Is That a Threat? How Types of Stakeholder and Reputational Threat Matter for Gaining Influence in Regulatory Rulemaking

This paper assesses what type of comments are most useful to what type of stakeholder in gaining influence during public consultations. Theoretically, the paper approaches stakeholders' consultation comments as reputational threats from key audiences that the agency needs to respond to. Different types of threats are expected to carry different weights depending on the type of stakeholders. The analysis is based on a dataset of 73,283 consultation comments left by stakeholders in EASA rulemaking consultations. The findings indicate that it matters what interests pose what kind of threat in regulatory rulemaking. Certain group types become more influential while others lose out when making specific kinds of threats. This extends our understanding of how stakeholders gain influence and what reputational threats are seen as credible by regulatory agencies.