Do public comments make a difference in open rulemaking? Insights from information management using machine learning and QCA analysis

Scholars still have a mixed picture of the impact of online public involvement in regulatory policy making, and a shortage of theoretical explanations. The novel theory put forward in this article is that substantive, technical and political factors combined can help explain the degree of success public involvement will have in shaping proposed rules. Using a study with 25 regulations from the United States Department of Education, Latent Dirichlet Allocation (LDA) measures the degree of content change between proposed rules and final rules. Substantive and political aspects in democratic legitimacy and pluralism approaches to participation, antecedents are theorized, and associations of the antecedents with the degree of content change are assessed using Qualitative Comparative Analysis (QCA). Findings show that the substantive public contributions do make a difference especially when media attention and input from professional organizations is present.