The following letter was submitted in response to our analysis piece, “How Regulatory Capture Actually Works.” It has been edited for length and clarity.

To the Editors:

I spent thirty-one years as a career attorney at a federal regulatory agency — not one I will name, for reasons that will become obvious — and your field guide to regulatory capture is the most accurate short account of the phenomenon I have read in the popular press.

I want to add one thing your piece did not cover, which I observed repeatedly over three decades: the role of what I came to think of as anticipatory accommodation.

Your piece correctly identifies the revolving door and the epistemic monoculture. What it underweights is the degree to which experienced agency staff learn to pre-filter their own recommendations based on their prediction of what leadership will accept — and leadership, in turn, pre-filters based on what the administration will support — and the administration pre-filters based on what will generate industry opposition of a kind that carries political cost.

The result is that by the time a recommendation reaches the level at which it might actually be acted upon, it has already been through three or four rounds of internal accommodation that nobody ever made explicit, nobody ever voted on, and nobody could easily point to as a decision. The capture happens in the white space between the formal steps of the process.

I raise this not to be dispiriting but because understanding it is necessary for any realistic reform proposal. You cannot fix anticipatory accommodation by changing the revolving door rules. You have to change the incentives at every level of the chain, which is a much harder problem.

Thank you for the work you are doing. This kind of journalism is needed.

— Name withheld at the writer’s request. Location: Washington, D.C.