in various formats and in separate locations.

Natural Language Processing

When faced with the thousands of submissions that can accompany a request for comments, agency staff can use Natural Language Processing capabilities to help determine public sentiment around a given issue. At SmartComment, this involves our software automatically scanning the comment and performing an instant analysis on the keywords, themes, and general sentiment it contains. The more accurately such data is dissected, the more informed an agency can be when they have to make a decision on a rule, regulation or issue.

No matter the challenges on the horizon, regulatory bodies are continually being called on to provide ever-clearer lines of communication with the citizens affected by their decisions. As this process brings new technological obstacles, it becomes all the more imperative for agencies to use the most innovative methods and tools to manage their relationship with the public--for the benefit of both citizens and the projects and proposals at the center of their dialogue.