Consultation as Policymaking Innovation: Comparing Government Transparency and Public Participation in China and the United States

June 4, 2020

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This article compares government transparency and public participation in policymaking across China and the United States. The analysis specifically focuses on the notice and comment process—government announcement of proposed policies and solicitation of public feedback—at the Chinese Ministry of Commerce (MOC) and U.S. Environmental Protection Agency (EPA). The MOC and EPA are leading organizations in the implementation of such consultation in their respective countries. Information is collected and coded for hundreds of draft regulations and thousands of public comments that occurred during the 2002–2016 period. Statistical analysis of levels of, and variation in, transparency and participation demonstrates both similarities and differences in the operation of the notice and comment process at the MOC and EPA. Transparency and participation are generally lower at the MOC than in EPA consultations. Within such constraints, however, there is evidence of standardization in the administration of consultation by the MOC. These findings suggest that differences in the Chinese and U.S. political systems, rather than issues of administrative capacity, are the primary limitations of consultation as a policymaking innovation in contemporary China.