Emerging Problems of Citizen Participation
D. Stephen Cupps, West Virginia College of Graduate Studies
Over the last decade and a half the increased activity, involvement, and influence of public interest groups and citizen organizations has become one of the most distinctive features of American administration.' Citizen groups have besieged administrative agencies and courts at every level of government with demands that they be allowed to participate fully in administrative proceedings, that they be given greater access to agency information, and that they be permitted to present any and all evidence in behalf of their interests before appropriate administrative and judicial tribunals. They have skillfully cultivated the press to broaden their appeal to administrative and political officials, established effective, full-time lobbying organizations, and in some cases have put together sophisticated professional staffs which rival the agencies' own in their ability to grasp the intricacies and complexities of public policy issues. Furthermore, both the participants themselves and knowledgeable observers have predicted that the torrent of citizen suits and public interest activity seen thus far is only a small fraction of the deluge yet to come.2 On the whole, reaction to this surge of citizen participation has been positive. The general assumption is that broadened participation is desirable because it increases the representa-tiveness and responsiveness of our administrative and political institutions, heightens citizens' sense of political efficacy, and acts as an important check on the abuse of administrative discretion. Yet in spite of the proven accomplishments of citizen groups in some policy areas, there is a growing body of data to support the contention that public participation which is automatic, unrestrained, or ill-considered can be dangerously dysfunctional to political and administrative systems. The purpose of this article is to explore the "other side" of the public participation issue * This article analyzes the problems which have accompanied the growth of the citizen participation and public interest movements. The principle prob-lems identified are the potential shortsightednesso f the administrative response to citizen demands, problems of representation and legitimacy, the style and tactics of citizen groups, and the absence of sophisticated cost-benefit analysis of public interest policies and programs. The authors uggestst hat public participation which is not carefully ordered and constrained by administrators can lead to poorly conceived, unrepresentative, and costly policy deci-sions. Administratorsa re chiefly responsiblef or the integrity of the administrativep rocess, and sensitivity to citizen demands is no substitute for independent, carefully reasoned, professional judgments regarding the nature of the public interest in each new administrativesi tuation. by identifying some of the problems that have accompanied the growth of citizen advocacy in politics and administration. Examination of emerging trends suggests that public officials must cease to accept uncritically each new instance of citizen participation and every new effort to extend its operation and impact into additional areas of the political and administrative system. Administrators must begin to inquire into the form, style, and objectives of public participation, as well as the conditions under which it can function most effectively. Finally, administrators should recognize the limits of the device as a means of providing solutions to highly complex D. Stephen Cupps is associate professor and director of the MPA Program at the West Virginia College of Graduate Studies. He has taught at Princeton and the University of California, Santa Cruz, and has served as a consultant to organizations such as the National Aeronautics and Space Administration, Union Carbide Corporation, and various state and local governmental agencies. He is currently at work on a book dealing with the role of public interest groups and citizen organizations in administrative affairs. SEPTEMBER/OCTOBER197 7 This content downloaded from 183.88.117.226 on Sat, 27 Jun 2015 13:52:14 UTC All use subject to JSTOR Terms and Conditions CITIZEN PARTICIPATION and many-sided administrative issues and prob-lems. The Affirmative Impact of Citizen Participation It is important at the outset to acknowledge the substantial contribution of citizen groups and public interest organizations to current adminis-trative theory and practice. The increased activity and participation of these groups in political and administrative affairs are designed, at least in part, to cultivate the political consciousness of the American public, stimulate widespread and ef-fective participation by citizens, and thus enhance the responsiveness and legitimacy of political institutions. Citizen groups have been remarkably effective in creating public issues out of problems which otherwise might never reach a level of serious public debate or controversy. Matters once considered private are now seen as properly the subject of public discussion and decision. Citizen advocates have sought to place basic personal and moral issues and values at the center of political discourse, introducing "quality of life" con-siderations and a sense of individual dignity and personal worth explicitly into public policy equations. Perhaps more important, they have insisted that society's failure to recognize and address these issues is not simply private misfortune, but public injustice calling for the direct intervention of governmental authority. Most of these groups seem to exhibit, in the words of James Elden, " . .. a vision of politics that transcends government as merely the mechanics of allocating public resources among elite interests."3 Public interest organizations and citizen groups have placed a premium on openness of political and administrative proceedings and the free flow of public information. Their unremitting pressure has consistently forced agencies away from restrictive information policies, aiding concerned citizens in their efforts to scrutinize and evaluate administrative action.4 This has enabled citizen groups and their spokesmen to participate meaningfully in public policy decisions at an early stage, before policies are fixed and while effective advocacy is still possible. On a broader scale, these groups now constitute an effective check on the exercise of administrative discretion, forcing administrators to structure and confine their discretion and making them more sensitive to the implications of their non-actions, or decisions not to act, as well as their affirmative uses of discretionary power.5 In the long run this subtle but unmistakable intrusion on the anticipated reactions of politicans and bureaucratsm ay be one of the most significant consequences of increased citizen action. At a minimum it suggests that the impact of these groups cannot be measured in terms of their overt activities alone; the simple fact of their existence has now become almost as important as the programs, policies, and pro-cedures they are attempting to promote. Emerging Problems Despite these impressive accomplishments, the growth of the public interest movement has been paralleled by several disquieting trends with implications for administrators at every level of government. For purposes of simplicity and order, we may group into a few broad categories most of the problems of public participation as it is currently developing: the potential short-sightedness of political responses to the citizen participation movement; problems of repre-sentation and legitimacy; problems associated with the style and tactics of public interest groups and their spokesmen; and the absence of sophisticated cost-benefit analysis of citizen group policies and programs. One of the major perils posed by the citizen participation movement is the potential that it offers for overenthusiastic and shortsighted ad-ministrative responses to the demands of public interest groups and citizen organizations. As administratorsp erceive the emergence of new and powerful interests in their program areas, they are generally quick to recognize the advantages to be gained by responding, or appearing to respond, to the demands being made by these new forces. An agency's ability both to recognize and to react to new constituencies in its environment is one measure of its political sophistication and, ultimately, of its long-run ability to survive in a highly competitive political arena. Problems arise, however, as administrators seek to demonstrate that they are open and receptive to the public interest movement and sympathetic to the views and interests of its spokesmen. Citizen groups, environmentalists, and consumers often seem to pressure agencies to act in behalf of the public before the consequences of such action can be fully assessed by the agency or by others likely to be affected by the action. In several cases the SEPTEMBER/OCTOBER 1977 479 This content downloaded from 183.88.117.226 on Sat, 27 Jun 2015 13:52:14 UTC All use subject to JSTOR Terms and Conditions PUBLICA DMINISTRATIONR EVIEW Consumer Product Safety Commission has been accused of moving precipitously to warn the public about safety defects in certain products, or to completely prohibit the continued marketing of others, only to reverse itself a short time later on the basis of new test data or additional information on the product.6 Unfortunately for the companies involved, the damaging publicity and resulting loss of sales and trust in the companies' products cannot be so easily reversed. Another side of this same coin is the pressure brought to bear on administrators and public officials to cling to existing environmental and consumer policies despite mounting evidence that these policies are either misguided or unworkable. Because they do not wish
ปัญหาที่เกิดขึ้นของประชาชนมีส่วนร่วม Stephen D. Cupps เวอร์จิเนียตะวันตกวิทยาลัยบัณฑิตศึกษา Over the last decade and a half the increased activity, involvement, and influence of public interest groups and citizen organizations has become one of the most distinctive features of American administration.' Citizen groups have besieged administrative agencies and courts at every level of government with demands that they be allowed to participate fully in administrative proceedings, that they be given greater access to agency information, and that they be permitted to present any and all evidence in behalf of their interests before appropriate administrative and judicial tribunals. They have skillfully cultivated the press to broaden their appeal to administrative and political officials, established effective, full-time lobbying organizations, and in some cases have put together sophisticated professional staffs which rival the agencies' own in their ability to grasp the intricacies and complexities of public policy issues. Furthermore, both the participants themselves and knowledgeable observers have predicted that the torrent of citizen suits and public interest activity seen thus far is only a small fraction of the deluge yet to come.2 On the whole, reaction to this surge of citizen participation has been positive. The general assumption is that broadened participation is desirable because it increases the representa-tiveness and responsiveness of our administrative and political institutions, heightens citizens' sense of political efficacy, and acts as an important check on the abuse of administrative discretion. Yet in spite of the proven accomplishments of citizen groups in some policy areas, there is a growing body of data to support the contention that public participation which is automatic, unrestrained, or ill-considered can be dangerously dysfunctional to political and administrative systems. The purpose of this article is to explore the "other side" of the public participation issue * This article analyzes the problems which have accompanied the growth of the citizen participation and public interest movements. The principle prob-lems identified are the potential shortsightednesso f the administrative response to citizen demands, problems of representation and legitimacy, the style and tactics of citizen groups, and the absence of sophisticated cost-benefit analysis of public interest policies and programs. The authors uggestst hat public participation which is not carefully ordered and constrained by administrators can lead to poorly conceived, unrepresentative, and costly policy deci-sions. Administratorsa re chiefly responsiblef or the integrity of the administrativep rocess, and sensitivity to citizen demands is no substitute for independent, carefully reasoned, professional judgments regarding the nature of the public interest in each new administrativesi tuation. by identifying some of the problems that have accompanied the growth of citizen advocacy in politics and administration. Examination of emerging trends suggests that public officials must cease to accept uncritically each new instance of citizen participation and every new effort to extend its operation and impact into additional areas of the political and administrative system. Administrators must begin to inquire into the form, style, and objectives of public participation, as well as the conditions under which it can function most effectively. Finally, administrators should recognize the limits of the device as a means of providing solutions to highly complex D. Stephen Cupps is associate professor and director of the MPA Program at the West Virginia College of Graduate Studies. He has taught at Princeton and the University of California, Santa Cruz, and has served as a consultant to organizations such as the National Aeronautics and Space Administration, Union Carbide Corporation, and various state and local governmental agencies. He is currently at work on a book dealing with the role of public interest groups and citizen organizations in administrative affairs. SEPTEMBER/OCTOBER197 7 This content downloaded from 183.88.117.226 on Sat, 27 Jun 2015 13:52:14 UTC All use subject to JSTOR Terms and Conditions CITIZEN PARTICIPATION and many-sided administrative issues and prob-lems. The Affirmative Impact of Citizen Participation It is important at the outset to acknowledge the substantial contribution of citizen groups and public interest organizations to current adminis-trative theory and practice. The increased activity and participation of these groups in political and administrative affairs are designed, at least in part, to cultivate the political consciousness of the American public, stimulate widespread and ef-fective participation by citizens, and thus enhance the responsiveness and legitimacy of political institutions. Citizen groups have been remarkably effective in creating public issues out of problems which otherwise might never reach a level of serious public debate or controversy. Matters once considered private are now seen as properly the subject of public discussion and decision. Citizen advocates have sought to place basic personal and moral issues and values at the center of political discourse, introducing "quality of life" con-siderations and a sense of individual dignity and personal worth explicitly into public policy equations. Perhaps more important, they have insisted that society's failure to recognize and address these issues is not simply private misfortune, but public injustice calling for the direct intervention of governmental authority. Most of these groups seem to exhibit, in the words of James Elden, " . .. a vision of politics that transcends government as merely the mechanics of allocating public resources among elite interests."3 Public interest organizations and citizen groups have placed a premium on openness of political and administrative proceedings and the free flow of public information. Their unremitting pressure has consistently forced agencies away from restrictive information policies, aiding concerned citizens in their efforts to scrutinize and evaluate administrative action.4 This has enabled citizen groups and their spokesmen to participate meaningfully in public policy decisions at an early stage, before policies are fixed and while effective advocacy is still possible. On a broader scale, these groups now constitute an effective check on the exercise of administrative discretion, forcing administrators to structure and confine their discretion and making them more sensitive to the implications of their non-actions, or decisions not to act, as well as their affirmative uses of discretionary power.5 In the long run this subtle but unmistakable intrusion on the anticipated reactions of politicans and bureaucratsm ay be one of the most significant consequences of increased citizen action. At a minimum it suggests that the impact of these groups cannot be measured in terms of their overt activities alone; the simple fact of their existence has now become almost as important as the programs, policies, and pro-cedures they are attempting to promote. Emerging Problems Despite these impressive accomplishments, the growth of the public interest movement has been paralleled by several disquieting trends with implications for administrators at every level of government. For purposes of simplicity and order, we may group into a few broad categories most of the problems of public participation as it is currently developing: the potential short-sightedness of political responses to the citizen participation movement; problems of repre-sentation and legitimacy; problems associated with the style and tactics of public interest groups and their spokesmen; and the absence of sophisticated cost-benefit analysis of citizen group policies and programs. One of the major perils posed by the citizen participation movement is the potential that it offers for overenthusiastic and shortsighted ad-ministrative responses to the demands of public interest groups and citizen organizations. As administratorsp erceive the emergence of new and powerful interests in their program areas, they are generally quick to recognize the advantages to be gained by responding, or appearing to respond, to the demands being made by these new forces. An agency's ability both to recognize and to react to new constituencies in its environment is one measure of its political sophistication and, ultimately, of its long-run ability to survive in a highly competitive political arena. Problems arise, however, as administrators seek to demonstrate that they are open and receptive to the public interest movement and sympathetic to the views and interests of its spokesmen. Citizen groups, environmentalists, and consumers often seem to pressure agencies to act in behalf of the public before the consequences of such action can be fully assessed by the agency or by others likely to be affected by the action. In several cases the SEPTEMBER/OCTOBER 1977 479 This content downloaded from 183.88.117.226 on Sat, 27 Jun 2015 13:52:14 UTC All use subject to JSTOR Terms and Conditions PUBLICA DMINISTRATIONR EVIEW Consumer Product Safety Commission has been accused of moving precipitously to warn the public about safety defects in certain products, or to completely prohibit the continued marketing of others, only to reverse itself a short time later on the basis of new test data or additional information on the product.6 Unfortunately for the companies involved, the damaging publicity and resulting loss of sales and trust in the companies' products cannot be so easily reversed. Another side of this same coin is the pressure brought to bear on administrators and public officials to cling to existing environmental and consumer policies despite mounting evidence that these policies are either misguided or unworkable. Because they do not wish
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