As a rule they do not have the funds to sponsor lavish luncheons, as do many professional lobbyists. Governmental agencies having defined responsibilities are responsible with administering statutory law. Governmental agencies interpret the law and adopt rules and regulations for its implementation. This function creates many controversies over correctness of an agency's understanding of the legislature's intent. In theory these agencies seek public comment before adopting substantive regulations.
Administrative regulations are likely to be adopted in-house without the benefit of public comment.
There is frequently an issue in characterizing a regulation as substantive or administrative. Whenever a serious dispute arises over an agency's interpretation and implementation of a statute, there may be an opportunity for a strong aviation constituency to negotiate a compromise. If no compromise can be effected, new legislation may be necessary. An agency may be more willing to negotiate if the alternative is a likelihood of new legislation that would affect the agency's authority. A negotiating technique that has been used successfully is that of obtaining support from a member of the state legislature.