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Partisan Commenting: Evidence from State and Local Government Involvement in Federal Rulemaking

Maria Silfa, Postdoctoral Scholar at Stanford Graduate School of Business
Encina Hall West, Room 400

When do state and local governments comment on federal rules? While scholars note that subnational governments and politicians comment on federal regulations, we know very little about the conditions under which these actors prioritize this action. We argue that participation in the notice-and-comment period by state and local governments depends on partisan misalignment with the president. Using data from the Environmental Protection Agency, we demonstrate that extensive communication occurs between state, local, and federal actors in the realm of federal rulemaking, and these interactions are more likely to occur when there is partisan disagreement between levels of government. Our findings provide evidence for the motivations behind the participation of actors who largely carry out the directives of the federal bureaucracy.


Maria Silfa is a political scientist studying American politics with a focus on interest groups and bureaucratic politics. Her current work explores how business interests interact with the bureaucracy at different stages of the rulemaking process. She received her Ph.D. in Political Science from the University of Rochester in 2022 and was a Postdoctoral Research Associate at the Center for the Study of Democratic Politics at Princeton University in 2022-2023. During the 2023-2024 academic year, she will be a Postdoctoral Scholar at the Stanford Graduate School of Business.