{"id":{"repo_id":"vt","oai_identifier":"oai:vtechworks.lib.vt.edu:10919/25804"},"canonical_url":"https://search.dev.ndltd.org/etd/vt/oai:vtechworks.lib.vt.edu:10919/25804","repository":{"repo_id":"vt","name":"Virginia Tech","base_url":"https://vtechworks.lib.vt.edu/oai/request"},"display":{"title":"Comparing Apples: Predicting the effect of public comments on administrative rules","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.","abstract_html":"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.","abstract_has_math":false,"creators":["Yavorosky, Bart Mykolas"],"institution":"Virginia Tech","degree_name":"Ph. D.","degree_level":"doctoral","degree_discipline":"Planning, Governance, and Globalization","degree_department":"School of Public and International Affairs","school":null,"contributors":[],"advisors":[],"committee_chairs":["Stephenson, Max O. 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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."]},{"key":"dc:description.degree","label":"Dc Description Degree","values":["Ph. D."]},{"key":"dc:format.medium","label":"Dc Format Medium","values":["ETD"]},{"key":"dc:title","label":"Title","values":["Comparing Apples: Predicting the effect of public comments on administrative rules"]}]}],"canonical_facts":{"dc:contributor.committeechair":["Stephenson, Max O. 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