Piotrowski, S. J. and Rosenbloom, D.H. (2005). "The Legal-Institutional Framework for Interest Group Participation in Federal Administrative Policymaking,"in The Interest-Group Connection: Electioneering, Lobbying, and Policymaking in Washington (Herrnson, P.S., et al., eds.), pp. 258-281, Washington, CW Press.
The authors are engaged in two projects in this chapter: first, describing the basics of the laws and institutions that govern lobbying of the administrative state; and second, discussing some of the research that shows how administrators themselves view interest group participation in the process. Some quotes I'll want to pull out for my own paper: the discussion of the failed Walter-Logan Act of 1940 (by way of comparison to the APA, p. 260). "Under the APA, participation in rulemaking is predominantly (or largely) by trade and professional associations, public interest groups, and corporations." (p. 261). "Public interest groups can try to represent broad swathes of the public effectively. . . ." (p. 275, citing Shaiko 1999). "Administrators themselves may even be representative of the public at large." (p. 275, citing Krislov and Rosenbloom 1981). "Greater ease in bringing legal challenges to agency rules tends to work to the advantage of interest groups even though these may not be 'repeat players.'" (p. 264, citing Golden 1998).
Two major models of interest group influence: subsystems model (iron triangles) and issue or policy networks model. Iron triangles appear to be fading in influence. Golden 1998 describes networks in her finding that iron triangles are slowly disappearing (see p. 277; see also Furlong 1997 and Kerwin 1999). The more flexible issue network appears to be growing. And in survey data, administrators appear more worried about interest groups than any other influencer except courts (Furlong 1998).
My take: Assuming that issue networks are more salient than iron triangles, particularly in abstruse but contested policy areas like the persuader rule, then we will expect to see the mechanisms Golden describes in the persuader rule context.