Since April 2014, 35 of OIRA’s 712 meetings on proposed EPA regulations have been with API representatives – including a 2015 conference call with the institute’s president, Gerard, over ozone. The institute, along with the American Chemistry Council and ExxonMobil, ranked among the top 10 groups that met with OIRA from 2001 to 2011. Such encounters wield influence: a 2015 study by University of Wisconsin-Madison researchers found the agency was more likely to edit rules when lobbied by industry than by public interest groups. Rao’s office did not respond to requests for comment, but on its website OIRA notes it will meet with “any party interested in discussing issues on a rule under review”.