Summary and Analysis of Comments

PAI has developed electronic databases for summarizing comments on advance notices of proposed rulemaking, notices of proposed rulemaking, supplemental notices of proposed rulemaking, interim final rules, regulatory reviews, exemptions, and other regulatory notices.  

Each of PAI’s databases facilitates trend analysis and retrieval of industry and commenter concerns, and functions as an efficient and reliable means of summarizing comments.  PAI has used such databases for rulemaking projects, receiving as many as 30,000 comments and as few as 100 comments.  Each database is tailored to the particular project and includes fields such as commenter name, commenter affiliation, a summary of the comment, and commenter recommendations related to individual issues or specific section numbers.  These databases allow PAI to sort the collected data and form numerous reports, including graphs and charts according to each requesting agency’s needs.

PAI then analyzes the public comments and organizes them in a manner that allows the agency to easily address and respond to the comments in the final rule.  In addition, based on agency guidance, PAI has drafted the agency response to the comments for publication in the final rule.