Abstract
Scholars have identified that interest groups can be most influential on regulatory outcomes during the preproposal stage of the rulemaking process, yet this stage is notoriously understudied. Recently, Rinfret concluded that interest groups use three frames (expertise, fiscal feasibility and instructive) to influence agency personnel at the United States Fish and Wildlife Service. Of the three, the expertise frame was considered most effective. This work confirms these findings across three more significant rulemakings at the United States Environmental Protection Agency (USEPA) and builds on Rinfret's framework in two ways. First, this analysis adds a relevant fourth frame to the model, the legal frame. Second, this research addresses why interest groups use all four frames, when the expertise frame is considered most impactful. Simply stated, interest groups use each frame to complement the expertise frame and build a coherent story that justifies their preferred solution. Thus, understanding how interest groups use each of the four frames can inform our understanding of why two groups that both use the expertise frame may have varying impacts on the agency.
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