Diverse Lobbying Coalitions and Influence in Notice-and-Comment Rulemaking

Many studies have identified a line of influence between interest group lobbying and the federal bureaucracy’s implementation of public policy. These works, however, have often focused on the influence of individual groups rather than coalitional efforts, which compose the majority of lobbying. Assessing this activity is critical to understanding the role of public participants in administrative policymaking. I test the influence of diverse coalitions of interest groups on bureaucratic policy outputs by analyzing a new dataset of organizations’ co-signed public comments across nearly 350 federal agency rules proposed between 2005 and 2015. I find that agencies favor recommendations from organizationally diverse coalitions, and not coalitions that are bipartisan or dominated by business interests. Further, I find that coalition influence is heightened when lobbying in coalitions that are larger in size and more well-resourced, and when policy salience is low. I conclude that diverse lobbying coalitions help bureaucrats to shape the direction and content of regulatory law. This conclusion further establishes the role of organizational participants in bureaucratic policymaking and contributes to the debate over democratic legitimacy in the administrative state.