Frames of Influence: U.S. Environmental Rulemaking Case Studies

The purpose of this article was to question whether interest group actions during the pre-proposal stage of U.S. federal rulemaking influences the language proposed in natural resource agency rules. The influence of interest groups during this stage was examined across three case studies: (1) the United States Fish and Wildlife Service (USFWS) critical habitat designation for Nebraska's Salt Creek tiger beetle, (2) the USFWS critical habitat designation for the Utah/Arizona Shivwits and Holmgren milk vetch, and (3) the USFWS delisting of the Northern Rocky Mountain gray wolf population from the endangered species list. To analyze these three cases, a frame analysis approach is used and offers evidence to support the proposition that the instructive, expertise, and fiscal feasibility frames that stakeholders used during the pre-proposal stage can shape the language of a Notice of Proposed Rulemaking. These cases suggest the rich potential for careful study of the earliest stages in the regulatory and administrative rulemaking process in the United States and beyond.