She Who Shall Not Be Named: The Women That Women's Organizations Do (and Do Not) Represent in the Rulemaking Process

Abstract

AbstractThough the concept of intersectionality has been in circulation for nearly 30 years and women's organizations have long been criticized for failing to prioritize the concerns of women of color, poor women, and LGBTQ women, more research is needed to determine precisely why women's organizations do and do not discuss those intersectional identities during policy debates. This study analyzes 1,021 comments that women's organizations submitted to rulemakers to test a series of hypotheses about how women's organizations’ references to women's intersectional identities increase or decrease depending on the organization's primary constituency and ideology, the proposed rule's target population, and other features of the policy-making context. Using automated text analysis and a series of models, it shows that women's organizations do discuss intersectionally marginalized women in their comments. However, not all subgroups of women are equally represented during the process. Women's organizations focus on women's sexual orientations and gender identities more than their races, ethnicities, nationalities, or socioeconomic statuses. Intersectionally marginalized women also tend to receive the most attention when commenters are from organizations that are explicitly focused on representing intersectionally marginalized women and when bureaucrats include references to intersectionally marginalized women in their proposed rules.