Association for Public Policy Analysis & Management

Although mass comment campaigns are common occurrences in contemporary agency rulemaking in the United States, little is known about the efficacy of campaigns with respect to rulemaking processes and outcomes. This paper addresses this issue by analyzing the role played by more than 1,000 mass comment campaigns that occurred during EPA rulemakings between 2012 and 2016. The research entails coding the content of mass comment campaigns, other comments, proposed and final rules, and agency responses to comments. Through these original data, the article generates insight into two specific aspects of the operation of mass comment campaigns in EPA rulemaking during the period under analysis. First, in what manner does the EPA explicitly respond to mass comment campaigns? Second, is there an association between mass comment campaigns and the substance of EPA rules? Given data limitations, the paper does not provide definitive evidence of the direct influence of mass comment campaigns on the content of EPA regulations. Rather, the analysis focuses on EPA processes (i.e., the handling of mass comment campaigns) and patterns in outcomes (i.e., the consistency of campaigns with final rules).