Sweet-Talking the Fourth Branch: The Influence of Interest Group Comments on Federal Agency Rulemaking

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Abstract
Students of politics have identified a variety of actors who appear to influence the federal bureaucracy's implementation of public policy, including Congress, the president, and interest groups. These lines of research, however, have often portrayed interest groups as actors with indirect influence (who, for example, work through or with Congress), rather than assessing the direct influence of interest groups on bureaucratic policy outputs. I conduct a test of direct interest group influence by analyzing an original data set composed of 1,444 interest group comments in reaction to forty federal agency rules. I find, contrary to the expectations of the extant literature, that the formal participation of interest groups during rulemaking can, and often does, alter the content of policy within the “fourth branch” of government. I conclude that those who voice their preferences during the notice and comment period rulemaking are often able to change government policy outputs to better match their preferences.