Feedback: Waiting for the deluge

From the abstract to a recent article.

In this research, we assess whether the number of public comments filed in response to proposed agency rules has dramatically increased as a result of the automation of the submission process. Specifically, we compare the volume of comment activity across two large sets of rules issued by the Department of Transportation, one that occurred before the launch of an agency-wide electronic docket system and another that occurred after this launch in 1998. Our analysis shows that, contrary to expectations held by many researchers and practitioners, the overall levels and patterns of stakeholder behavior showed a remarkable degree of similarity across the two periods. This finding implies that public involvement in rulemaking is not likely to become vastly more prevalent in the information age, confounding both hopes of democratization of the process and fears of costly and harmful mass participation.

Hypothesis: it takes a certain kind of irrationality to provide feedback to a government department, or even to complain. You’re unlikely to be listened to, you spend a lot of your time – and others’ and the best you can expect is to have your problem fixed and/or a bit of cash. But this is hard and uncertain work. In our recent report (pdf) we documented the fact that it’s been years negotiating with the privacy commissioner to finesse a particularly silly requirement for mortgage brokers to remove tax file numbers from tax returns when sending them to banks (it’s a complicated story but trust me it’s stupid or if you don’t trust me search for TFN in the report). And nothing has happened.

If the hypothesis is correct, lowering the barriers to comment making still doesn’t change things that much because guess what? People still know that no-one’s listening. I recall having a conversation with a quite senior person in an economic policy inquiry agency and made a suggestion about an inquiry his agency was involved in. He said he thought it was an interesting idea and that I should, if I wanted make a submission. I’m afraid when I’m told to put such things in writing, I don’t. A bit of a case of Gresham’s Law I’m afraid. Being asked to put something in writing is very often a sign that the recipient is process based and unlikely to be interested in your comments.

This is just the issue that I’ve raised in my feedback posts. When the idea of listening to a firms’ customers took off as a kind of mantra in the 70s and 80s, lots of firms would have said that they did that. But as the pioneers of TQM style management discovered, generating a rich culture of feedback involves much more than simply inviting it. People are reluctant to give it if they think it’s a waste of time.

And this is one of the underpinnings of the strength of open-source software. It is feedback rich software. There’s no point in complaining about it. Let someone know if you’ve got a problem, if they don’t fix the problem, fix it yourself and then send it into the project to get it integrated into the project.

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Stephen Bounds
Stephen Bounds
16 years ago

Nicholas, I like your line about needing “a certain kind of irrationality to provide feedback to a government department”.

I work on the theory that government departments naturally have a large amount of inertia due to their sheer size. It takes a big push to get them moving, and small changes can be almost impossible to make unless they are “obviously” an improvement.

Mind you, I don’t necessarily see that as a bad thing. It means that you can’t just trot in with a half-baked idea and have it implemented.

Kevin Cox
Kevin Cox
16 years ago


I love the idea of “open source” regulations. It would lead to fewer but better regulations.