Early-bird CIO Commenters Better Positioned to Help Frame Public Policy

Digital Communities task force members are active in addressing communication, broadband and other policy issues at the national level. The reassignment of 700MHz radio spectrum for use by public safety, for instance, was an issue where CIOs from many of the larger cities and counties made their own recommendations. As well, they jointly issued a Digital Communities Task Force memo urging that a significant portion of the 700MHz spectrum not be auctioned off to private interests, but rather be licensed directly to local public safety entities who could use it to build a truly interoperable national voice and data network.

More recently, a number of cities have weighed in during the comments period on how Broadband stimulus money should best be utilized.

But how effective are such efforts? Is there a way to improve local CIO participation in federal comment processes?

A new study in the Journal of Policy Analysis and Management makes the case that public commenters who participate during the early phases of regulatory policymaking play an important agenda setting role. Results suggest that these "public" participants-who are often interest groups-can help shape the content of regulatory proposals as they move through the regulatory process and may thwart unwanted regulations.

In conducting the research, Keith Naughton and Celeste Schmid of the University of Southern California, Susan Webb Yackee of the University of Wisconsin-Madison, and Xueyong Zhan of Shanghai University of Finance and Economics analyzed data from 36 Department of Transportation rules and almost 500 comments.

They found what they say is the first systematic quantitative evidence of the importance of early participation in regulatory development. Commenters who participate early enough in the process do influence the regulatory direction of the policymaking process, they ascertained.

"This research suggests the great need for additional systematic knowledge regarding the politics of regulatory development and rulemaking," the authors conclude in the article.