Interest Groups in the Rule-Making Process: Who Participates? Whose Voices Get Heard?

This article addresses three questions about notice and comment rule making. The first considers who participates: Who submits comments to federal agencies during the notice and comment period? The second considers the extent to which the comments alter the content of the rules. The third is about evaluating agency rule making in the context of the iron triangle and issue network models of policy making. The article examines eleven rules selected randomly at the EPA, NHTSA, and HUD. Among the findings are: a dearth of citizen commenters, the predominance of participation by business interests, and the presence of issue networks, and the absence of any discernible bias in whose voices get heard. The article concludes by suggesting that agencies fail to hear from all affected parties but that they are nonetheless put in the precarious position of arbitrating among competing interests.