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Decisions_timing.md

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Displaying submissions after the consultation period

Regulations.gov displays comments during the consultation period. This creates a set of behaviours that run counter to the spirit of the consultation, which are outlined below. The alternative, which has been in place at the Canadian Nuclear Safety Commission for many years now, is to display all submissions at the end of the primary consultation period.

In addition the CNSC provides a second short feedback period in which people can respond to submissions from the primary consultation period. This prevents the comment-on-comments feedback loops that are possible in comment forums, that are very difficult to analyze and enable social-media style hate behaviours.

  • Note that this feedback consultation period will not be available in Pilot2, but should be considered for a later iteration.

Waiting to display comments disrupts suboptimal behaviours

  • Most organizations already wait to submit comments in the final day(s) of the consultation period - we believe that to avoid "showing their hand" or provoking submissions responding to their comments and thus engendering a cycle of submissions, people would wait even longer, to submit in the final minutes of the consultation period.
    • Waiting circumvents this - people are free to submit when they like rather than feeling pressured by the deadline
  • Showing comments during the period may create mistaken impressions that a particular view isn't being supported when in fact, they simply don't have their submission ready
    • Waiting ensures that all voices/views are heard together - that the balance is visible
  • There is more incentive to troll and spam when comments are displayed fairly quickly, even when moderated
    • Waiting reduces the incentive to troll and spam - trolls aren't big on delayed gratification

Waiting also has advantages for the regulatory team

  • Waiting reduces the moderation time pressure for regulatory teams. Moderating is usually expected to take place within hours - this provides an opportunity to moderate comment submissions within the consultation period and within a defined time frame afterwards.
  • Gives the team more opportunity to identify and tag form letters - so they can be displayed as a group (note this tagging and filtering capability will not be available in Pilot2)