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Artivate: A Journal of Entrepreneurship in the Arts    Volume 8, Issue 1 
http://artivate.org  pp. 23-44 
 
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Copyright © 2019, Brea Heidelberg   
 

LEARNING FROM NEGATIVE SPACE:  
CATEGORIZING SUCCESS IN ARTS POLICY ENTREPRENEURSHIP 
Brea Heidelberg 
Drexel University 

 

Abstract 

From its inception in 1965, the National Endowment for the Arts (NEA) has counted 
on its agency leaders to operate as policy entrepreneurs – working to influence the federal 
public policy process and advocating for increased public arts funding. Policy entrepreneurship 
research has largely centered on success stories (Mintrom & Luetjens, 2017), but this does not 
provide a full picture of policy entrepreneurship. Kingdon (2003) argues that when policy 
entrepreneurship fails, so does their policy initiatives, but there has not been an investigation 
into policy entrepreneurship that fully defines and studies policy entrepreneurship failure in 
context. This investigation identifies three distinct areas where policy entrepreneurs can 
achieve success: agency leader, advocacy coalition manager, oppositional respondent. 
Through the lens of policy entrepreneurship with a focus specifically on rhetoric, this study 
assesses John Frohnmayer, NEA Chairman from 1989 to 1992, as a case of policy 
entrepreneurship failure. In looking at a case of unsuccessful policy entrepreneurship, this 
study furthers policy entrepreneurship theory and provide arts and cultural policy scholars with 
a more nuanced understanding of Frohnmayer’s time as Chairman of the NEA. 
 

The creation of the National Endowment for the Arts in 1965 pushed arts funding into 
the public policy arena to compete for attention and resources among other policy issues under 
the purview of the House and Senate Appropriations Committees – the governmental bodies 
responsible for determining the authorization and funding of the NEA. The existence of the 
NEA and the way that it has operated since its inception has prompted a number of 
investigations related to budgetary politics and fiscal support of the agency (Wyszomirski, 
1988), how the agency has fared the appropriations process (Moen, 1997), and the language 
used in attempts to help the agency navigate both the times when it has enjoyed relative 
political favor and times when it has been under political attack (Saunders, 2005). While 
official leadership of the agency has beendiscussed in autobiographies (Alexander, 2001; 
Straight, 1979) and biographies of NEA Chairpersons (Straight, 1988), and investigated 
empirically (Wirgau, 2013), one area under-examined is the role of NEA Chairpersons as 
policy entrepreneurs. 

 Kingdon (2011) defined policy entrepreneurs as actors “in or out of government, in 
elected or appointed positions, in interest groups or research organizations. But their defining 
characteristic, as in the case of a business entrepreneur, is their willingness to invest their 
resources – time, energy, reputation, and sometimes money – in the hope of a future return” 
(p. 122). Policy entrepreneurs work to “mobilize others in support” of their proposed policy 
initiatives (Mintrom & Luetjens, 2017, p. 4) in order to achieve positive policy outcomes in 
their policy area. In this case, a policy entrepreneur would be working to achieve continued 
and increased public arts funding at the federal level.  



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In order to accomplish their policy goals, policy entrepreneurs must work with 
advocacy coalitions and against oppositional advocacy coalitions. Advocacy coalitions are a 
collection of actors and actor groups that are in favor of the same proposed policy action and 
oppositional advocacy coalitions are those aligned against it. It is not necessary for those in 
either camp to agree with the rest of their respective coalition about the policy issue. In fact, it 
can be part of a policy entrepreneur’s work to get an advocacy coalition to act as a cohesive 
unit, or they may choose to coordinate various factions of an advocacy coalition to work toward 
their policy goals (Sabatier & Weible, 2007). In the art policy context, the arts advocacy 
coalition is comprised of all artists, arts administrators, legislators, and members of the general 
public that support public arts funding. The issue of public arts funding has always been 
contentious, and even those who agree that public arts funding should exist can have widly 
varying opinions about how that funding should be disseminated (Brenson, 2001, p. 132-33). 
At any given time, different factions of an advocacy coalition can be vying for dominance 
within the coalition.  

Various Chairpersons have been lauded as successfuli agency leaders based on specific 
accomplishments on behalf of some facet or facets of the arts subgovernment during their 
tenure. Roger Stevens was commended for being a “natural leader” who was fair and 
“evenhanded” (Taylor & Barresi, 1984, pg. 55-56). Nancy Hanks was praised for her political 
acumen and relationship building with Congress, despite being one of the first NEA Chairs 
with the least amount of experience in Washington leading up to her tenure, (Zeigler, 1994, p. 
68). Livingston Biddle was praised for his work to diversify further the art that was funded by 
the NEA in an effort to combat longstanding charges of elitism (Binkiewicz, 2004, p. 192). To 
date, the field of arts policyii has drawn important insights from success stories which have 
helped to shape the field’s emerging theories and practices. However, focusing solely on 
instances of successful policy entrepreneurship highlights a single path to success, embedded 
in the conjectures and contexts of the times. Furthermore, success is too malleable in this 
instance. It can mean a variety of things. Not having a fixed definition of success prevents true 
learning and application across contexts. I assert that studying instances of policy 
entrepreneurship failure can provide just as much, if not more, insight into the nuances of the 
roles policy entrepreneurs can play. In line with the aforementioned assertion, this 
investigation asks the following: given the various audiences and needs present in the public 
policy arena, are there various ways to define policy entrepreneurship success? Additionally, 
given the importance placed upon rhetoric in policy entrepreneurship literature (Petridou et al., 
2015), what specific insights can a rhetorical focus offer when looking at instances of policy 
entrepreneurship failure? These two research questions serve to further the field of policy 
entrepreneurship, which has begun to move beyond conceptualizations of policy 
entrepreneurship as “well-placed policy heroes with time on their side” (Mintrom & Luetjens, 
2017, p. 4) and has improved theorization of policy entrepreneurs through investigations of 
these actors in context (Mintrom, 2013; Mintrom et al., 2014; Mintrom & Luetjens, 2017; 

                                                
i In the policy arena, success is a relative term that often depends on who is in power at a given point in time. In 
order to ground the use of this work in the context of arts policy entrepreneurship, I use success to mean 
positive policy action from the vantage point of the NEA, those in favor of public arts funding at the federal 
level, and John Frohnmayer, specifically. 
ii Here, I use the term arts policy to signify a focus on the policy issue of public arts funding in the United 
States. This is distinct from the term cultural policy, which is primarily used outside of the United States and is 
much more expansive in its policy considerations. 



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Verduijn, 2015). These questions also address Mintrom’s (2015) call for the application of 
political entrepreneurship as an analytical lens in diverse contexts. While the issue of learning 
from policy entrepreneurship failure has been explored within the context of stem cell research 
(Mintrom, 2015), this has been done to demonstrate how policy entrepreneurs can “learn from 
failures and take new runs at securing policy change” (p. 103). My investigation expands upon 
this research by providing insights that can be applied across policy contexts and actors 
operating as policy entrepreneurs. To address my research questions, I look at the case of John 
Frohnmayer’s tenure as Chairman of the NEA. It is widely accepted that Frohmayer’s tenure 
was a failure (Zeigler, 1994, p. 68). However, investigating Frohmayer’s time as the agency’s 
leader through the lens of policy entrepreneurship helps better articulate exactly why he was 
unsuccessful as a policy entrepreneur and elucidates paths to policy entrepreneurship success 
that are obscured by less nuanced definitions of success and failure in the public policy arena.  

In this article, I first provide a brief overview of the NEA leading up to and outlining 
Frohmayer’s tenure. In a review of the work of policy entrepreneurs, I emphasize the role of 
rhetoric, namely through the issue-framing process, as a crucial component of the path toward 
policy entrepreneurship success. This will help redefine previous agency leadership successes 
as a demonstration of the utility of this lens. After the theoretical discussion, I present my 
methodology – which allows for simultaneous consideration of the rhetoric of the policy 
entrepreneur and other actor groups operating within the same public policy spaces. Finally, I 
present Frohnmayer’s time as Chairman as an illustrative case that, through the articulation of 
how he failed as a policy entrepreneur, highlights how policy entrepreneurs can have varying 
types and degrees of success. They can be successful agency leaders, achieving their agency 
goals, successful coalition organizers, with rhetoric and rationales that create a broad and 
strong advocacy coalition, and they can be successful oppositional respondents, managing to 
avoid or mitigate the damage caused by an oppositional advocacy coalition.  

Case Context: The Perfect Storm 

During the push to create the NEA, and for the first few years of the agency’s existence, 
many artists within the arts advocacy coalition were tentatively supportive of public arts 
funding. However, they were concerned with the issue of censorship and government control 
of the arts (Levy, 1997, p. 105). The practices of the agency, which was accused of favoring 
large, Eurocentric artistic institutions housed on the east and west coasts (Kester, 1998, p. 104) 
did not assuage these concerns. Two events occurred immediately prior to Frohnmayer 
becoming chairman that caused him to inherit an arts advocacy coalition that had gone from 
splintered to fractured. The first incident occurred when a Washington, DC gallery canceled a 
show from controversial artist Robert Mapplethorpe unexpectedly, amid pressure from The 
American Family Association, an organization that represented the interests of the religious 
right. The second occurred when another artist, Serrano, sparked additional controversy with 
the religious right with his work entitled Piss Christ. The American Family Association was 
joined by the Southern Baptist Convention, the Eagle Forum, Concerned Women for America, 
and the 700 Club, forming a strong religious right coalition. Although the grants that indirectly 
supported two separate shows in which each artist was showcased were handled during 
Hodsoll’s tenure, the controversy began gaining national attention as Hodsoll left his 
leadership position.  



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In addition to issues within the advocacy coalition framework, the oppositional 
advocacy coalition was experiencing a surge in political power. Critics of the agency within 
the arts policy landscape at the state and local levels, who called out the exclusionary dynamics 
of the agency’s grantmaking processes during Hanks’ tenure (Taylor & Barresi, 1984, p. 180) 
were gaining traction as influential leaders from various religious organizations, who 
mobilized members of the general public and members of Congress in both the House and the 
Senate in response to the two controversial grants. In the Senate, D’Amato (R-NY) and Helms 
(R-NC) coordinated efforts to get 39 Senators to sign a letter to the NEA expressing their 
outrage over Serrano’s work. In the House of Representatives, Armey (R-TX) enlisted the 
support of 107 members of Congress to sign a letter denouncing the Serrano grant. Senator 
Helms went as far as to propose the Helms Amendment, which limited the types of art that 
could be funded and sought to marry the concepts of obscenity with indecency. This is 
significant in that the former is not protected by the First Amendment, while the latter is. 
Marrying them could lead to them being considered one and the same, and therefore not 
protected under the First Amendment. Despite calls for the abolishment of the NEA, the agency 
was able to continue its work with a $45,000 cut to their budget. These cuts, known as the 
Stenholm Amendment, were the exact amount of the two grants involved in the Serrano and 
Mapplethorpe controversies. Although the entirety of these controversial events, from the 
granting of funds to the actual exhibition and initial backlash, occurred prior to Frohnmayer 
taking on the role of chair, the respective controversies caused by the NEA’s indirect funding 
connection to the work of Serrano and Mapplethorpe significantly impacted Frohnmayer’s 
time as chair from the moment of nomination.  

Other controversial grant assignments had existed in the NEA’s history, but they were 
handled relatively quickly  – either by quickly defusing the situation with a swift and 
unwavering decision, a favored tactic of Livingston Biddle, or by deflection with a focus on 
the number of successes the agency had enjoyed over the years, which is how Nancy Hanks 
often handled similar situations. In Frohnmayer’s nomination hearing, Senator Pell noted, 
“controversies have been few and far between, and each time, the Endowment has emerged 
unscathed, if not strengthened (Frohnmayer Confirmation, 1989, p. 3). However, in the case 
of Mapplethorpe and Serrano, the public and very controversial ways these two incidents were 
addressed, yet not truly resolved, caused old concerns about censorship to resurface.  

In 1989, John Frohnmayer became the fifth Chairperson of the National Endowment 
of the Arts (NEA) on the heels of a smooth nomination process (Gamarekian, 1989). In 
addition to experience as a lawyer, Frohnmayer served at the Oregon Arts Commission for 
eight years, four of those as chair. Additionally, Frohnmayer served as a peer reviewer for the 
NEA prior to his nomination. Each of the previous chairpersons was well-known in either elite 
artistic circles in the Northeast or as a Washington insider. The organization was fiscally stable 
at the time but was at risk of stalling out due to stalemate appropriations from Frohnmayer’s 
predecessors.  

Frohnmayer inherited an organization under political attack. At the onset of his tenure, 
Ronald Reagan assembled a task force, the Independent Commission, tacitly aimed at 
questioning the agency’s governmental processes and funding pathways. Reagan’s task force 
was part of a macro bureaucratic effort to economically streamline the government and cut 
costs within the federal government (Danziger & Haveman, 1981). However, this task force 
was also a response to Mapplethorpe and Serrano controversies, continued pressure from 



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members of the oppositional advocacy coalition operating within the legislature, and to 
mounting pressure coming from the aforementioned organizations representing the religious 
right. The group’s concerns were summarized by Donald Wildmon (as quoted in Zeigler, 1994, 
p.76): 

“What we are up against is not dirty words and dirty pictures. It is a philosophy of life 
which seeks to remove the influence of Christians and Christianity from our society. 
Pornography is not the the disease, but merely a visible symptom. It springs from a 
moral cancer in our society, and it will lead us to destruction if we are unable to stop 
it.” 

In the eyes of the religious right, the NEA was a symbol of moral decay, and it was their duty 
to bring it down for the good of society. 

In light of the Serrano and Mapplethorpe grants, Frohnmayer focused on avoiding 
further controversy. Against this backdrop, Frohnmayer’s earliest initiatives as Chairman 
sought to divert attention from the ostensibly “risky” individual artists by driving policy change 
in the arena of arts education and rural access to the arts. Soon after becoming chair, he 
attempted to retract NEA funding from Artists’ Space, a lower Manhattan gallery focusing on 
emerging artists, due to rumors that they would be mounting a show that both attacked certain 
political figures and featured provocative nude photos. The board of Artists’ Space responded 
with a letter stating their refusal to return the funds (Bolton, 1992). Instead of quelling the 
issue, Frohnmayer’s attempt to retract the grant further alienated the agency from artists and 
the arts constituency. In direct response, Leonard Bernstein, a famous conductor, refused the 
National Medal of Arts in protest. This act publicly embarrassed President George H.W. Bush 
and his wife, further alienating Frohnmayer from government supporters who had already 
distanced themselves from him. When he officially joined the NEA, Frohnmayer found the 
NEA disjointed and its staff low on morale. Attempts to hire staff members of Frohnmayer’s 
choosing were met with admonishment or silence from presidential personnel (Frohnmayer, 
1993), and he struggled to understand the agency practices and governmental norms that would 
get him the results he wanted. Additionally, Frohnmayer’s attempts to reason with the 
evangelical community – including public appearances on CNN and other public media 
(Zeigler, 1994) where he openly discussed concerns with members of the American Family 
Association, a very vocal component of the oppositional advocacy coalition, were 
unsuccessful. 

Administratively, Frohnmayer spent most of the time as chair dealing with the 
ramifications of the Helms amendment. Although the Helms amendment itself was not passed, 
language from that amendment was adopted into the NEA granting terms and conditions. The 
language prevented the agency from providing funds: 

…to promote, disseminate or produce materials which … may be considered obscene, 
including depictions of sadomasochism, homoeroticism, the sexual exploitation of 
children, or individuals engaged in sex acts and which, when taken as a whole, do 
not have serious literary, artistic, political or scientific value (Frohnmayer, 1993, p. 
133). 



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Many in the arts community considered this a loyalty oath. As a direct result, organizations 
such as The American Poetry Review, Gettysburg Review, and the Paris Review rejected 
grants they were awarded because of the decency clause (Masters, 1990). The New School 
sued the NEA in 1990, seeking a ruling that would ban the NEA from asking grant recipients 
to sign a pledge of compliance that they would not engage in any obscene (Masters, 1990). 
The public embarrassment was subject to criticism from the media, artists, and the oppositional 
advocacy coalition. Indirectly, artists of the time reported a high level of tacit self-censorship 
as a result of the Helms amendment language (Walker, 1993, p. 937). 

The most noted controversy of Frohnmayer’s tenure was the “NEA Four.” Four 
individual artistsiii filed lawsuits against Frohnmayer for revoking grants that had been 
approved by the NEA peer-review process, stating that their “indecent” content went against 
“obscenity clause” introduced into the NEA administrative purview as a compromise to the 
Helms Amendment (Zeigler, 1994). In the end, Frohnmayer’s decision was upheld when the 
Supreme Court, under then-President Clinton, ruled that the NEA could, and should, consider 
decency standards when making granting decisions. This decision occurred six years after 
Frohnmayer was forced to resign. Winning in court, however, could not remedy the irrevocable 
damage to the arts advocacy coalition and its relationship with the agency. 

The NEA managed to navigate the 1990 reauthorization process, despite attacks from 
both the arts constituency and the oppositional advocacy coalition. One of the biggest factors 
in the agency’s ability to survive the reauthorization was the Independent Commission. This 
group, called for in the agency’s 1990 appropriation legislation, was charged with “reviewing 
the National Endowment for the Arts grant-making procedures, including those of its panel 
system, and considering whether the standard for publicly funded art should be different than 
the standard for privately funded art” (The Independent Commission, 1990, p. 1). The 
individuals chosen to serve on the commission spanned the political ideological spectrum, were 
well-versed in the intersection of public policy and the arts, politically savvy, and capable of 
garnering bipartisan supportiv. The outcome of this process was four significant changes to the 
agency and the way it conducted business (Effect of Last Year’s NEA Reauthorization Process, 
1991). First, grant reviewers were supposed to assess grant applications through a lens of 
general-decency standards. Second, the percentage of NEA funds required to be set aside for 
state and local arts organizations was increased to a total of 35% to be passed along in FY93. 
Third, of any funds for the organization over $175 million, 50 cents of each dollar must go 
toward education. Finally, to address charges of elitism among panelists, the peer-review 
process was altered to make panels more representative of the general public. While surviving 
reauthorization can be seen as a political win for the agency, the Independent Commission’s 
work served to further erode the relationship between the agency and artists – who found the 
proposed changes to be a further attack on free speech rights of artists (Yasui, 1991). After 
reauthorization, other skirmishes between the agency, the oppositional advocacy coalition, and 

                                                
iii Karen Finley, John Fleck, Holly Hughes, and Tim Miller 
iv Four members of the commission were from New York (Theresa Elmore Behrendi, Dr. John Brademas. Kitty 
Carlisle Harl, and Charles Kinsley McWhorter); two were from California (Peter Nicholas Kyros, Jr., and 
Rosalind Wiener Wyman); two were from Illinois (David E. Connor and Joan White Harris): and one each from 
New Mexico (Dr. John Thomas Agresio), Kansas (Marcia Laing Golden), West Virginia (Kay Huffman 
GoiKlwin), and the District of Columbia (Leonard Garment) (The Independent Commission, 1990, p. 1) 
 



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artists continued. Frohnmayer, under constant fire from the oppositional advocacy coalition 
and unable to unify the arts advocacy coalition and gain their support, was forced to resign 
after only two years as chair. 

Initial assessments of Frohnmayer’s tenure with the NEA simply painted the picture of 
an inept outsider who was not privy to the inner workings of the federal government (Zeigler, 
1994). However, looking at Frohnmayer’s tenure through the lens of policy entrepreneurship 
provides a much more nuanced reading of his time and highlights different types of policy 
entrepreneurship success that do not rely solely on whether or not specific legislation is passed. 

 
Theoretical Approach 

In order to account for a broad definition of policy entrepreneurship success and to 
highlight the role rhetoric plays in that context, this study overlays Kingdon’s (2003) Policy 
Window/Multiple Streams framework, Baumgartner and Jones’ (1999) Punctuated-
Equilibrium Theory, and Sabatier’s (2006) Advocacy Coalition Framework. While each of 
these theories has stood alone in other policy analyses and investigations, they work in tandem 
to assess the full complexity of the policy context. Each of these theories informs the literature 
on policy entrepreneurship and addresses the role of rhetoric in the work of policy 
entrepreneurship. 

Kingdon’s (2003; 2011) multiple streams (MS) framework separates the policymaking 
process into three distinct streams. The political stream is comprised of elements such as 
national mood, pressure group campaigns, administrative and legislative turnover, and 
politicians’ interests. The problem stream is where issues are defined and brought into the 
policy arena. Finally, the policy stream is where issue definitions are analyzed and 
reconfigured by a community of concerned issue actors. The MS framework assumes that each 
stream flows independently of the others and that it is special work to get two or more of the 
streams to converge to create a policy window. A policy window is a narrow opportunity where 
policy change may occur. Policy windows can either be auspicious or inauspicious, depending 
on the reason the policy window opening. Much like the relative definition of success – the 
polarity of a policy window depends on your vantage point. Because I am looking specifically 
at John Frohnmayer, I view auspicious policy windows as ones that would benefit his 
organization and policy issue: public arts funding. Likewise, inauspicious policy windows are 
those that would threaten the NEA, public arts funding, and his role as the agency’s leader. 

This study investigates how Frohnmayer rhetorically navigated these streams. In the 
case of a potentially auspicious policy window, successful policy entrepreneurship would 
require Frohmayer to use rhetoric to combine the three streams and create a window of 
opportunity for positive policy change. Conversely, if members of the oppositional advocacy 
coalition can combine the three streams, this would create an inauspicious policy window. In 
the event of an inauspicious policy window, success would entail Frohnmayer utilizing rhetoric 
to separate the streams or to mitigate the damage to his agency, his policy issue, and his 
authority as Chairman. This theory is particularly useful when looking at the role rhetoric plays 
in the work of a policy entrepreneur. While this theory is useful from a policy rhetoric 
perspective, its focus on whether or not a policy window occurs is too reliant upon outcomes 
and does not allow for more nuanced definitions of policy entrepreneurship success.  



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 The how and why of a policy window opening dictates the specific set of 
entrepreneurial policy skills required to navigate and manage policy change successfully. 
Baumgartner and Jones’ (1999) Punctuated-Equilibrium Theory complements Kingdon’s 
(2003) framework by identifying data types and sources analysts can use to examine policy 
windows, regardless of their polarity. This theory indicates that looking at a fuller picture, 
which includes failures as well as successes, is important in understanding the work of policy 
change management (Howlett et al., 2017). Finally, Sabatier’s (2006) Advocacy Coalition 
Framework focuses on the use of rhetoric employed by policy entrepreneurs to manage 
advocacy coalitions operating in favor of their policy issue as well as those operating in 
opposition. The Advocacy Coalition Framework has successfully been combined with the MS 
framework to provide complementary explanations for the policy change management of 
specific policy issues, and it serves the same purpose in this study (Meijerink, 2005).  

 
Research Methodology 

I used NVivo, qualitative data-analysis software developed by QSR, to conduct 
rhetorical analysis to track individual themes (e.g., artistic excellence, economic impact, 
geographic access) and how those themes occurred (e.g., metaphor, storytelling, synecdoche) 
by actor group (Advocacy Coalition, Chairman, Oppositional Advocacy Coalition, and 
Policymaker). I constructed my codebook by investigating arguments both in favor of and 
against public arts funding at the federal level between 1962 and 1968 (the years leading up to 
and including the start of the NEA). I then compared my codebook to that used in Strom and 
Cook’s (2004) investigation of rationales used both for and against public arts funding at the 
federal level in the policy arena between 1965 and 2005, which was based on Kingdon’s MS 
framework and successfully utilized in two other studies (Berkers, 2009; Toohey, 2007). I 
utilized Stone’s (2002) Policy Paradox to construct my rhetorical strategy codebook. Stone 
(2002), working from a theoretical base closely aligned with my own, provided thorough 
investigations of symbols, the use of numbers, interest statements, and rhetorical strategies to 
track the evolution of issue definitions.  

This approach accounts for the rhetorical dynamics of the main components of the arts 
subgovernment: the arts advocacy coalition, the oppositional advocacy coalition, John 
Frohnmayer, and policymakers during Frohnmayer’s time at the NEA. In order to track the 
rhetoric I analyzed the following sources: three confirmation hearings, NEA annual and 
research reports released during Frohnmayer’s tenure, appropriations hearings for the two 
years Frohnmayer was a part of the proceedings (FY90 and FY91), the 1990 Independent 
Commission report, and the Reauthorization Hearings. Newspaper coverage was particularly 
important during this time, by Frohnmayer’s time as Chairperson, news about the NEA was 
covered beyond the arts section. I also analyzed interviews, personal letters between members 
of the arts subgovernment, editorials from newspapers, and print advertisements by various 
members of the subgovernment during Frohnmayer’s time as Chairman. Finally, I analyzed 
Frohnmayer’s account of time at the NEA, Leaving Town Alive: Confessions of an Arts 
Warrior (1993) through the policy entrepreneurship lens to include the narrative perspective 
of the policy entrepreneur as context. I investigated each argument from these sources based 
on a series of questions that I constructed to reflect best practices in advocacy coalition building 
(Sabatiér, 2007). 



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Findings 

Based on the policy entrepreneurship lens, I determined three areas where policy 
entrepreneurs may achieve success: agency leader, coalition manager, and opposition 
respondent. Here, I present my findings in these three areas – demonstrating Frohnmayer’s 
failed policy entrepreneurship by analyzing his rhetoric in the formal policy arena as well as 
his rhetorical interactions with the arts advocacy coalition and the oppositional advocacy 
coalition. 

Agency Leadership 

According to statements made in the confirmation hearing and Frohnmayer’s book, he 
wished to focus on art education and rural arts access (Frohnmayer Confirmation, 1989; 
Frohnmayer, 1993). However, Frohnmayer presented seven different rationales for public arts 
funding during his time as Chairman: access, intrinsic value, art education, artistic quality, 
economic impact, industry comparison (comparing the plight of the arts sector to those in 
education and other social industries), and U.S. image abroad. This is a large number of 
rationales to be presented in the short time that Frohnmayer was chair, especially since his 
stated agency agenda was fairly concise. Based on the policy entrepreneurship literature, it is 
expected that a policy entrepreneur with a clear agenda would narrow their rhetorical focus 
(Edelman, 2013). Frohnmayer found it difficult to further his agency agenda, even during his 
confirmation hearing. When the conversation strayed into Frohnmayer’s desires for the agency, 
a member of Congress always brought the conversation back to the issue of NEA processes 
and accountability to the public (Senate Committee on Human Resources, 1989). In a tight 
rhetorical space, like the one Frohnmayer experienced, policy entrepreneurs usually use that 
limited space to focus on a small number of advocacy arguments strategically chosen to garner 
the most agreement and support from policymakers and their advocacy coalition (Mio, 2018). 
The choice to introduce seven different arguments, none of which directly align with any of 
the three main arguments (censorship, freedom, and accessv) presented by the arts advocacy 
coalition demonstrates a lack of policy entrepreneurship awareness and an inability to 
rhetorically navigate the policy arena to further his policy agenda.  

Instead of rallying support for his stated agency goals of arts education and rural arts 
access, Frohnmayer spent his time reacting to crises stemming from the artists’ faction of the 
arts advocacy coalition and the oppositional advocacy coalition. The controversial acts of many 
artists who had received media attention were mentioned repeatedly throughout appropriations 
hearings during Frohnmayer’s tenure. Frohnmayer’s attempt to rhetorically situate rural arts 
access and arts education in politically favorable ways did not gain traction among 
policymakers – who forced Frohnmayer to focus on accountability reactively. Additionally, 
Frohnmayer’s arguments shifted based on his context. When dealing with the arts advocacy 
coalition and the oppositional advocacy coalition, Frohnmayer focused on access, intrinsic 
value, and arts education. When in the policy arena dealing with policymakers Frohnmayer’s 
top three rationales were access, accountability, and quality. Access was the only argument 

                                                
v The arts advocacy coalition focused on access as a critique of the NEA’s funding processes – meaning lack of 
access to public arts funding for many marginalized artists. This is distinct from Frohnmayer’s focus on rural 
arts access for the general public. 



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that Frohnmayer used consistently across audiences – unfortunately, Frohnmayer’s attempts to 
further his agency goal of rural access did not align with the rest of the arts subgovernment’s 
focus on access to arts funding for a more diverse pool of artists and arts organizations. 
Frohnmayer’s shift in focus from intrinsic value and arts education to accountability and 
quality meant that his agency agenda was not strategically expressed across actors. The 
outcome was a disjointed attempt to focus on his agency agenda that did not resonate with 
policymakers focus on avoiding additional controversy. Frohnmayer’s policy entrepreneurship 
failure in this area saw the agency unable to make significant advancements in the areas of 
rural access and arts education. This is not to say that there was no agency presence in those 
areas at all – there was just no marked difference in agency action in these areas during 
Frohnmayer’s tenure. 

Coalition Management 

The arts advocacy coalition consisted of arts educators, arts managers, individual 
artists, arts service organizations, and general arts advocates. As a whole, the arts advocacy 
coalition focused on three main concepts: anti-censorship, artistic freedom, and access. While 
the concentrated number of advocacy arguments suggests a unified advocacy coalition, low 
word frequency findings demonstrate a lack of coherence among the arts constituency in their 
attempts to justify or discuss these issues.  

Artists employed arguments and rhetorical strategies that differed significantly from 
strategies deployed by the rest of the coalition – demonstrating splinters within the arts 
advocacy coalition. During Frohnmayer’s tenure the arts advocacy coalition fell into a loose 
pool of disparate concerns and priorities. In the arts advocacy coalition, artists were primarily 
concerned with artistic freedom and the ability to receive grant funds regardless of how the 
general public perceived their art. Arts administrators and others working in and representing 
arts institutions, on the other hand, wanted to avoid losing grant funding and support from the 
general public based on the actions of some artists. The artist faction of the arts consistency 
focused primarily on censorship with artistic freedom being a related secondary concern. Other 
parts of the coalition were more politically strategic, focusing on artistic freedom and, to a 
much lesser extent, access to the arts through ethos-building tactics. Organizations like the 
Association for Independent Film and Video called for organized campaigns to advocate for 
public arts funding throughout the artistic controversies. They encouraged an approach based 
on logic and technical information, such as public support of arts research (Bolton, 1992, p. 
206). Other arts advocates called on the general public to review the legislation being proposed 
and methodically outlined the detriment that censorship would cause. However, artists 
targeting specific members of Congress and the oppositional advocacy coalition with pathos-
driven aggressive messaging were granted more media coverage. 

Table 1 shows the differences between Frohnmayer and the arts advocacy coalition at 
the start of Frohnmayer’s tenure. Although access showed up as one of the top three rationales 
from Frohnmayer and the arts constituency, they each focused on different aspects of the access 
argument. Frohnmayer was concerned with rural access, whereas the arts constituency focused 
on access to NEA funding for women and minorities. Despite this minor overlap, the concerns 
of the chair did not match those of the arts constituency at the start of this tenure. There was 
the potential for overlap with intrinsic value and artistic freedom, as parts of the arts 



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constituency based their artistic-freedom argument on intrinsic values, but the connection was 
not explicit. 

Table 1 Frohnmayer’s and the Arts Advocacy Coalition’s Initial Rationale Preferences 

Rationale Rank John Frohnmayer Arts Advocacy Coalition 

1st Access (Geographic) Artistic Freedom 

2nd Accountability Anti-censorship 

3rd Intrinsic Value 
Access 
 (Women & Minority Artists) 

Table 2 provides an assessment of the advocacy arguments stemming from the arts advocacy 
coalition during Frohnmayer’s tenure. 

Table 2. Arts Advocacy Coalition Argument Scorecard 

Argument Assessment 
Element 

Argument 

Anticensorship Artistic Freedom Access 

Does the argument address the 
concerns of multiple parts of 
the advocacy coalition?  

No Yes No 

Does the argument address the 
concerns of the general public? No Yes No 

Does the argument address 
concerns in the oppositional 
advocacy coalition? 

Yes Yes No 

Does the argument have 
connections with other, 
politically salient arguments?  

No No No 

Is the argument multifaceted? No No Yes 

From a consensus building perspective, the arguments stemming from the arts constituency 
were neither cohesive nor strong. These arguments only took into account the desires of artists 



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and arts organizations to the exclusion, and often alienation, of members of the general public. 
The number of controversial artworks and their media coverage, coupled with these arguments, 
shifted the way the general public felt about artists and public arts funding. At a time of 
heightened public attention, the arts advocacy coalition was not making it a point to make 
enticing or politically salient arguments to the general public about their most popular benefit, 
public access to the arts. 

A policy entrepreneur inheriting a strong arts advocacy coalition would only need to 
plug into pre-existing advocacy rhetoric and maintain equilibrium within the coalition, while 
a policy entrepreneur inheriting a weak, yet cohesive coalition would need to formulate new 
advocacy rhetoric that maintained the group’s cohesion (Rochefort & Cobb, 1994; 
Baumgartner & Jones, 2002). Given the lack of cohesion within the arts advocacy coalition, 
successful policy entrepreneurship in this area would require consensus building. Relative 
success in this area would include some combination of neutralizing factions of the arts 
advocacy coalition working against his efforts and banning together with the factions of the 
arts advocacy coalition whose goals for public arts funding and the NEA were in alignment 
with his. 

Frohnmayer stated his aspiration to repair the arts advocacy coalition before his official 
start date as Chair (Frohnmayer Confirmation Hearing, 1989, p. 6), but he did not explicitly 
outline tactics. Frohnmayer employed seven distinct rationales for the arts, while the rest of 
the arts advocacy coalition used only three. Frohnmayer’s top three rationales were access, 
intrinsic value, and arts education. The only commonality is access, but Frohmayer defined 
access from an audience perspective while the arts advocacy coalition defined access from a 
funding perspective. This lack of common arguments and lack of cohesion, which was present 
at the start of Frohnmayer’s tenure, continued throughout his time as chair. Frohnmayer’s 
advocacy arguments did not mirror or complement any of the discordant intra-coalition 
priorities of the arts advocacy coalition. During his tenure, Frohnmayer stayed consistent with 
the rhetoric started at the onset of his time as Chair, never altering his arguments to bring them 
more in alignment with rhetoric stemming from any faction of the arts advocacy coalition. This 
instance of policy entrepreneurship failure prevented Frohnmayer from having a support base 
that could be utilized to help him achieve policy entrepreneurship success in other areas. Due 
to the inner turmoil in the arts constituency, compounded by some of Frohnmayer’s actions 
and decisions, he was unable to either build or strengthen the advocacy coalition: “having made 
the decision to reject the four performance artists, I became the object of the vitriol of both the 
left and the right” (Frohnmayer, 1993, p. 178). By failing to organize and focus his arguments 
in ways that aligned with or complemented arts advocacy coalitions’ argumentation strategies, 
Frohnmayer failed to mobilize a splintered coalition. 

Oppositional Respondent  

Legislative members of the arts advocacy coalition understood the political climate into 
which Frohnmayer would enter. At his confirmation hearing, congresspeople mentioned the 
fact that the agency was under attack by the oppositional advocacy coalition and public interest 
groups on 20 separate occasions. From “recent unpleasantness” (Frohnmayer Confirmation 
Hearing, 1989, p. 1), to “controversy” (p. 38), the publicity concerning Serrano and 
Mapplethorpe was in the forefront of policymaker’s minds. It was clear to them than an 
inauspicious policy window was, if not already opened, a likely possibility. A series of 



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concepts that would frame his tenure emerged: Congress universally used the word oversight 
to define the role that the NEA should play in order to demonstrate accountability to taxpayers, 
while intrusion was used in lieu of government control or censorship. The importance of 
maintaining the integrity of the agency was also noted repeatedly, as policymakers did not 
want to be seen as promoting government control at the expense of artistic freedom. 

Table 3 assess the advocacy argument from the oppositional advocacy coalition during 
Frohmayer’s tenure. During this time the oppositional advocacy coalition’s arguments were: 
“bad art,” accountability, and no need.  
 
Table 3: Argument scorecard for the rationales used by the oppositional advocacy coalition 
throughout Frohnmayer’s tenure. 

Argument Assessment Element 
Argument 

Bad 
Art 

Accountability No 
Need 

Does the argument address the concerns of multiple parts 
of the advocacy coalition?  No Yes No 

Does the argument address the concerns of the general 
public? No Yes No 

Does the argument address concerns in the arts advocacy 
coalition? Yes Yes Yes 

Does the argument have connections with other, 
politically salient arguments?  Yes Yes No 

Is the argument multifaceted? Yes No No 

 

Unlike the arts advocacy coalition, rhetoric across actors within the oppositional advocacy 
coalition was consistent, indicating a well-organized and cohesive advocacy coalition. They 



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defined art they deemed obscene or blasphemous as “bad art.” Having the works of Serrano 
and Mapplethorpe as concrete examples helped inflame a growing and increasingly vocal 
religious right.  This argument was a direct challenge to longstanding values of quality and seal 
of approval upon which the NEA was founded (Mark, 1991). This argument was often used to 
directly address the general public, letting people know about the “vile content of [their] tax-
funded material” (Bolton, 1992, p. 123), “photographs too vulgar to print” (Bolton, 1992, p. 
124), and “pornographic, anti-Christian ‘works of art’” (Bolton, 1992, p. 150). The 
oppositional advocacy coalition then rallied around the bad-art argument and furthered it by 
stating that public dollars should not be used to support obscene or offensive art. Arguing that 
artists should be held accountable to taxpayers, the oppositional advocacy coalition brought 
additional members of the general public into its ranks. They also resurrected arguments from 
the 1960s, when the NEA was being conceptualized, that placed the arts in a market context. 
Arguing that artists should be able to make a living working in the same capitalist structure in 
which businesses operate played into the growing fiscal conservatism with Congress and 
among the general public. Overall, the oppositional advocacy coalition presented a unified set 
of arguments with consistent language. Although their arguments were not designed to win 
over members of the arts constituency, they were able to reach some members of Congress and 
increase their political power. 

Success as an oppositional respondent requires policy entrepreneurs to defend the 
agency and their agency goals through deflection and mitigation of negative impact that could 
be caused by any successes achieved by the oppositional advocacy coalition. The strong, 
cohesive oppositional advocacy coalition which was organized and strategic about gaining 
support from Congress and the general public was difficult for Frohnmayer to combat.  

Frohnmayer was unable to successfully deflect attacks from the oppositional advocacy 
coalition with his main argument tactic: avoidance. When possible, Frohnmayer avoided the 
topic of the various artistic controversies and the oppositional advocacy coalition’s growing 
political power. At times he appeared to be making attempts to deflect attacks. For example, 
Frohnmayer consistently drew the conversation to art education and the desire to see access to 
the arts continue to increase during the nomination hearing. He employed an “intrinsic values 
of the arts” rationale, buttressed mainly by arts education rationales, to argue for more funding 
and resources - even though controversy over some NEA policies were already a prominent 
concern among policymakers. Arguments such as “the arts help children to understand 
civilization, try various approaches to problem-solving, use intuition as well as reason, and 
develop the discipline required for success in life,” (NEA, 1989, p. vii) did not land well outside 
the policy arena when deployed in response to charges of publicly funded pornographic art 
(Bolton, 1990, p. 180). Sometimes, Frohnmayer was forceful – such as in his correspondence 
with Art Space where he requested that they return their NEA funds (Bolton, 1990, p. 125):  

“Artists Space should relinquish the Endowment’s grant for [your] exhibition. 
Additionally, please employ the following disclaimer in appropriate ways to correct the 
misapprehension of our support for this exhibition: ‘The National Endowment for the 
Arts has not supported this exhibition or its catalogue.’”  

At other times, Frohnmayer appeared to be conceding and undermining his agency. For 
example, in his response to the New York Shakespeare Festival’s refusal of an NEA grant 
where Frohnmayer referred to the obscenity clause as “not one of our asking nor one which I 



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thought necessary” (Bolton, 1990, p. 173). Even Frohnmayer admitted often being unsure of 
how to handle difficult situations and that he was undecided about staying at the agency even 
before he was asked to resign (Frohnmayer, 1993, p. 247-250).  

As previously mentioned, the arts advocacy coalition had alienated some members of 
Congress and members of the general public leaving an advocacy vacuum that the oppositional 
advocacy coalition stepped into, gaining momentum and popularity (Sabatier & Weible, 2007). 
In choosing to focus on access, and art education at a time when the oppositional advocacy 
coalition was gaining momentum focusing on arguments resonating with policymakers and 
their constituents, Frohnmayer failed to construct politically salient advocacy arguments that 
directly undermined the oppositional advocacy coalition.  
 

Frohnmayer’s Tenure: The Aftermath 

Arts advocates in the policy arena thought that Frohnmayer’s background in both 
religion and law would be useful in combating attacks from the religious right and conservative 
policymakers. Ultimately, his failure to leverage the skills of policy entrepreneurship toward 
coalition building prevented Frohnmayer from forming strategic alliances with policymakers 
and the arts constituency. Frohnmayer’s failure to find coalition management success 
prohibited him from organizing a successful defense against further attacks from the 
oppositional advocacy coalition and antagonistic or retaliatory actions from the arts 
constituency. As a result of these two types of policy entrepreneurship failure, Frohnmayer 
was ultimately unsuccessful in the policy entrepreneurship goal of agency leadership.  

Agency efforts were predominantly spent defending the agency and public arts funding. 
Defensively making a case for public arts funding in the face of potential agency elimination 
is distinctly different from proactively making a case for the arts to increase or strengthen an 
existing advocacy coalition. Frohmayer’s attempts to steer the conversation away from artistic 
freedom and obscene art controversies toward geographic access and art education were 
unsuccessful with policymakers. Frohnmayer was forced to resign only two years into the job 
(Frohnmayer, 1993). This was the final confirmation of his overall failure to harness the power 
of policy entrepreneurship. 

As a result of the NEA 4 case, one of the larger artist-based controversies during 
Frohnmayer’s tenure (Zeigler, 1994), the agency was restricted from giving out any additional 
grants to individual artists except in the areas of Literature and Jazz. From the agency’s and 
arts constituents’ vantage point, this was not an optimal resolution to censorship concerns that 
had persisted since the agency’s creation. State Arts Agency leaders, realizing that there was 
an opportunity for increased power and resources, collectively called for restriction of the 
NEA’s autonomy, which would increase theirs (Gamarekian, 1990b). As a result, they enjoyed 
increased federal allocation percentages and operational autonomy; a demonstration of lost 
political control and agency autonomy for the NEA. 

As the head of a federal agency, Frohnmayer’s lack of policy entrepreneurship success 
in the policy arena would normally result in dire consequences for the agency. However, an 
alternative to Frohnmayer’s leadership presented itself with the Independent Commission that 
was charged with investigating the granting processes of the NEA in response to the Serrano 
and Mapplethorpe granting controversies (The Independent Commission, 1990). This group 
provided some of the characteristics of a successful policy entrepreneur by focusing on 



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procedural changes that garnered bipartisan support. The Commission also leveraged the 
support of policymakers and the less controversial factions of the arts advocacy coalition by 
displaying both “technical feasibility and value acceptance” Burgess, 2006, p. 123). The 
Independent Commission Report was used extensively to assist with the Reauthorization of 
the NEA. This report, especially during this time of controversy and disarray for the agency, 
helped ward off agency consequences such as closing the agency, complete defunding, or 
folding of the agency into another federal institution or structure that are common in instances 
of policy entrepreneurship failure (Burgess, 2006).  

 
Conclusion: Lessons Learned 

My research demonstrates a method for systematically investigating policy 
entrepreneurs in ways that are more nuanced than simply relying on appropriations amounts 
or agency autonomy. I offer three different types of policy entrepreneurship success and 
provide additional insight into exactly why Frohnmayer was considered a failure in the policy 
arena. My analysis does not argue for a fundamental change in the perception of Frohnmayer 
as an agency leader and policy entrepreneur. Instead, it offers an additional understanding of 
the specific ways in which agency leaders can manage policy change or orchestrate purposeful 
policy equilibrium in service to their agency and their agency agenda.  

Frohnmayer’s time as chair was notorious due to the widespread perception that he was 
unable to gain significant allies in the arts subgovernment and was a “political liability” 
(Wyszomirski, 1995, p. 13). My investigation uncovers critical nuance beneath this perception. 
This study demonstrates the importance of policy entrepreneurs figuring out how to 
rhetorically mirror or complement their advocacy coalition. Even when the advocacy coalition 
appears to be completely at odds with agency leaders, success in coalition management 
requires finding common rhetorical ground – whether it is with the advocacy coalition in its 
entirety, or with a curated faction of the coalition.  

This study utilizes a policy entrepreneurship lens to assess Frohnmayer’s abilities as a 
policy entrepreneur. This lens focuses on the rhetoric of dominant actors within the arts 
subgovernment. Arguably, given the systemic processes of oppression that exists throughout 
the public policy arena, “dominant actors” could also be read as privileged or a proxy for 
White, Eurocentric, and predominantly male (Carnes, 2013; Naff, 2001; Novkov, 2008). A full 
investigation of Frohnmayer, and any Chairperson of the NEA, should include an analysis of 
their policy entrepreneurship in relation to marginalized voices. My study focused on data from 
the policy arena, newspapers and agency documents alongside an analysis of Frohnmayer’s 
memoir of his time as Chairman. While this focus does not provide a full analysis, my methods 
do provide a more robust analysis than was previously available and lays the groundwork for 
analysis of policy entrepreneurs that is inclusive of, or even focuses on, marginalized voices. 
Rushton (2003) has already investigated the inadequacies of economic analysis when 
investigating public arts funding through a multiculturalvi lens. Further work to conduct policy 
analysis on public arts funding can and should determine theoretical lenses and methods that 
explicitly incorporate and champion traditionally marginalized voices to counter the 
longstanding practices of silencing them.  

                                                
vi This was the term used in the citation. 



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By defining three distinct avenues for policy entrepreneurship success – agency leader, 
advocacy coalition manager, and oppositional respondent – my work suggests that a policy 
entrepreneur may find success in one area without necessarily achieving success in another. 
Cases where a policy entrepreneur is successful in one area (e.g., is a successful agency leader), 
without finding success in the other two areas (e.g., as an advocacy coalition manager or 
oppositional respondent) can provide more field-building information about policy 
entrepreneurship in context. The findings of this investigation suggest an ideal ordering of 
achieving policy entrepreneurship success. Successful coalition management can provide a 
base of support to help policy entrepreneurs achieve success as an oppositional respondent. 
Success as an advocacy coalition manager and oppositional respondent can then lead to an 
easier path toward achieving agency leadership success. There is potential for additional 
theory-building and testing when looking at differences in policy entrepreneurship success or 
failure, and varying degrees of those successes and failures (e.g., initiating large-scale policy 
change vs. smaller-scale policy change) in times of policy punctuation and equilibrium.  

The more nuanced aspects of this study raise some additional questions for 
investigation. Because Frohnmayer’s case involved the general public in ways not common 
for an agency like the National Endowment for the Arts, the amount of public attention may 
make this case special. Data regarding the involvement of the general public as a negative 
audience or compounded context suggest that policy entrepreneurs should focus on issue 
management in the smaller context of the subgovernment to avoid needing to respond to a 
large-scale crisis in a time of punctuation. For example, concerns over censorship and the 
“appropriate” types of art for government funding existed within the arts constituency in the 
time leading up to the creation of the NEA and remained a concern throughout Frohnmayer’s 
tenure. If this issue were addressed when it was only a concern in the arts constituency, perhaps 
the space for controversy, which reached its peak during the Frohnmayer case, would not have 
existed in the same way. In addition to causing rifts among arts advocates, the continued 
existence of the same policy concern may have been a causal factor in creating conditions that 
encouraged the oppositional advocacy coalition.  

This investigation was successful in that the steps I took did provide the information 
necessary to make a more nuanced assessment of Frohnmayer’s failure as a policy entrepreneur 
than has been offered by others discussing arts policy entrepreneurship. This led to additional 
insights about policy entrepreneurs in general, offering alternative definitions of success that 
better reflect the three main facets of policy entrepreneurship work for agency leaders 
operating in the policy arena. By incorporating all facets of the arts subgovernment, my 
assessment acknowledges that agency leaders do not operate in a vacuum. They must operate 
in their specific political context, which includes oppositional advocacy coalitions of varying 
strengths, policy arenas that house amenable or hostile policymakers, and a supportive or 
antagonistic advocacy coalition. My methods take into account those possibilities and include 
means of identifying and assessing various political contexts.  

 
 

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