“…Rules are proposed and developed by unelected, high-level agency bureaucrats and managers who have substantive knowledge in the rulemaking policy area (Kerwin, 2011). 7 Although subject to some institutional constraints (Kerwin, 2011;Moe, 2006;Terman, 2012Terman, , 2013), 8 agency actors are given substantial policymaking discretion in terms of the basic promulgation of rules in addition to the timing and intensity of their rulemaking activity (Worsham & Gatrell, 2005).…”