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ERIC Number: EJ833313
Record Type: Journal
Publication Date: 2009
Pages: 20
Abstractor: As Provided
Reference Count: 45
ISSN: ISSN-0276-8739
Understanding Commenter Influence during Agency Rule Development
Naughton, Keith; Schmid, Celeste; Yackee, Susan Webb; Zhan, Xueyong
Journal of Policy Analysis and Management, v28 n2 p258-277 Spr 2009
We provide the first empirical assessment of commenter influence during the rule development stage of administrative rulemaking. We argue that public commenters play a critical agenda-setting role during rule development. To test this proposition, we analyze data from 36 Department of Transportation rules and almost 500 comments. Each of these rules began with an Advance Notice of Proposed Rulemaking--a procedure that allows us to track the formal participation of interested parties during rule development. Our analyses are supplemented by face-to-face interviews with agency officials. We find a strong agenda-setting role for early commenters--both in terms of affecting the content of future regulations and in thwarting unwanted regulations. We conclude that "early-bird" commenters are well positioned to frame public policy debates as rules move through the regulatory process. (Contains 2 tables and 14 footnotes.)
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Publication Type: Journal Articles; Reports - Evaluative
Education Level: N/A
Audience: N/A
Language: English
Sponsor: N/A
Authoring Institution: N/A