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Lost in the flood?: Agency responsiveness to mass comment campaigns in administrative rulemaking


  • Steven J. Balla
  • Alexander R. Beck
  • Elizabeth Meehan
  • Aryamala Prasad


This article examines agency responsiveness to mass comment campaigns – collections of identical and near‐duplicate comments sponsored by organizations and submitted by group members and supporters – in administrative rulemaking in the United States. Focusing on 1,049 mass comment campaigns that occurred during 22 Environmental Protection Agency rulemakings between 2012 and 2017, the article develops and assesses expectations regarding responsiveness to campaigns relative to comments submitted outside of campaigns. The analysis demonstrates that, procedurally, the agency references mass comment campaigns in its responses to comments, but cites campaigns at lower rates than other comments. In terms of outcomes, the agency's regulations are generally not consistent with changes requested in comments, a lack of association that holds especially for mass comment campaigns. These patterns suggest that legal imperatives trump political considerations in conditioning agency responsiveness, given that mass comment campaigns – relative to other comments – generally contain little “relevant matter.”

Suggested Citation

  • Steven J. Balla & Alexander R. Beck & Elizabeth Meehan & Aryamala Prasad, 2022. "Lost in the flood?: Agency responsiveness to mass comment campaigns in administrative rulemaking," Regulation & Governance, John Wiley & Sons, vol. 16(1), pages 293-308, January.
  • Handle: RePEc:wly:reggov:v:16:y:2022:i:1:p:293-308
    DOI: 10.1111/rego.12318

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    References listed on IDEAS

    1. Keith Naughton & Celeste Schmid & Susan Webb Yackee & Xueyong Zhan, 2009. "Understanding commenter influence during agency rule development," Journal of Policy Analysis and Management, John Wiley & Sons, Ltd., vol. 28(2), pages 258-277.
    2. Hibbing, John R., 2001. "Process Preferences and American Politics: What the People Want Government to Be," American Political Science Review, Cambridge University Press, vol. 95(1), pages 145-153, March.
    3. Papke, Leslie E & Wooldridge, Jeffrey M, 1996. "Econometric Methods for Fractional Response Variables with an Application to 401(K) Plan Participation Rates," Journal of Applied Econometrics, John Wiley & Sons, Ltd., vol. 11(6), pages 619-632, Nov.-Dec..
    4. Stuart Shulman, 2003. "An experiment in digital government at the United States National Organic Program," Agriculture and Human Values, Springer;The Agriculture, Food, & Human Values Society (AFHVS), vol. 20(3), pages 253-265, September.
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    1. Alena V. Pivavarava & Christel Koop, 2023. "The adoption of digital practices by economic regulators: mapping digital pathways for consumer e-participation," Economics Series Working Papers 1013, University of Oxford, Department of Economics.
    2. Cory L. Struthers & Kathryn J. Murenbeeld & Matthew A. Williamson, 2023. "Environmental impact assessments not the main barrier to timely forest management in the United States," Nature Sustainability, Nature, vol. 6(12), pages 1542-1546, December.

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