Responsive to What? Mapping and Explaining the Information Quality of Public Comments on Bureaucratic Policymaking Using a Text-as-Data Approach.

A precondition for bureaucratic responsiveness is that stakeholders provide policymakers useful information allowing them to fruitfully engage in problem-solving and policy formulation. A key mechanism facilitating this information transmission is the public commenting on bureaucratic rulemaking. While these comments improve the procedural legitimacy and reputation of bureaucratic policymaking, important questions remain over the extent to which public comments meet the informational needs for expertise and evidence-based policymaking that underpin bureaucratic decision-making. We therefore ask: under what conditions are stakeholders more likely to provide public comments that score high in information quality, and successfully meet the informational needs of bureaucratic policymaking? We develop a conceptual framework that recognises the multi-dimensional nature of information quality of public comments as policy inputs and captures their textual sophistication, tone and position taking. We elaborate an argument emphasizing the importance of institutional and policy context in explaining the variation in observed levels of information quality of public comments. We test our argument on a novel dataset containing 20,769 stakeholder comments on 1,037 bureaucratic acts issued by the European Commission between 2016-2019, across all policy areas and policy formulation stages. We contribute to the study of access, agenda and policy responsiveness in Europe and beyond.