CommentWorks^® Case Studies

CommentWorks® has improved the public participation efforts of our customers by: Accelerating and improving comment analysis efforts Integrating easily with existing comment collection systems Serving as a fully capable enterprise solution for all comment management activities Increasing government transparency and accountability with the public Enhancing collaboration among different organizations and across locations Encouraging more focused comments from stakeholders than other collection methods typically allow CommentWorks e-Tour CommentWorks Brochure National Environmental Policy Act (NEPA) and Related Services

Accelerate and Improve Your Comment Analysis

• On Multiple, Concurrent Projects

The Department of Labor's Employment and Training Administration turned to ICF and its CommentWorks^® software to establish a consistent and proven method for analyzing public comments across all of its concurrent rulemaking activities—both large and small. Using CommentWorks as an enterprise solution on initiatives that range from only a handful of comments to over a thousand allowed ETA to improve consistency across its projects and conserve resources by avoiding ad hoc comment analysis approaches to each new rulemaking. ICF has used CommentWorks^® to support more than 10 ETA rulemakings to date, working closely with ETA subject matter experts on each occasion to ensure that comments are tracked by the most critical issues.

• On One, Particularly Large Initiative

Clients often turn to ICF and our CommentWorks^® software when they expect a relatively high volume of public comments to be received on one specific proceeding. For example, after receiving 228,000 public submissions on its "provider conscience" proposal, the Department of Health and Human Services asked ICF to provide our CommentWorks^® software and support services to track, sort, analyze, and summarize this high volume of public feedback. This controversial rule would safeguard against coercive or discriminatory policies or practices targeting medical professionals who refuse to perform services to which they are morally opposed. ICF teamed with another contractor to complete the analysis and deliver a comprehensive final summary within just 15 business days of initial award.

Integrate Easily with Existing Systems

• Federal Docket Management System (FDMS)

The Department of Homeland Security received more than 10,000 unique comment letters on its proposal to establish minimum standards for state-issued driver's licenses and identification cards under the REAL ID Act of 2005. While DHS used FDMS to post these letters to the public via www.regulations.gov, the Department needed a separate but compatible system for analyzing and summarizing the comment content. DHS hired ICF and our CommentWorks^® software for this purpose. ICF worked closely with DHS docket staff to obtain electronic copies of the 10,000 comments and their metadata from FDMS in a format that could be batch-imported quickly into CommentWorks^®. Within less than four weeks of receiving the comments, ICF delivered a report distilling these 10,000 comments into a detailed summary covering approximately 200 topical areas.

• Other Comment Collection Systems

The Bureau of Land Management asked ICF to help catalog, organize, and analyze more than 30,000 public comments received on a draft environmental impact statement (EIS) on revisions to its Resource Management Plans (RMP) in western Oregon. As part of this project, ICF quickly and efficiently integrated CommentWorks^® with an existing Web-based project forum that had already been employed to collect public comments electronically. ICF transferred these materials seamlessly into CommentWorks^® for in-depth analysis, filtered out redundant form letters, sorted substantive comments into issue categories, and prepared cogent summaries. The Interdisciplinary Team leader for this project called ICF's performance "magnitudes better than what we have ever received from a contractor."

Handle All Comment Management Needs at the Enterprise Level

• NEPA and Resource Management Planning Projects

The Bureau of Land Management has selected CommentWorks^® as a critical component of its "ePlanning" software, which is currently under development to support resource management and National Environmental Policy Act (NEPA) activities throughout BLM as part of an effort to incorporate information technologies into business practices. CommentWorks^® allows BLM planning teams to review and parse public submissions, categorize and group comment excerpts, write summary statements and responses, and manage the volume of "form" letters submitted by the public. Though deployment of ePlanning and CommentWorks^® to date has been limited, BLM has already reported significant measurable time savings from using CommentWorks^® to manage protests on numerous RMP/EISs.

• Rulemakings and Other Initiatives

Since 2004, the Federal Trade Commission has tasked ICF to manage nearly every aspect of FTC's public comment management and analysis efforts—from initial collection and tracking of comments on nearly 200 different initiatives, to detailed analysis, summarization, and reporting on a handful of FTC rules that prompted strong public feedback. On this enterprise-level support, FTC has received more than 38,000 comment submissions to date through ICF’s customized public comment Web forms on rulemakings, notices, workshops, consent agreements, and other proceedings related to the national "Do Not Call" list, spam e-mails, credit reporting, identify theft, wholesale gasoline pricing, and other topics. This support ranges from just a handful of comments on some proceedings to tens of thousands on others.

Increase Transparency and Accountability

Under significant time pressure to address contentious issues regarding the so-called Plan B "morning after" emergency contraception pill, the U.S. Food and Drug Administration tasked ICF to review 18,000 unique comments (i.e., non-form letters) that FDA received on this topic and analyze them using our CommentWorks^® software. Throughout the project, FDA staff had ongoing on-line access to run reports from CommentWorks^® that tallied the number of comments on each issue, listed the commenters by the issues they addressed, and sorted substantive excerpts by issue so that subject matter experts could focus on the content about which they care most. To make its efforts more transparent to the public, FDA published ICF's timely and comprehensive analytical reports from CommentWorks^® directly on its Web site for public review.

Collaborate with Staff from Multiple Organizations and Locations

Because it is a Web-based solution, CommentWorks^® is easily accessible by staff from different organizations and locations working from the office, at home, or on the road. For example, the Nuclear Regulatory Commission, three other cooperating federal agencies, and seven contractor firms—comprising a team of more than 100 staff sprinkled across 10 states—jointly used CommentWorks^® to rapidly address comments on a draft environmental impact statement related to the storage of spent nuclear fuel. NRC managers used CommentWorks^® to assign responsibilities for each agency or contractor and to track efforts at every stage in the process.

Encourage More Substantive and Focused Comments

Many clients already have multiple means of collecting public comments (e.g., via Web site, standard mail, fax). However, in most cases, these methods allow the commenter to submit feedback in an unstructured and unfocused way, complicating the job of analyzing these materials. To avoid this problem on a project involving the review of draft emergency support function (ESF) procedures, FEMA asked ICF to deploy an advanced CommentWorks^® Web form through which stakeholders were allowed to review individual sections of the draft ESF document and link their comments to each individual section. This approach greatly reduced the time required for FEMA to sift through and sort the feedback they received. Through the use of this advanced Web form, FEMA was able to generate reports of stakeholder comments that were "pre-coded" to each section in the ESF document as soon as these comments were submitted by commenters.