problems. Although there are clear indications that these complaint systems do have an impact on priority setting and control and enforcement activities of local environmental officials (Kostka and Mol, 2013), such bottom up pressure still plays only a very minimal role.

Public hearings form a more institutionalized arrangement for participation in China’s environmental policy-making. The best-known example concerns public hearings in the Environmental Impact Assessment (EIA) procedure, as formalized in the 2002 EIA law and its implementation measures. Zhao’s (2010) study of a public hearing concerning renovations to the Imperial Summer Palace (Yuan Ming Yuan Park) and Johnson’s (2013) study on the siting of waste incinerators illustrate that such a legal obligation to organize consultation with citizens does not mean that it always takes place in a meaningful way. Another example of participation through public hearings takes place in the field of setting tariffs for drinking water and wastewater (Zhong and Mol, 2008). Here, various interest groups as well as citizens participate in a public hearing on plans to increase drinking water tariffs and wastewater fees. Any government proposal needs to have at least two-third majority of the votes in the public hearings in order to be able to be implemented.

Citizens also put pressure on local governments to enforce pollution standards by exposing local polluters through the media. The media is influential in shaping both public and government officials’ perceptions of environmental issues, but particular attention is placed on issues that have immediate implications for citizens’ lives. For instance, the media heavily covers PM 2.5 pollution issues but pays much less attention to less visible pollution issues such as heavy metal pollution. Media reports also tend to focus more on specific events (e.g., a new polluting enterprise moving to a particular regions) than they do on pollution problems that develop gradually. As a result, local government agencies increasingly feel pressure to immediately respond to media reports and might sideline other equally pressing but less publically reported environmental problems (see Lora-Wainright, 2013).

Organized protests in cities have also recently helped to oust polluting factories and, in some cases, have succeeded in putting a stop to polluting projects and closing down polluting enterprises. However, the NIMBYist nature of many of these protests leaves the door open for offending enterprises to simply relocate to another locality. Recent research also suggests that most urban protests are oriented toward enterprises which come from other regions or other countries, while less attention is paid to polluting enterprises run by locals (Deng and Yang, 2013). One possible explanation is that urban citizens are not opposing pollution as such but only pollution from which they do not receive any benefits (Lora-Wainright, 2013; Deng and Yang, 2013). In summary, there is no linear relationship between the intensity of pollution and protest, whether citizens organize collectively depends on received benefits for locals, measurability, visibility, and many other circumstances.

# **Limited role of local NGOs**

Over the last few years, non-governmental organizations working on environmental issues have considerably increased in number but their influence is limited as they are not integrated in policy formulation processes and play a “supplementary role” at best. The number of environmental non-governmental organizations (ENGOs) has been rapidly increasing in China, including both officially registered and unregistered groups.<sup>18</sup> While reliable official numbers do not exist, estimates suggest that there are currently approximately 1,000 registered ENGOs,

> 18 This section draws from Kostka and Mol (2013).

31