Learning or Leaking? Enforcement Spillover Effects Within and Beyond the Firm

Abstract

We posit and find evidence consistent with a new mechanism of intra-firm enforcement spillovers: the leakage of scarce compliance resources across facilities within a firm. Using a facility-level panel data set of Clean Air Act (CAA) enforcement actions from 2005 to 2017, we find a facility is more likely to violate the CAA following penalties on its same-industry-same-state siblings. In contrast, there is no significant spillover across firms. We show that the intra-firm spillover is not due to changes in regulatory attention or production shifting. Instead, our results suggest it may result from the redeployment of scarce compliance resources across siblings. Consistent with this mechanism, we find compliance leakage only occurs at privately held firms and facilities that lack the resources to invest in pollution prevention. The findings contribute to understanding the efficacy of environmental enforcement and have important implications for intra-firm management of environmental performance and regulatory enforcement approaches.