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Answers to Open
Ended Questions
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Question 18:
What would you most prefer to change about the electronic commenting/docket
system that you used?
It is too difficult to move
around in the docket. It would be most helpful if docket entries were
dated and if the names of commenters were displayed.
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Integration with the semiannual
regulatory agenda, thus improving upon the site at http://ciir.cs.umass.edu/ua/
Integration with any FOIA e-reading rooms with materials related to the
rule, like the single source pages set up at Labor/MSHA in which a
large number of frequently requested docs on a signle subject are
grouped together for one-stop shopping Links to reg impact analyses
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Integration with the semiannual
regulatory agenda, thus improving on the site at http://ciir.cs.umass.edu/ua/,
which is an improvement over the Fed Reg version Integration with FOIA
e-reading rooms that have information related to the rule or the
behind-the-scenes process of creating the rule. Most helpful would be
something like Labor/MSHA's single source pages, which group
frequently FOIAed documents related to a single subject. Underlying
docs, like reg impact analyses, are sometimes strewn throughout websites
and not gathered in some of the e-docket/commenting sites I have visited
(although I typically rely on other sources, so I may simply have failed
to see them if they are readily available there). Add advanced
searching tools, like Westlaw's search features (same sentence, same
paragraph, within X words, and nested combinations of those) and field
searches for more targeted searching (like Westlaw's SY,DI searching,
which helps to ensure search results that are really focused on the
search subject and do not randomly have search terms in a particular
combination)
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I am very concerned about the
imbalance in the ability of trade associations/corporations vs.
public-interest groups to gather information about supporters and
opponents of an issue. Electronic commenting is easy, but personal
contact information is too easily available to the public. I don't
think people intend for their contact information to be instantly
available anywhere in the world when they send a comment to the
government. For this reason, I strongly suggest that the option be made
available to all commenters that their personal info (name, contact
information) be blanked out when it is electronically posted. The full
information would be available in the offices of the government agency.
The option should be at both the top of every docket, and on the dockets
management pages through which a prospective commenter has to scroll
through. I personally feel this lack of privacy is a barrier to
commenting.
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The agency should ensure that
all scientific, technical, and other supporting documents that are used
or relied upon by the agency are including in the electronic docket.
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Needs better search capability,
generally, and within a specific docket. Needs better navigation
capabilities within a specific docket. Needs clearer instructions
regarding attachments, e.g., how to and what format. Needs to allow
download of multiple documents in a single step.
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The OSHA e-docket system does
not have any capability to search the substance of submissions. The
search of any documents in an individual docket is limited to who
(person, organization) sent the submission. I would like to see greater
search and indexing capability.
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Easier and more accurate
confirmation processes.
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enable the review of comments by
an electronic tool that will scann multiple comments and rank them
according to a key word priority
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More interactive
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The agency should provide a
user-friendly, non-technical explanation of the purpose and functioning
of the docket/commenting system. Individual comments should be labelled
more clearly -- perhaps using a code inserted by the commenter or the
agency.
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I'd prefer a proactive system,
all information is available and subject to comments but not all sources
are labelled so you have to waste a long time in reading information
that doesn't match your interests.
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Define the sources of dockets
before you ask questions about them. No space to add that in addition
to being a concerned citizen, activist, etc., I am other: elder,
grandmother replying for future generations. When will we stop
consuming their water?
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Would like it configured to
accept only good rule proposals and reject dumb rule proposals.
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would like to be able to
manipulate data...i.e. sort, compartmentalize, batch, find, etc.
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More prominent links to other
comments and supporting and related documents.
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Still could use some
improvements that would make it more user-friendly, and that would
provide current status information on the rulemaking.
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Date range searches Separate
one-page non-substantive comments from those that are more substantive.
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That the proposed rule was
summarized in non-legalize making it more understandable.
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Sometimes they ask biased
questions -- questions should always be impartial and neutral.
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Easier searching and a summary
search response. Current electronic systems assume that everyone
understand how that agency identified information
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searchability
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This survey has been an
educational tool for me, as I was unaware of this tool to be part of
government/policy work. I would like to learn more about this.
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accept/post other than text
files
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I lack sufficient computer
experience and experience great difficulty in finding documents/dockets
that are relevant to our issues due to disabilities. As a matter of fact
just using this box to comment to your survey is causing problems
because I hit the enter key and believe but am not certain that I lost
the paragraph or two that I entered prior to that action. I have greater
difficulty finding dockets/items that are relevant to myself and the
issues that our organization focuses on than I ever had in the era of
paper documents.
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The rulemaking process is far
from transparent and the agencies are not accountable. Rulemaking
success should be measured in terms of compliance with democratic norms.
Interest groups and powerful lobbies have the heads up on actions. The
are invited to regneg sessions at the exclusion of the public. The
public is not informed on the process and therefore not able to
participate effectively. It is also clear that there is little
substantive change from the proposed rule to the final rule. This
suggests to me a fait accompli process where the influence and the real
decision is made before the public is really actively involved. Finally,
finding information in the FR and CFR via websites is difficult and
unreliable.
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A different, more intuitive way
of visualizing the process.
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I think that more dockets should
have tutorials and explanations about the process. In addition,
explanatory web sites like the organic foods and roadless rulemaking
sites should be standard. More of the background materials supporting
the proposal should be put on the Web. Federal Register fees limit the
size of preamble texts and the Web can solve this. Analytical modeling
tools could also be mounted allowing parties to explore specific
outcomes. Rule compliance wizards would also be helpful. They would
allowed regulated interests see how the rule would impact them. Dockets
should have listserv features like DOT's that alert parties that a new
comment has been filed.
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A meta-tag function should be
added to the Web form for submitting comments that allows each commenter
to categorize his/her comment according to a number of categories (e.g.
support, modify, oppose, etc). These self-assigned meta-tags would allow
users of the docket system and agency staff to sort large numbers of
comments.
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What I'd like to change re this
one: on previous question there is no way to say a) this may increase
access for some citizens but decrease it for others; b) it's probably an
improvement over paper comments for some people and not others; c) the
question re preventing having to go to DC to read paper versions in
unanswerable because I wouldn't have gone to DC but have ordered
proposals in print by mail. I don't know if there's another chance to
enter comments so will say here that I'm very concerned that
overreliance on electronics will cut out those who don't use them for
religious or financial reasons.
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That more grassroots people be
aware of being able to participate
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We don't have such a system in
rulemaking in the Montana state government.
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Haven't used it yet ... usually
send comments via e-mail, mail and fax.
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I reviewed individual comments,
and am unaware of whether I could have searched by terms to identify
comments addressing issues of particular interest to me.
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I am not familiar enough with
the system to respond to this from a commenter's point of view.
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Lousy search interface
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Still not able to determine when
a particular rule is open for comments. Since agencies cannot respond
to inquiries in any detail while a proposed rule is being vetted by OMB,
there is a gap until the rule is finished at OMB and then appears in the
CFR. also not easily to see other people's comments to revise own
comments or refute those made by others.
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I never used one. Sounds like
an excellent idea though.
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First of all, no one in my
office has been able to get Regulations.gov to work effectively: every
time we click to make a comment it launches a new browser window or
returns to the home page (we have reported this problem many times, with
no response). Also, the searching is really weak and doesn't handle
phrases well at all. Once it is working, I strongly believe that a
central point for reviewing proposed rules, reviewing comments, making
comments, and reviewing responses is critical to the success of
eRulemaking in general, and Regulations.gov is certainly headed in the
right direction, even if the first step has been what appears to be an
expensive, abyssmal disappointment. Specifically, I would like 1. to be
notified via e-mail when proposed rules are posted that match my
interests and/or needs (i.e., profile- keyword-based automatic
notifications) 2. to be able to find all of the rules I am looking for
from a single search interface, regardless of source, and to be able to
browse proposed rules by subject area, not just agency 3. to be able to
make comments at the paragraph or section level, so I don't have to keep
track of citations and references when I comment (e.g., the requirement
is paragraph four is unacceptable... 4. to be able to quickly and
easily review other comments at the section or paragraph level, and to
make comments on those comments at that level 5. to be able to
categorize my comments by issue and to sort other comments by issue for
review 6. to be able to respond to specific questions in a proposal
using standard conventions (e.g., radio buttons, check boxes, etc.) and
to view a real-time summary of responses to questions 7. to easily
review the agency's responses to specific comments at the section or
paragraph level and/or how specific issues were addressed by the agency
8. to be automatically registered for notifications of updates,
changes, etc., once I have made a comment on a proposed rule, including
when (and if) an agency posts a specific response to my comment
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make it run faster better
organize comments by topics
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Make it simpler to comment and
retrieve others comments. The system I used seemed unnecessarily
complex and I had to try twice before I could submit my comment. Also,
there should be a feature that allows the submitter to receive an
acknowledgement the the agency had received and considered my comment.
The CPR still said that the only way to receive an acknowledgement was
to make a submission in writing and submit a postage paid,
self-addressed postcard. If the government is going to accept
e-comments, it should be able to e-acknowledge them.
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Easier & more direct navigation
to the substance of the proposed rule.
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Quicker posting of comments
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E-docket does not, but should,
present the date received (or I couldn't find it) only the date of the
document. I don't know how the index info gets into the database but
typos have made it impossible to search on key words I would expect to
be able to search on.
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Index/summary of submitted
comments -- one short sentence on the viewpoint expressed or group
stance.
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In my experience, on the day
that comments are due, I sometimes can't get to the docket. I assume
that's because many people are trying to file their comments at the same
time. So I think that EPA needs to increase its server capacity to
handle all of the traffic on the deadline day.
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EPA does a magnificent job with
its e-docket. All federal departments and agencies should follow
suit. My experience with the Fish and Wildlife Service, in contrast was
very frustrating, as they have no electronic docket. I've been spoiled
by EPA. Docket should immediately provide on screen and/or by email to
the submitter a receipt for comments submitted via the internet,
showing date and time of receipt. Since the document(s) thus submitted
are not immediately posted to to the docket, a receipt would give the
submitter assurance that comments have been received by the the
applicable deadline. I would encourage putting contents of older
dockets into the e-docket system, particularly those that have a
significant level of stakeholder interest. For docket listings that
exceed one computer screen, by default show how many screens are needed
to see the entire docket listing, with links I can click on to go to any
one page of that listing without having to page through the entire list
to get to the end. For example, Docs 1-30, 31-60, 61-90, etc.
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Navigation around the site
should be rapid and intuitive. List most recent postings first. The
Agency should be committed to the system and keep it up to date.
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Make sure that the items listed
in the edocket are really accessible. A recent edocket which was
supposed to contain a RED document for a chemical and the docket
indicated that the document was not posted. EPA argued that it was, but
there were apparent technical problems. I was able to access the docket
a few days before the comment period closed.
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I had difficulty sending items
in PDF format because I do not have Adobe write capability, so my
original comments did not register on the system. The manager of the
process allowed me to send her a Word file that she then saved as a PDF
file. The person I dealt with was very helpful. You should allow
people to submit comments as either a PDF file or a Word file. The
directions are confusing and should be clarified.
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Electronic dockets will likely
be subject to mass responses from activists that may swamp the ability
of the system to cope. This could be especially true where generic
comments are prepared by a group and circulated to its membership.
Multiple copies might be sent by single individual to either influence
the count of pro or con talleys or to attempt to exclude or discourage
other opinions. The e-Docket may haave no capability to handle the
number of responses.
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Indicate clearly the last update
made to the comments contained in the docket and the frequency of
updates for new comments.
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In scrolling thru the docket to
review the comments submitted, I could not pick up from the last comment
I reviewed as more comments were added without going thru all the other
existing comments. That is, I could not jump to the last comment by
number, and then pick up scrolling thru new comments added in numerical
(chronological) order. Lack of this capability restricted my ability to
review the docket. I could search for particular documents that I new
existed, but I could not review documents that I did not know existed as
the docket grew large.
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information posted more quickly
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The creation of an overview
document that captures in a good summary the action that is being taken
is one of the most important aspects of any e-comment system.
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Better information on the people
who comment. Those who participate would be asked to fill a form giving
data on themselves, their relationship to the project, any group,
organization, business or institution with which they are affiliated and
which has a bearing on the project, the areas in which they claimed
expertise, and the basis for those claims. That information in turn
should go into a database that allows easy sorting and searching.
Oftentimes, when one reads comments, it is not clear who is speaking on
whose behalf. This information should be requested in a friendly format
designed to respect people's sense of privacy, and should not be readily
downloadable.
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Allow multiple attachments per
entry.
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Create an interactive comment
system that would focus comments on specific issues and organize
comments by issue. The intent would be to minimize irrelevant comments
and help organize and focus comments. This could be by funneling
commenters by subject, asking specific questions (similar to this
survey), or a combination. This would probably need to be supplemented
by a capability of free form comments also, to make sure no relevant
comments are discouraged. This would save time for agencies and help
them focus on relevant comments.
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Used it twice. Well, I TRIED.
(1) first attempt involved the FCC. At deadline, the system JUST DID
NOT WORK. Period. Fortunately, I had a friend who was a Commissioner!
Sent the comment directly to her e-mail for filing in the docket. If I
didn't have that capacity I would have been very, very, very upset, as I
had invested a whole lot of time in the process (and had some comments
that raised issues involving technology that the agency had not
considered). (2) second time, FDA. The electronic commenting system
would only let you answer THEIR particular questions. It tried to
steer you in a certain way that had absolutely nothing to do with the
issues I wanted to raise. So I landed up putting what I wanted to say
within a framework of a certain set of questions -- to which I was being
quite nonresponsive. There was no free response option in the
electronic docket (which, of course, I screamed about, loud and clear
...). So, what to change? (1) Make sure there is technical support
available -- in the form of an e-mail address (to which, in the worst
case, you could always attach your document), and (2) Don't assume the
public commentors need to be led down a path, but rather leave open
the possibility of people saying ... what they want to say. That is,
after all, the point of comments...
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I'd like it to have bookmarkable,
human-readable URLs that made it easier to find a particular proceeding
and/or specific comments within that proceeding, as well as to refer
others there.
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Add a cross reference to recent
related rulemaking or pr notices.
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Consider providing auto-feedback
email regarding updates made to specific dockets to people who have
previously submitted comments -- particularly if there were other
comments offered in support of or rebuttal to their comments. Also:
Consider allowing 'intelligent' searches through entire population of
comments, based on specific search parameters or subject material. This
would focus searches on specific subject matter, rather than having to
research entire comments database for specific subject material of prime
interest to commenter.
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