ED Settles on Less Ambitious Overhaul of Borrower Defense
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Are Agencies Responsive To Mass Comment Campaigns?
In this age of clicktivism, federal agencies sometimes receive a large number of public comments during rulemaking. High-profile rules such as greenhouse gas emissions and Restoring Internet Freedom garnered millions of public comments. Advocacy organizations orchestrate campaigns to encourage politically conscious citizens to send letters in favor or against proposed regulations.
This article examines the sponsorship and content of mass comment campaigns in administrative rulemaking in the United States. Mass comment campaigns consist of identical and near‐duplicate comments sponsored by organizations and submitted by group members and supporters to government agencies in response to proposed rules. Drawing from research on interest group lobbying, it is posited that organizations of all types sponsor mass comment campaigns, but that campaigns submitted by regulated entities (i.e., industries) are more substantive than campaigns generated by beneficiaries of stringent regulations (e.g., environmental advocacy groups).
Dynamic Benefit-Cost Analysis for Uncertain Futures
The diverse policy decisions confronting decision-makers today demand “dynamic BCA,” analytic frameworks that incorporate uncertainties and trade-offs across policy areas, recognizing that: perceptions of risks can be uninformed, misinformed, or inaccurate; risk characterization can suffer from ambiguity; and experts’ tendency to focus on one risk at a time may blind policymakers to important trade-offs.