Comparing Apples: Predicting the effect of public comments on administrative rules
| dc.contributor.author | Yavorosky, Bart Mykolas | en |
| dc.contributor.committeechair | Stephenson, Max O. Jr. | en |
| dc.contributor.committeemember | Medina, Dennis Xavier | en |
| dc.contributor.committeemember | Luke, Timothy W. | en |
| dc.contributor.committeemember | Khademian, Anne M. | en |
| dc.contributor.department | School of Public and International Affairs | en |
| dc.date.accessioned | 2014-03-05T09:00:24Z | en |
| dc.date.available | 2014-03-05T09:00:24Z | en |
| dc.date.issued | 2014-03-04 | en |
| dc.description.abstract | This dissertation addresses three questions about administrative rulemaking: • Do comments submitted on proposed rules vary in identifiable ways? • Do these differences directly relate to the likelihood that recommendations will be associated with changes to regulations? • Can these characteristics be incorporated into a model that accurately predicts whether or not suggestions will coincide with changes to administrative rules? Using data collected from the Commonwealth of Virginia's Regulatory Town Hall, I analyze 2,534 comments that address 67 regulations proposed by state agencies during an 11-year period. I find that submissions do differ in meaningful ways. I also find statistically significant evidence that those differences are related to the probability that a requested change coincides with a subsequent modification to a rule. The principal result of this research is a model that predicts with a high degree of accuracy the outcome of participants' recommendations to alter proposed regulations. I also demonstrate the implications of these results and how failure to account for these differences undermines the legitimacy of conclusions that can be drawn from studies of notice-and-comment rulemaking. The primary contribution of this dissertation is methodological, but the empirical evidence presented here also raises questions about the value of citizen participation in notice-and-comment rulemaking in its current form. As a result, it challenges contentions that participation contributes to the democratic legitimacy of bureaucracy, serves as a safeguard against the influences of organized interests, or improves the substantive quality of administrative decisions. | en |
| dc.description.degree | Ph. D. | en |
| dc.format.medium | ETD | en |
| dc.identifier.other | vt_gsexam:2227 | en |
| dc.identifier.uri | http://hdl.handle.net/10919/25804 | en |
| dc.publisher | Virginia Tech | en |
| dc.rights | In Copyright | en |
| dc.rights.uri | http://rightsstatements.org/vocab/InC/1.0/ | en |
| dc.subject | administrative rulemaking | en |
| dc.subject | notice-and-comment | en |
| dc.subject | public administration | en |
| dc.subject | bureaucracy | en |
| dc.subject | public participation | en |
| dc.title | Comparing Apples: Predicting the effect of public comments on administrative rules | en |
| dc.type | Dissertation | en |
| thesis.degree.discipline | Planning, Governance, and Globalization | en |
| thesis.degree.grantor | Virginia Polytechnic Institute and State University | en |
| thesis.degree.level | doctoral | en |
| thesis.degree.name | Ph. D. | en |