Authors:

Stephanie Bouserhal

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About Paper:

When a federal agency plans to create or revise a policy, it will publish an initial draft known as an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public feedback. This research analyzes public comments to the Federal Transit Administration (FTA) regarding Docket FTA-2011-0056, which was a proposal to reform their Environmental Impact Statement (EIS) requirements and categorical exclusions in transit/transportation projects. The study evaluates the relative success of government-affiliated comments compared to those submitted by non-governmental entities, and measures the difference that the volume of comments makes. | hypothesize that collective mobilization, measured by comment volume, will be a stronger predictor of rule adoption than the institutional identity of commenters. This evaluation was conducted using a pre-established standardized coding framework. Each comment was grouped into coalitions based on shared policy requests. Comments were then coded according to their position on the ANPRM and the extent to which its asks were tangibly reflected in the final rule. To empirically compare influence of commenters in the rulemaking process, | modeled adoption rate as a function of actor type and comment volume. Non-government comments had a raw adoption rate of 58.7%, while the government comments raw adoption rate was 53.3%. However, when the volume of comments was factored into the success rate, regression analysis shows that the difference is negligible. Rather, comment volume was the strongest predictor of regulatory success (B=0.55, p < 0.001). These findings suggest that the level of organization and participation drives changes in FTA rulemaking more than the actor type behind the comment.

Source:

Chicago Area Undergraduate Research Symposium

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No topics listed

Co-authors:

Stephanie Bouserhal