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agencies, professional associations, Native American tribes, and the business community
routinely weigh in as well, as often as needed, and in whatever legislative, executive, or judicial
fora are available to them.
Despite the practical, normative, and theoretical import of these intragovernmental
regulatory challenges, scant research exists on this topic in the literatures of political science,
public administration, or public management. Thus, there has been little research attention paid
to the early and provocative thesis offered by James Q. Wilson and Patricia Rachal (1977) that
federal regulatory targets were uniquely positioned to resist regulation, and that they often lacked
the will and wherewithal to be held as accountable as private actors to this nation's laws. Indeed,
they were especially loath to change or modify their behavior at the behest of other public
agencies lest they disturb the delicate political economies supporting their core missions.
Moreover, the sobering consensus of the very limited amount of research conducted since on
intragovernmental regulation is that public agencies at all levels of government are often among
the most egregious major violators of ENR laws in the country (e.g., see Durant 1985; Paehlke
1991; Davies and Probst 2001). As Terry Davies and Kate Probst have recently observed, for
example, not only were government agencies responsible for 5 percent and 7 percent,
respectively, of all NO2 and SO2 emissions in the United States, but two-thirds of all facilities in
significant noncompliance with the Clean Water Act were public entities.
Absent, nonetheless, have been systematic and empirically rigorous efforts to track
longitudinally the dynamics and outcomes of intragovernmental regulation and to cull from these
observations the rudiments of an empirically grounded theory of intragovernmental regulation.
The purposes of this exploratory study are thus twofold. In a purely descriptive sense, the paper
chronicles what can happen, and why, when public agencies are charged with holding other
Convention