American administration is beset by critics on all sides. A conservative Supreme Court majority is skeptical of administration’s democratic legitimacy. Meanwhile, a rising chorus on the left criticizes agencies for inadequate consideration of public perspectives. These critics claim that agency proceedings should be more “democratic,” offering greater opportunity for robust public engagement. One area in which these calls are particularly pointed is energy regulation. Energy administration is formal, adversarial, and complex. At the same time, its subject matter is of high salience for individuals and communities concerned about the climate crisis and energy equity. 

This Article argues that enthusiasm for “democratic administration” should be tempered by a little realism, especially in areas like energy regulation. History teaches that while modest efforts to expand administrative participation can succeed, more ambitious reforms generally falter. The reasons for this, the Article suggests, are the inevitable trade-offs between expanded public engagement and other core administrative law values such as effectiveness, expertise, and non-arbitrariness. 

Using energy administration as a case study, the Article surveys federal and state agency responses to the call for more robust participation. It concludes that these efforts are unlikely to achieve advocates’ most ambitious goals. Instead, this Article proposes less romantic but more promising paths forward. First, attention could be re-focused on legislative change. Second, institutional structures for representation of particular interests could be enhanced. Finally, deliberative bodies of stakeholders outside of specific regulatory proceedings could be established to amplify the public’s voice in administration without creating significant tension with other administrative law values.