research articles

Designing Bureaucratic Responsiveness:

Administrative Procedures and Agency Choice
in State Environmental Policy
Matthew Potoski, Iowa State University

abstract
Elected politicians can manage government agencies using administrative procedures
that either enhance agencies’ political responsiveness or their autonomy. Rational
politicians will delegate autonomy when the benefits of agency decision-making are
high, such as when the policy problem is technically complex. This article tests this
hypothesis by investigating how state politicians design the institutional features of
state clean air agencies and how these agencies perform under different administra-
tive procedure regimes. I find that when a state’s air pollution problem is complex,
politicians eschew administrative procedures that enhance political control, and these
agencies respond by choosing policies from a broader range of options.

The rise of large government programs has led many scholars and citizens
to worry that government bureaucracies lie beyond the reach of democratic
accountability (Mayhew 1974). However, elected politicians may be able to
manage their relations with bureaucratic agencies through the administrative
procedures under which these agencies make policy decisions. Politicians may
grant agencies autonomy by designing procedures that provide a broad range
of policy options for the agency, or they may enhance agency responsiveness
by limiting the range of permissible policy choices. This article examines
both sides of this delegation process by modeling both politicians’ delegation
decisions and bureaucratic policy choice. I evaluate my model by examining
state air pollution control agencies in the United States.
This study sheds light on how institutional arrangements shape bureau-
cratic behavior. Previous research has shown that government agencies can be
both politically responsive (Weingast and Moran 1983; Wood and Waterman
1994) and politically autonomous (Balla 1998; Krause 1996), but no one has
yet explained why these agencies are sometimes politically responsive and
other times politically autonomous. While administrative procedure theory
State Politics and Policy Quarterly, Vol. 2, No. 1 (Spring 2002): pp. 1–23

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2 potoski

offers to resolve this dilemma (Bawn 1995; McCubbins, Noll, and Weingast
1987, 1989), it has not yet received much empirical scrutiny.
In this article, I explore both the causes and consequences of the rules
that politicians use to structure agency behavior (Epstein and O’Halloran
1999). First, I examine how elected politicians, acting under the constraints
of the political control-expertise tradeoff, use institutional arrangements to
regulate agencies’ autonomy. I hypothesize that politicians grant bureaucrats
more autonomy when bureaucratic expertise is more valuable (i.e., when the
policy problem is more complex) and constrains bureaucratic autonomy
when the politicians themselves have more policy expertise (Bawn 1995;
Epstein and O’Halloran 1999). Second, I investigate how these institutional
arrangements shape agencies’ political responsiveness and autonomy. Au-
tonomous agencies have a broader range of options from which to select
policy than politically responsive agencies (Bawn 1995). Thus, I hypothesize
that the policy choices of autonomous agencies are more variable than those
of politically-controlled agencies. My analyses suggest that indeed agencies
enjoy autonomy when politicians design them to capitalize on the agencies’
superior policy expertise. This insight may prompt a re-evaluation of the
normative standards for evaluating bureaucratic policy performance.

the political influence and autonomy

of government agencies
Recent research shows that government agencies can be both politically re-
sponsive (Weingast and Moran 1983; Wood and Waterman 1994), and politi-
cally autonomous (Balla 1998), even to the point of influencing their political
overseers (Krause 1996).1 This line of scholarship has brought sophisticated
statistical techniques to bear on vast amounts of data from a variety of agen-
cies and policy contexts. A common analytic strategy in these studies has
been to correlate changes in agencies’ policy choices with events involving the
agencies’ political principals (e.g., congress or the president) or from within
the agency itself (Wood and Waterman 1994). In this strategy, autonomy
occurs when an agency’s policy activities are associated with changes that
occur within the agency. If an agency’s policy choices are found to be asso-
ciated with events regarding its political principals, the agency is said to be
politically responsive. However, validly distinguishing external from internal
causes of agencies’ policy choices is often quite difficult. For example, since
politicians can influence bureaucrats’ policy preferences (e.g., via political
appointments), a policy choice that appears to reflect bureaucratic discre-
tion (e.g., an agency’s policy choice reflects bureaucratic preferences) may in
fact be political responsiveness. In this case, the agency’s policy choices may

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 spring 2002 / state politics and policy quarterly 3

be perfectly responsive to politicians’ preferences, as conveyed through the

politicians’ choice of political appointees. Furthermore, testing hypotheses
about the causal origin of agency policy choices usually requires measure-
ment techniques developed specifically for the case under investigation that
are not applicable across different agencies. Such methodological problems
have hurt efforts to cross-fertilize findings among research programs.
Positive political theory may help explain these disparate empirical re-
search findings by suggesting how politicians use administrative procedures
to manage their relations with agencies (for a review, see Huber and Shipan
2000). Politicians can influence agencies ex ante through the amount of au-
thority they delegate to agencies and the rules under which agencies exercise
this delegated authority.2 Administrative procedures are the rules politi-
cians place on how agencies develop, implement, and enforce policies. These
procedures can make agencies more or less autonomous, forcing them to
focus their policy decisions more or less closely on the political interests that
legislators and the governor favor. For example, politicians might require
that an environmental protection agency consult with pro-environmental
groups before making policy decisions, thus increasing the likelihood that
these decisions will favor the environment (McCubbins, Noll, and Weingast
1987, 1989; Bawn 1995). Another perspective on the purpose of administra-
tive procedures is that they improve politicians’ ability to make sound policy
(Moe 1989). From this perspective, politicians cause agency autonomy and
responsiveness to vary, depending on the distribution of expertise among
politicians and agency officials. When policy decisions require significant
expertise that only agency officials have, politicians may delegate more deci-
sion-making autonomy to them.3
Some positive theories define agency discretion as the range or distri-
bution of options from which an agency can select policy (Bawn 1995), a
somewhat different approach than identifying the ultimate internal or exter-
nal cause of an agency’s policy decisions. Under this definition, politicians
delegate discretion by granting agencies a broader range of options from
which to select a policy and restrict agency discretion by specifying a nar-
rower range of policy options. From this specified range, an agency chooses
a specific policy in response to a broad variety of stimuli, including its own
preferences and external pressures from interest groups, the courts, and so
on.
Despite their resonance with some scholars and practitioners, the accu-
racy of positive administrative procedure theory has been called into question
by studies finding that administrative procedures are not effective in limiting
agency autonomy (Balla 1998; Spence 1997, 1999; Hamilton 1996; Hamilton
and Schroder 1994). Consequently, whether variation in administrative pro-

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cedures and other bureaucratic institutions can account for the conflicting
political control-autonomy research findings remains an open question.
More broadly, there exists no empirically tractable theory that accounts for
both politicians’ delegation decisions and agencies’ policy decision-making
under delegated autonomy. I develop such a model in the next section.

theory
Before laying out my model in detail, I illustrate the central theoretical issue
at stake in this article in the context of state air pollution policy. Legisla-
tors in states with simple air pollution problems and professional legislative
institutions (e.g., more staff, longer sessions, higher pay—see Bowman and
Kearny 1988) are better able to enact satisfactory environmental regulations
and instructions for how their agencies should implement them, and they
can monitor these agencies more effectively to improve political respon-
siveness. These legislators may have access to adequate technical expertise
on this subject, particularly when the pollution problem is simple. On the
other hand, legislators in states with more complex air pollution problems
and less professional legislatures, likely need more expert help from outside
the legislature to develop clean air policies. Consequently, these legislators
delegate more authority to their environmental protection agencies in order
to capitalize on the expertise these agencies have. Agencies in these states
may choose to adopt stringent pollution regulations, perhaps justifying their
choices on technical grounds. This policy choice might be consistent with
what the politicians would want if they knew as much as the bureaucrats.
Alternatively, these more autonomous bureaucrats may choose policy largely
to satisfy their own preferences, and the resulting regulations may be differ-
ent than those that would have been set legislatively. Because the politicians
know less about the technical features of these pollution policy problems and
their solutions, and because politicians are uncertain about the bureaucrats’
policy preferences, they delegate policy-making authority to the bureaucrats
and hope for the best.

Initial Assumptions
The key actors in my model, the elected politicians who make laws (legisla-
tors and the governor) and the bureaucrats who exercise delegated policy
authority in the agencies, are assumed to be rational optimizers constrained
by costly transactions. Developing, implementing, and enforcing policy re-
quires time, effort, and expertise. These actors also have incomplete technical
information about policy problems, such as which technologies lower pollu-

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 spring 2002 / state politics and policy quarterly 5

tion emissions at the lowest economic costs, but the bureaucrats are assumed
to have more policy technical information than politicians. Consequently,
bureaucrats can develop policies more quickly and efficiently than politi-
cians, and their policy choices are more likely to achieve their desired policy
outcomes. Furthermore, bureaucrats’ expertise advantage over politicians is
greater for more complex policy problems. Politicians may know the state of
affairs they want to achieve (e.g., a cleaner environment at minimal economic
cost) but may not know how to achieve it.
Politicians are also assumed to have imperfect knowledge about bureau-
crats’ policy preferences and activities. Therefore, they do not know to what
extent the agencies’ policy choices are the result of bureaucrats’ technical
evaluations or policy preferences. I also assume that politicians are motivated
to provide appropriate policy, perhaps because doing so improves their re-
election prospects by achieving the state of affairs the voters want (Mayhew
1974). My theory does not rely on detailed assumptions about actors’ prefer-
ences and motives. Rather, it assumes only that they are goal oriented.4

Politicians’ Delegation Decisions

Politicians have neither the resources nor the expertise to develop and imple-
ment any but the simplest policies (Epstein and O’Halloran 1999). Conse-
quently, they must delegate some policy-making authority to government
agencies. But politicians would like these agencies to make the same choices
that the politicians would make if they had the bureaucrats’ resources and
expertise. Delegating authority means agencies can apply their technical
expertise to solve policy problems, but it also gives them the opportunity to
pursue policy directions that politicians might not like.
The amount of authority that politicians are willing to delegate depends
on the value of the agency’s expertise. When a policy problem is complex,
politicians need more of the agency’s valuable expertise to solve it, and so they
are willing to delegate more authority to the agency. When politicians have
more policy expertise, or when the problem is technically simpler, agency
expertise is less valuable and politicians can set policy themselves. Thus,
politicians with more policy expertise will delegate less autonomy to agen-
cies.5 Politicians can vary the amount of policy authority they delegate to
agencies, but they do so under the constraint of this political control-agency
expertise tradeoff (Bawn 1995; Epstein and O’Halloran 1994, 1999).6
Politicians may delegate policy authority to agencies in two ways. First,
politicians may grant agencies administrative authority by legally requir-
ing them to make policy decisions. For example, politicians may direct an
agency to write air pollution regulations through the agency’s administrative

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regulations. Establishing any sort of standards for policy or process in such

legislation limits agency autonomy. Second, politicians may require agen-
cies to submit proposed policies and regulations to legislative committees,
oversight commissions, and interest groups for comment and/or approval.
(McCubbins and Schwartz 1984). Such administrative procedures improve
political control by providing politicians both information about the agen-
cies’ activities and the opportunity to take ex post corrective action.7 These
delegation approaches are not mutually exclusive. Politicians may delegate
policy responsibility but also require the agency to submit proposals for
review.

Agencies’ Policy Choices

Agencies make policy choices in response to a diverse range of internal and
external stimuli (Noll 1985; Hamilton and Schroeder 1994; Magat, Krupnick,
and Harrington 1986). External influences include political signals from
courts, interest groups, and legislative committees (Wood and Waterman
1994). Internal influences include the agency’s technical evaluation of the
policy problem and its own policy preferences (Noll 1985, Bawn 1995).
Administrative procedures structure the range of options from which agen-
cies select policy in response to these signals. The range of these policy options
reflects an agency’s discretion, as defined by legislation. Politically-controlled
agencies choose from a narrow range of policy options, as politicians seek to
maximize their control of policy. More autonomous agencies choose from a
broader range of options, with the resulting policy being more reflective of
the internal and external stimulation on the agency. Therefore, administrative
procedures structure agency behavior by altering how responsive it can be to
the various internal and external signals it receives (Bawn 1995).

Hypotheses
In this article, I evaluate three hypotheses drawn from the theory outlined
above. The first two hypotheses relate to politicians’ design of agencies and
their delegation of policy authority in the context of the political control-
expertise tradeoff:
H1: Politicians faced with more (less) complex policy problems del-
egate more (less) policy authority to the relevant agency.
H2: Politicians with more (less) access to policy expertise delegate less
(more) policy authority to the relevant agency.
Thus, politicians are hypothesized to delegate more policy authority when the
agencies’ expertise is more valuable (when the problem is complex or when

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 spring 2002 / state politics and policy quarterly 7

they lack their own policy expertise), all else being equal. The third hypothesis
relates to how delegated authority influences agencies’ policy choices:
H3: Agencies receiving more (less) delegated authority choose policies
from a broader (narrower) range of policy options.
The next section sketches the fundamentals of clean air policy in the
United States, applying the theoretical model in an important policy arena
and laying out the policy context for my paper’s research design.

clean air policy

The United States Environmental Protection Agency (U.S. EPA) sets national
criteria for states’ clean air policies, including minimum standards, the extent
of states’ enforcement programs, the financial and legal resources granted
to state clean air agencies, and so on (Lowry 1992; Rinquist 1993).8 States
submit a State Implementation Plan (SIP) to the U.S. EPA detailing how
they will meet these standards. If the U.S. EPA determines that a state’s SIP
is inadequate, it can pre-empt all or part of that state’s clean air program,
administering the failing portions itself. However, by 1998, pre-emption had
become very rare. States may exceed U.S. EPA standards, and many states
have done this (Potoski 2001). States have even more discretion on subjects
where U.S. EPA standards are silent. For example, states can choose whether
to adopt each of the various administrative procedures discussed below.9
I test my hypotheses of agency autonomy and political responsiveness
in four stationary-source air pollution policy areas: setting ambient stan-
dards, setting emissions standards, and ambient air monitoring and enforce-
ment. The U.S. EPA has established National Ambient Air Quality Standards
(NAAQS) that determine the allowable levels of six pollutants (called “criteria
pollutants”) in the air. Emissions standards govern how much pollution
sources (such as factories and power plants) are allowed to release into the
air. Tougher emissions standards are applied in areas that fail to meet ambient
air standards. The U.S. EPA’s New Source Performance Standards (NSPS)
are an important group of emission standards. States can choose to exceed
the NAAQS and NSPS by establishing more stringent standards through
legislation or administrative regulation. Ambient monitoring is the process
of operating stations that sample the air and test it for ambient air quality.
Enforcement refers to agency efforts to ensure that pollution sources comply
with emissions regulations, and pursue informal warnings, formal written
notices of violation, more severe administrative penalties and fines, and even
criminal prosecution for pollution violators.

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8 potoski

States’clean air programs provide a rich environment for studying the

politics of delegation and bureaucratic performance because of the diversity
of pollution control agencies, air pollution problems, and political contexts.
Also, the basic policy problems, programs, and activities in this area are com-
mon to other policy areas at both the state and national levels. Thus, the study
of these state clean air programs allows me to test my general hypotheses,
providing insights into political-bureaucratic relations in other venues.

research design
My research strategy has two steps. The first step is to analyze politicians’
choices about delegating policy authority under the constraints of the political
control-agency expertise trade off. In this analysis, the relevant transaction
costs are the independent variables and politicians’ choices about the amount
of delegated policy authority are the dependent variables. Evaluating hypoth-
eses H1 and H2 requires measures of the amount of policy authority delegated
to agencies for the dependent variable. These measures will be based on the
administrative procedures that govern how the agencies develop, implement,
and enforce policy. The key explanatory variables for these analyses are the
complexity of a state’s air pollution problem (H1) and the professionalism
of its state legislature (H2). Since politicians may also use administrative
procedures to force agencies to favor politically potent interest groups (Mc-
Cubbins, Noll, and Weingast 1987), my analyses also include controls for the
strength of states’ environmental and industry interest groups.
The second step in my research strategy is to analyze the impact of ad-
ministrative procedures on clean air agency performance for four policy
activities: setting ambient standards, setting emissions standards, monitor-
ing emissions sources, and enforcement. Evaluating hypothesis H3 requires
measuring the range of policy options available to state clean air agencies,
and determining whether this set of options varies with the amount of policy
authority delegated to agencies. My statistical strategy is to apply conditional
heteroskedastic models to explain the variance of agencies’ policy choices.
Data on state’s administrative procedures and clean air policies come
from the Air Pollution Control Survey (APCS) conducted during the spring
and summer of 1998 by the author and the Council of State Governments
(Potoski 1999a; Potoski and Woods N.d.). The APCS survey consisted of
a 30–question, 16–page booklet sent to the chief or assistant air pollution
control administrator in each state. Administrators in 38 states responded
to the survey.10 There were no obvious differences between responding and
non-responding states; neither population, per capita income, legislative

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 spring 2002 / state politics and policy quarterly 9

professionalism, environmental and industry group membership, ideology,

or pollution emissions significantly predicted whether states responded to
the survey.11 Other data come from the U.S. EPA and published sources as
indicated below.

Dependent Variables: Procedures and Policies

Politicians grant policy discretion to agencies by allowing them to make
important decisions with administrative regulations and by specifying the
administrative procedures under which agencies make these decisions. Be-
tween them, these two approaches represent both ex ante and ex post over-
sight institutions. The APCS survey asked respondents whether the legal
basis for implementing their state’s ambient and emissions standards was in
administrative regulations or legislation. “Administrative authority” mea-
sures the degree to which administrative regulations are the legal mechanism
for implementing state ambient air and emissions standards, being scored
one point for each (ambient air standards and stationary source emissions
standards) that is implemented through agency-controlled administrative
regulations (range: 0–2). Higher levels of administrative authority indicate
that politicians have delegated more policy authority to the agency.
Administrative procedures can enhance ex post oversight by reducing
agencies’ information advantages over politicians. Politicians can require an
agency to submit proposed policies to various groups, thus increasing exter-
nal control over the agency’s policy choices. The APCS asked respondents
whether their state clean air agency is legally required to submit proposed
policies to industry groups, environmental groups, legislative committees, or
oversight commissions. “Administrative procedures” measures the number
of these administrative procedures that a state’s clean air agency is required
to perform, being scored one point for each procedure (range: 0–4). Higher
levels of administrative procedures mean politicians have designed the agency
for more political control and less agency autonomy.
The analyses of agency policy choice use four measures. “Ambient stan-
dards” measures if a state’s criteria pollutant standards exceed the NAAQS
for one or more pollutants (scored 1) or not (scored 0). “New source perfor-
mance standards” (NSPS) measures if a state exceeds the U.S. EPA emissions
standards (scored 1) or not (scored 0). “Ambient monitoring” is the number
of ambient monitoring stations a state operates. State clean air agencies can
initiate a variety of enforcement activities, including assessing administra-
tive penalties and bringing civil and criminal prosecution. The APCS asked
respondents the number of times their agency performs each of these activi-
ties in a typical month, resulting in the variable “enforcement actions.”

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Explanatory Variables
My analyses employ two measures of a state’s interest groups’ activities.
“Green groups” is the members per 1,000 residents of the Sierra Club, Green-
peace, and the National Wildlife Federation, as reported in Hall and Kerr
(1991). The measure of industry group strength, “industry groups,” is a
replication of a proxy measure developed by Rinquist (1993) that gauges the
economic strength of polluting industries. The measure is the “value added
by manufacturing by those industries most responsible for air pollution as
a proportion of a state’s gross product” (Rinquist 1993, 112) as reported in
the 1992 economic census (U.S. Bureau of the Census 1992).12 The measure
assumes that more economically potent industries have stronger interest
group representation before state policy-makers. There are two expectations
for how these interest group variables will perform in my analyses. First,
industry and green groups may both prefer an agency with fewer administra-
tive procedures, perhaps allowing them more direct influence over agency
performance through informal rulemaking (Hamilton and Schroeder 1994).
Second, these groups alternatively may prefer an agency with more proce-
dures, if they think that these will improve their access to agency officials
and influence on agency decisions.
“Legislative staff” measures the strength of state legislative staff resources,
as measured by Bowman and Kearney (1988). This is a composite index of
several measures (e.g., the number of committee staff and personal staff, staff
salaries, etc.) and is scaled so that its mean is zero and its standard deviation
is one. Such standardized scaling, also used for the pollution complexity mea-
sure (see below), allows the combination of several indicators using different
metrics, thus conserving degrees of freedom for the statistical analyses.
The measure of a state’s air pollution context is based on the amount
and distribution of pollutants released into the atmosphere there. “Pollu-
tion complexity” is an index of the sum and entropy of stationary-source air
pollution emissions in each state during 1995. The sum is the total amount
of criteria pollutants (in tons) released into the atmosphere.13 Entropy is
a measure adapted from communications theory to gauge the complexity
or uncertainty inherent in a state’s air pollution problem (Potoski 1999b).
Entropy scores were calculated for each state. Entropy is zero when all of the
signal is one category and its value increases with the number categories and
the more evenly distributed the proportion of the signal that falls into each
category. In state air pollution cases, the signal is the total amount of pollut-
ants emitted in a state and the categories are two-digit standard industrial
codes (SIC). More specifically, entropy is calculated as:

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 spring 2002 / state politics and policy quarterly 11

n
E = – Σ pi log(pi)
i=1
Where p is the proportion of pollutants emitted by the ith SIC category. Thus,
E is zero when the entire signal is in one category, and grows with the number
of categories (i) and as pi become more uniform across categories.14
A simple example helps illustrate the intuition behind the entropy mea-
sure applied to state air pollution policy. States A and B both have major
sources of sulfur dioxide in four different industrial categories. Ninety per-
cent of the sulfur dioxide emissions in state A comes from sources in one
industrial category, with the rest evenly distributed among sources in the
remaining three categories. The sources of sulfur dioxide emissions in state
B are evenly distributed among all categories. Thus, using the formula for
calculating E above, state A’s entropy value is .189 and state B’s entropy value
is .602. The importance of entropy in estimating the complexity of a state’s
air pollution problem can be seen if both these states tried to reduce emission
levels by 10 percent. State A would face a technically simpler problem in do-
ing this, since it might only need to develop new standards for one industrial
category. On the other hand, state B would most likely have to develop new
standards for two or more industrial categories, thus making its job more
complex.15
My pollution complexity index (total emissions plus entropy) validly
measures the complexity of the pollution emissions problem from the poli-
ticians’ and bureaucrats’ perspective. Total emissions measures complexity
because it is technically more challenging to develop pollution policies when
more pollution is released into the atmosphere. Entropy measures complex-
ity because the U.S. EPA regulations prescribe production processes and
pollution control technologies for each category of air pollution source, so
the more categories, the more complex the pollution problem. Entropy and
total emissions are highly correlated (r = .53) and aggregate to a reliable scale
(alpha = .65). This pollution complexity index is scaled so that its mean is
zero and standard deviation is one.

Statistical Analyses
To test whether politicians delegate policy authority and design agencies
consistent with the political control-expertise tradeoff (H1 and H2), the
administrative procedures and administrative authority measures were re-
gressed on my measures of legislators’ policy expertise (legislative staff) and
problem complexity. I expect (H2) that the coefficients for legislative staff

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12 potoski

Table 1: Descriptive Statistics for Variables in Statistical Models

Standard
Variable Mean Deviation Minimum Maximum
Clean Air Policies
Ambient standards 0.31 0.47 0 1
NSPS standards 0.18 .393 0 1
Enforcement 5.28 6.15 0 22.5
Ambient monitoring 58.9 53.0 6 200
Institutions
Administrative Authority 0.789 .741 0 2
Administrative Procedures 1.86 1.19 0 4
Controls
Problem complexity –0.135 0.936 –3.10 1.17
Green groups 8.70 3.59 2.50 20.2
Industry groups 0.09 0.05 0.01 0.226
Legislative staff –.031 .883 –1.13 3.76
Sources: Indicated in text

will be positive in the administrative procedures model and negative in the

administrative authority model. Conversely, (H1), the coefficients for prob-
lem complexity should be negative in the administrative procedures model
and positive in the administrative authority model. The models also contain
controls for the strength of green and industry interest groups.
Evaluating H3 requires a statistical technique that gauges how adminis-
trative procedures and administrative authority influence the range of op-
tions from which agencies select policy. Conditional heteroskedastic (CH)
models allow both the mean and the variance of a dependent variable to be
modeled as a function of a set of independent variables (Greene 1993). My
assumption is that the variance of an agency’s policy choices measures the
range of options from which it can select policies. This approach is implicit in
Bawn’s (1995) study, when she models agency discretion as the distribution
of agency policy choices, and is explicit in O’Toole and Meier’s (1999, 521)
model of political networks and hierarchies. Agencies that are given more
autonomy may choose a wider range of policies than are chosen by agencies
designed for more political control.
While more autonomy allows a greater range of policies to be chosen,
it does not force agencies to do so. Thus, my test of H3 is conservative. A
positive correlation between administrative procedures and a wide range
of policies shows that agencies are exploiting their autonomy, but the lack
of such a correlation is not necessarily evidence against H3. Agencies may
respond to autonomy by choosing a very narrow set of policies. Nevertheless,
my expectation is that more administrative authority will expand agency

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 spring 2002 / state politics and policy quarterly 13

autonomy by expanding the variance of agency policy choices (yielding posi-

tive coefficients), while more administrative procedures will reduce agency
autonomy by reducing the variance of agency policy choices (yielding nega-
tive or non-significant coefficients).16
Interpreting coefficients in CH models is straightforward. The coefficients
estimating the influence of a variable on the mean of the dependent vari-
able are interpreted as in any other regression analysis. The variance CH
coefficients in the model estimate the influence of the independent variables
on the variance of the dependent variable around its conditional mean. Be-
cause the specification of the CH variance term is based on an exponential
function, interpreting variance CH coefficients is akin to interpreting logit
coefficients.17 Following Alvarez and Brehm (1995; see also Greene 1993, 650),
I interpret statistically significant CH coefficients below by calculating the
predicted variance change associated with a change in the variance variable
from its minimum to its maximum. These predicted effects are reported in
Table 4.
My analyses include CH probit models (ambient standards and NSPS
standards) and CH ordinary least squares (OLS) models (ambient moni-
toring and enforcement). Each model contains administrative procedures
as an independent variable (along with the appropriate controls), and the
expectation (H3) is that more administrative procedures will reduce the error
variance in each model. Administrative authority is used as an independent
variable only in the ambient standards and NSPS models, because in these
policy areas, state legislatures can choose either to delegate authority to agen-
cies or to write the standards themselves in legislation.
The small sample size in my analyses suggests that the statistical results
should be interpreted with caution, particularly the CH analyses. Maximum
likelihood estimation ideally needs more observations than are available for
this study, especially for making statistical inferences. Unfortunately, addi-
tional data are not available. The sample size also limits the number of inde-
pendent variables that can be included in the models. Other variables I have
investigated included public opinion ideology (Erikson, Wright, and McIver
1993), and legislative and gubernatorial partisanship.18 Adding these indepen-
dent variables to the models sometimes causes others to lose significance,
probably because of the loss of degrees of freedom and the high correlation
among the independent variables (e.g., interest groups and partisanship).
The conditional mean independent variables for each CH model—green
groups, industry groups, and pollution complexity—were found in these
preliminary analyses to influence each dependent variable most strongly.
These conditional mean variables normalize the dependent variables (policy

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14 potoski

choices) and allow more accurate comparisons across states.

results: influences on the designed autonomy

of state air pollution control agencies
The first analyses evaluate H1 and H2, whether politicians design agencies
consistent with the political control-expertise tradeoff. Table 2 reports the
results of the ordered logit analysis of administrative procedures and admin-
istrative authority. These results are largely consistent with theoretical ex-
pectations—politicians in states with complex air pollution problems design
more autonomous agencies, and politicians in states with more professional
legislatures restrict agency autonomy.
In the first model, we see that politicians in states with more complex
air pollution problems establish fewer administrative procedures, consistent

Table 2: Influences on the Administrative Procedures and Authority of State Clean Air
Agencies (Ordered Logit)
Administrative Procedures Administrative Authority
Independent Variables Coefficients Effectsa Coefficients
Problem complexity –1.65** p0 = .22 .904
(.66) p1 = .36 (.728)
p2 = –.06
p3 = –.09
p4 = –.43
Legislative staff 1.30** p0 = –.15 –.290
(.52) p1 = –.30 (.575)
p2 = .06
p3 = .08
p4 = .31
Green groups –.095 .271**
(.087) (.112)
Industry groups 4.16 –.309
(6.47) (6.82)
Cut points –2.96 2.42
–1.09 4.58
0.96
1.40
Chi-square 9.39 9.06
Likelihood –46.6 –33.3
N 36 36
Notes: Sources indicated in text. Standard errors in parentheses.
*p < .05, ** p < .01 one-tailed tests.
a
Effects indicate the change in probability of being in each category associated with a two standard deviation
increase in the independent variable (from one standard deviation below the mean to one standard deviation
above), holding the other independent variables at their mean.

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 spring 2002 / state politics and policy quarterly 15

with H1. As the “Effects” column shows, a two standard deviation increase
in complexity decreases the estimated probability that a state has two (–.06),
three (–.09), or four (–.43) administrative procedures, while increasing the
estimated probability that it has only zero (.22) or one (.36) administrative
procedures, holding constant the effects of the other independent variables in
the model. When the policy problem is more complex, bureaucratic expertise
is more valuable, and politicians expand agency autonomy by cutting back
on administrative procedures.
The administrative procedures model also shows that politicians in states
with more legislative staff resources restrict the autonomy of state clean air
agencies more often, consistent with H2. Access to their own staff expertise
renders bureaucratic expertise less valuable, allowing politicians to tighten
their control over agencies. Specifically, a two standard deviation increase in
legislative staff is estimated to decrease the probability that a state has zero
(–.15) or one (–.30) administrative procedures, and increase the probability
that it has two (.06), three (.08), or four (.31) administrative procedures,
holding constant the effects of the other variables in the model.
The administrative authority model in Table 2 tells a similar story as the
administrative procedures model, but with weaker empirical support. The
estimated coefficients for complexity and legislative staff are in the expected
directions, but they are not statistically significant. This is perhaps due to
the small sample or weak measures, particularly the administrative authority
measure itself. Overall, the results in Table 2 suggest that politicians increase
agencies’ autonomy when the agencies’ expertise is more valuable, and they
reduce agency autonomy when they have access to their own internal policy
expertise.

results: influences on agency policy choices

The second set of analyses, reported in Tables 3 and 5, investigate how admin-
istrative procedures and authority influence agencies’ policy choices. Consis-
tent with H3, agencies designed for political autonomy (low administrative
procedures and high administrative authority) should have higher variance
in their policy choices, and agencies designed to be politically responsive
(high administrative procedures and low administrative authority) should
have lower variance policy choices. Thus, the coefficients for administra-
tive procedures should be negative, and the coefficients for administrative
authority should be positive.
Table 3 reports the results of the CH probit models of the influences on
states’ ambient and NSPS standards. The estimated variance coefficients

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16 potoski

suggest that administrative procedures and authority structure agency au-

tonomy by altering the range of options from which agencies select policy.
Administrative procedures restrict the range of options available to an agency,
and administrative authority expands it. Consistent with H3, the estimated
administrative procedures CH coefficient is statistically significant and nega-
tive in both the ambient and NSPS standards models, while the administra-
tive authority coefficient is statistically significant and positive in the NSPS
model. The predicted effects of agency autonomy on the variance of agency
policy reported in Table 4 shed further light on this relationship. Increas-
ing administrative procedures from its minimum to its maximum reduces
the variance in states’ ambient standards and NSPS standards by -1.77 and
-7.14, respectively, holding constant the effects of the other independent
variables in the model. Likewise, increasing administrative authority from its
Table 3: The Influence of Administrative Procedures and Authority on Agency
Autonomy in Ambient Standards and NSPS Standards (CH probit)
Independent Variables Ambient Standards NSPS Standards
Variance (CH) variables
Administrative procedures –1.16* –1.23*
(.64) (.71)
Administrative authority .71 2.79*
(1.03) (1.62)
Mean variables .037 .873
Green groups (.645) (1.34)
Industry groups –3.46 13.0
(–5.41) (25.5)
Problem complexity .009 –2.96
(.098) (4.41)
Constant –.136 –13.1
(.299) (18.9)
Log likelihood –14.4 –8.43
Number of observations 36 36
Note: Sources indicated in text. Standard errors in parentheses.
*p > .05 one-tailed tests.
Table 4: Predicted Effects of Administrative Procedures and Authority on
Agency Autonomy

Ambient NSPS Ambient

Standards Standards Monitoring Enforcement
Administrative procedures –1.77 –7.14 –1.45 1.67
Administrative authority n.s. 15.0 n.a. n.a.
Note: Calculated from CH coefficients in Tables 3 and 5. Predicted effects are the change in variance associated
with a change in the independent variable from its minimum to its maximum.
n.s. = not significant, n.a. = not applicable.

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 spring 2002 / state politics and policy quarterly 17

minimum to its maximum increases the variance in states’ NSPS standards

by 15.0, holding constant the effects of the other independent variables in
the model. Thus, administrative procedures are estimated to significantly
constrain the range of policy choices available to the agencies, and increased
administrative authority is estimated to expand it.
Table 5 reports the CH OLS analyses of states’ ambient monitoring
and enforcement policies.19 The coefficient for administrative procedures
is significant and in the direction predicted by H3 (negative) in the ambi-
ent monitoring model, but not in the enforcement model. As indicated by
the predicted variance effects reported in Table 4, increasing the number of
administrative procedures from its minimum to its maximum is estimated
to reduce the variance in states’ ambient monitoring policy by –1.45, but it
is estimated to increase the variance in states’ enforcement policies by 1.67.
The estimated enforcement model contradicts theoretical expectations, in
that more administrative procedures increase the error variance in states’
enforcement, holding constant the effects of the other independent vari-
ables in the model. It may be the case that for some policy activities, add-
ing administrative procedures expands the autonomy available to agencies.
Administrative procedures that grant influence to so many external groups
may effectively create autonomous agencies as strategic bureaucrats play
the groups against one another to mute external influence. Future research

Table 5: The Influence of Administrative Procedures on Agency Autonomy

in Ambient Monitoring and Enforcement (CH OLS)
Independent Variables Ambient Monitoring Enforcement
Variance (CH) variables
Administrative procedures –.338* .361*
(.198) (.197)
Variance constant .143 –.659
(.449) (.440)
Mean variables .038 .092*
Green groups (.038) (.046)
Industry groups 2.15 4.04
(2.70) (3.44)
Complexity .625** .669**
(.193) (.264)
Constant 3.17 .001
(.480) (.603)
Log likelihood –40.8 –51.5
Number of observations 35 36
Note: Sources indicated in text. Standard errors in parentheses.
*p > .05; ** p > .01 one-tailed tests.

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18 potoski

should investigate whether this finding is an anomaly or an indicator that

administrative procedure theory needs revising.

conclusion
I have presented a general model of how politicians design the institutional
structure of bureaucratic agencies to manage the political control-expertise
tradeoff and the impact of this design. When agencies’ expertise is valuable
(when the policy problem is complex or when politicians have little access
to policy expertise), politicians delegate more authority to agencies. When
bureaucratic expertise is less valuable (when the problem is less complex or
when politicians have more access to expertise), politicians constrain agen-
cies’ policy choices and increase their control over them. Politicians grant
agencies discretion by allocating them more administrative authority and
establishing fewer administrative procedures. My analyses of states’ air pol-
lution control agencies and policies generally support this theory, although
some anomalous findings were also noted.
This study has implications for our understanding of government agen-
cies. While administrative procedures do not necessarily push agencies to
favor one policy direction or another (Moe 1989; Balla 1998; Spence 1999),
they can have important consequences for agencies’ behavior. These pro-
cedures can shape the range of options from which agencies select policy,
an important theoretical and practical phenomenon that so far has escaped
empirical scrutiny. Thus, this article provides rare empirical support for the
political control-expertise tradeoff, an important proposition in positive
bureaucracies theory (McCubbins, Noll, and Weingast 1987).
More broadly, the overall picture of bureaucratic responsiveness to struc-
tural design presented here suggests the wisdom of more nuanced normative
standards for evaluating bureaucratic performance. I examined two impor-
tant normative standards of bureaucratic behavior—political responsiveness
and technical expertise—and reconfirmed the fundamental tension between
them (Bawn 1995; Epstein and O’Halloran 1999). But my findings suggest
that normative evaluations based on these standards should be informed by
the degree to which politicians designed an agency to be autonomous or re-
sponsive in the first place. Agencies are politically responsive or autonomous
in large part because politicians have designed them for different purposes. It
would be unfair to hold an agency to a standard that its fundamental design
makes more difficult to obtain.
Finally, this study demonstrates an analytic framework based on CH

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 spring 2002 / state politics and policy quarterly 19

models for examining causes and effects of agency autonomy and political
control. I use this framework to evaluate why administrative procedures
and authority are developed and how they influence the behavior of state
clean air agencies. This framework might also be applied to other theories
across a variety of agencies and policy areas to evaluate the influence of
institutional arrangements or other features in the agency’s environment
on the direction of its policy choices (the conditional mean) and its degree
of autonomy (conditional variance). For example, this framework may be
adapted to examine how conflict among principals influences the degree of
agency autonomy or political control (Woolley 1993; Hammond and Knott
1996). Future research could extend this approach to investigate other insti-
tutional features and policy areas beyond those investigated in this article.

endnotes
This research was supported by a Pew Charitable Trust Preparing Future Faculty Fel-
lowship, an Indiana University Graduate School Doctoral Student Grant-in-Aid of Re-
search, the University of Kentucky Martin School of Public Policy and Administration,
the Council of State Governments, and an American Political Science Association Small
Research Grant. Steve Balla, Kathleen Bawn, Ken Bickers, Ted Carmines, Bob Lowry, Leroy
Rieselbach, and John Williams provided helpful comments. Patrick Brandt assisted with
the statistical analyses.
1. Not only might agencies influence their political principals (e.g., by using policy
discretion to reward politicians’ key constituencies), they might also use their existing
policy discretion to convince politicians to grant them more discretion in the future.
Bureaucratic demand for discretion is a worthy topic of study but lies beyond the scope
of this study. For now, I assume a constant demand for autonomy across agencies.
2. Politicians can pursue ex post oversight, on the other hand, through oversight and
monitoring effects, such as oversight hearings. This article focuses on how administrative
procedures (ex ante decisions) create conditions for ex post oversight.
3. This political control-expertise tradeoff is only one of several theories that seek to
explain relations among politicians and agencies. For example, Moe (1989) proposes that
when the political environment threatens to bring political coalitions with policy prefer-
ences hostile to the status quo in the future, politicians insulate agencies from political
influence. These agencies’ future decisions will then reflect the intent of the current coali-
tion and will not be responsive to future, potentially hostile political coalitions (Moe 1989;
see also McCubbins, Noll, and Weingast 1987, 1989). Similarly, Epstein and O’Halloran
(1996) argue that legislators delegate less policy authority under divided government
than under unified government, suggesting that conflict among principals may influence
agency discretion (for other models of conflict among principals, see Woolley 1993 and
Hammond and Knott 1996).
4. Niskanen (1971), for example, argues that bureaucrats are motivated to maximize
their agency’s budget, while Downs (1967) describes a multi-dimensional motivational

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20 potoski

structure.
5. This assumes that for expert politicians the cost of developing the policy in legisla-
tion is cheaper than the cost overseeing and correcting the policy decisions of agencies
that have been delegated policy autonomy.
6. An alternative hypothesis based on Niskanen’s (1971) theory is that politicians will
delegate more authority to agencies when they have more information because correcting
agency transgressions will be easier.
7. Some scholars argue that politicians’ decisions about administrative procedures
and administrative authority are related (McCubbins 1986; Bawn 1997). Politicians who
delegate more administrative authority (thus expanding agency autonomy) may also
impose more administrative procedures (thus reducing agency autonomy) in order to
prevent agencies from abusing their administrative authority. To check for this possibility,
I examined whether clean air agencies with more administrative authority also had more
administrative procedures. There was no discernible relationship between the two in my
data set.
8. Air pollution policy in this article refers only to stationary-source air pollution, which
covers industrial sources such as factories and power plants. Mobile-source air pollution
policy mostly regulates tailpipe emissions from cars and trucks, and is not included in
my data.
9. Although the dynamics of relationship between the states and the U.S. EPA is an
important area for study (Wood 1992), it is beyond the scope of this study.
10. Some state administrators did not answer all the survey questions. Consequently,
sample sizes vary in my analyses.
11. The non-responding states were: IN, KY, MA, NC, NH, NJ, NM, OH, OK, TN, WI,
and WV.
12. The use of data from the early 1990s is appropriate for my analyses. Many of the state
policy decisions analyzed here were made early in the 1990s, in some cases in response
to the federal 1990 Clean Air Act. Also, relative levels of state interest group membership
are highly stable. For example, 1996 state membership in the Sierra Club is very highly
correlated (r = .98) with its 2000 membership.
13. The criteria pollutants are sulfur dioxide, particulate matter, volatile organic com-
pounds, carbon monoxide, and nitrogen oxide. All emissions data in this study are drawn
from the Emission Trends Viewer CD: 1985–1995, version 1.0, produced by the U.S. EPA
(1996).
14. This measure of entropy is quite flexible and has some interesting analytic applica-
tions. For example, Theil (1969) uses entropy in an analysis of representation in parlia-
mentary systems and McCombs and Zhu (1995) use it in an analysis of the complexity
of the public’s issue agenda.
15. Of course, entropy and total emissions are not the only dimensions of air pollution
complexity. For example, meteorological conditions can dramatically exacerbate pollu-
tion problems, as in Colorado where the high altitude and steep mountains conspire to
trap pollution around the cities. Unfortunately, I am unaware of any way to measure
systematically such meteorological conditions or any other dimension of air pollution
complexity.
16. This does not mean that agencies have a preference for a high variance set of policies.
Rather, the agencies choose policies for a variety of reasons, such as their own professional
judgment, outside political pressures from interest groups and the like, and their own

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 spring 2002 / state politics and policy quarterly 21

political preferences. Having more discretion—a broader range of options from which
to select a policy—gives agencies more flexibility to respond to these influences and to
choose a wider variety of policies.
17. In both logit and probit, the variance is a function of the mean. Therefore, the con-
stant term applies to both the mean and the variance functions when there are coefficients
estimating them separately, as is the case with CH models.
18. In addition, several potential measures were not available for this analysis. For
example, divided government may play a role in legislators’ delegation decisions and
agencies’ policy performance. However, investigating these potential effects is problematic
in this study because the data do not indicate exactly when states adopted the various
policies and rules incorporated into my measures. A state may have written its adminis-
trative procedure laws in 1982, while that state’s clean air agency then wrote its ambient
standards laws in 1992. Since divided government varies over time, there was no way of
accurately incorporating it into my analyses. More autonomous agencies may adopt more
environmentally stringent policies. To check this possibility, each of the CH models was
analyzed with the administrative procedures variables included in the conditional mean
equation. The coefficient for this variable did not achieve statistical significance in any
of the models, while the t-scores for the variance coefficients were lower in some cases
(which may be due to the decreased degrees of freedom).
19. Administrative authority is not included in either model in Table 4 because it only
gauges agencies’ authority to set ambient and NSPS standards. There is no corresponding
state-to-state variation on administrative authority for ambient monitoring and enforce-
ment because the U.S. EPA requires that all states grant agencies legal authority for these
tasks.

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