Is enabling citizens to complain about public services an effective way of improving government services, or should we be more concerned about their accuracy and reliability? In new research, Jonathan Colmer, Mary Evans, and Jay Shimshack evaluate the usefulness of citizen complaints by analyzing environmental quality complaints in Texas together with regulator investigations. They find that citizen complaints are associated with a very strong regulatory response; complaints about a facility are linked to a 75-percentage point increase in the likelihood of an investigation. These investigations are then up to four times more likely to uncover environmental violations than investigations not triggered by complaints.

Citizen complaints feature prominently in the oversight of public services ranging from policing and corruption to environmental protection and occupational safety regulation. Complaints are a way for citizens provide information about a specific environmental, health, or safety concern directly to a regulatory agency, typically any time day or night online or by phone.

Supporters of enabling citizens to complain about services argue that they improve transparency and promote government accountability, and that they enhance procedural justice by allowing individuals to participate directly in decisions that influence their families and communities. Complaints may improve regulatory efficiency if local agents have better information than officials, especially if they draw attention to concerns that would otherwise go undetected.

However, citizen complaints may not always be reliable and may reallocate limited monitoring and enforcement resources away from more harmful problems. There is of course no guarantee that public complaints are accurate or address significant concerns. In addition, citizen complaints could reduce procedural and distributional justice if there is an unequal regulatory response to complaints across income, race, or other factors.

Investigating public attitudes to citizens’ complaints about the environment

Despite theoretical ambiguity and policy prominence, the nature and effects of citizen complaints is poorly understood. In new research, we provide new facts on public attitudes and new evidence on the efficiency and distributional implications of environmental citizen complaints.

A natural starting point for exploring the potential advantages and disadvantages of citizen complaints is to simply ask the public about their attitudes towards such complaints. With this in mind, we conducted a nationally representative survey of US residents. Survey evidence reveals that, on average, the public believes that reports of pollution concerns promote environmental justice, improve public transparency and accountability, and provide high-quality local information. On average, the public does not believe that citizen complaints waste public resources or allow environmental activists and NGOs to have undue influence on environmental agencies.

While survey evidence helps inform attitudes towards complaints, it cannot reveal whether complaints genuinely affect the efficiency and equity of environmental regulation. For this we need more formal analysis. We therefore explore if and how environmental regulators respond to citizen complaints in the real world.

We combine data on the universe of citizen complaints made to the Texas Commission on Environmental Quality (TCEQ) between 2003 and 2019 with regulator investigations, notices of violations, and notices of enforcement at more than 23,000 Texas facilities regulated under two Clean Air Act programs.

“Air quality monitoring Dish Texas” (CC BY 2.0) by Jeremy Buckingham MLC

Citizen complaints are linked to investigations which can uncover environmental harm

We find that citizen complaints are associated with a very strong regulatory response. On average, complaints against a facility are associated with a nearly 75-percentage point increase in the likelihood of receiving an investigation across the two months following a complaint, compared to the likelihood in the previous month. Since investigations are typically uncommon — with less than three percent of firms receiving an investigation in any given month — these are big changes. The authors find that that these results are driven by citizen complaints and not confounding factors. They also find no evidence of a differential regulatory response to complaints along margins of race or income.

We then show that the investigations triggered by citizen complaints uncover significant harm. Complaints against a facility are associated with significant increases in the likelihood of formal notices of violation and enforcement for up to four months. Investigations associated with complaints are two to four times more likely to uncover violations than investigations not triggered by complaints. Violations detected during investigations triggered by complaints are more severe on average than violations detected through other processes.

Taken as a whole, these findings show that complaints play a significant role in pollution oversight. Citizen complaints are popular with the public. Citizen complaints do support the legal mandate of environmental agencies to uncover and sanction significant environmental violations. Citizen complaints do not compromise equity.

Citizen complaints also appear to enhance regulatory efficiency in the context of our study. Put differently, results are consistent with citizen complaints serving as an effective targeting mechanism. If complaint and non-complaint investigations have similar costs, results are consistent with the regulatory “bang per buck” from complaint activities being considerably higher than traditional regulatory monitoring activities.

• This article is based on the LSE CEP Discussion paper No. 1903, Environmental citizen complaints.
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• Note: This article gives the views of the author, and not the position of USAPP – American Politics and Policy, nor the London School of Economics. 
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