Hi Mike,
A quick answer to your second question. Lobbying is defined as attempting to influence legislation (federal, state, or local). It does not include attempts to influence actions of the executive branch. Accounting for lobbying is very complex. It includes direct and indirect efforts, including volunteer efforts. The limits are defined by the IRS in terms of activity and as a fraction of our spending for our tax exempt purpose. We report all of this on the 990. And just as an aside, since I can be personally liable, and others before me, we are well within the limits. ;-)
73, Howard, WB2ITX
This raises a couple of questions from a newbie, who by admission, is not a lawyer.
"I believe this approach is consistent with the approach set forth in the Guidebook for Directors of Nonprofit Corporations previously distributed to all members of the Board."
Mr. Bellows, can you provide a quote from "the book" that is relevant to this discussion?
On another subject:
I see a notation on Page 103 of "the book" that states: "A corporation will not qualify for a 501(c)3 if it devotes a substantial part of its activities to lobbying, propaganda, or attempting to influence legislation." The ARRL sends proposed changes to the FCC all the time, and it seem a "substantial" legal effort and associated cost was placed on trying to get ARPA through congress. How is this NOT a violation? What is the legal definition of "substantial"?
Also, does what Mr. Bellows state above infer that the ARRL Board has agreed to be bound by the Guidebook for Directors of Nonprofit Corporations for its governance? I don't remember reading that anywhere in the By Laws, but I might have missed it.
73;
Mike
W7VO
On March 19, 2019 at 1:18 PM jbellows@skypoint.com wrote:
My point was two-fold: I believe it is generally better to have the facts first. Secondly, assuming there was a violation of staff policy, though that has not been established, this would be a personnel and administrative matter.
If it should subsequently be determined that there is a need for a policy change the Board may desire to act.
73,
Jay, KØQB
From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> On Behalf Of rjairam@gmail.com
Sent: Tuesday, March 19, 2019 2:14 PM
To: jbellows@skypoint.com
Cc: arrl-odv@reflector.arrl.org
Subject: [arrl-odv:28049] Re: Regarding The Filing of Comments to RM-11828 By An ARRL Employee
Generally as a condition of employment in my experience, public statements concerning an employer by employees is restricted as a matter of policy since it could be interpreted as an official statement from the company.
It also directly correlated to the position one holds. IIRC, Fusaro’s title is “director of operations.” As such public statements concerning ARRL policy or FCC petitions could be interpreted as being the opinion of the ARRL as it comes from a senior manager with the title “director.” That’s the major problem I have with it.
As for the venue, it is what it is. I think bringing this to the board and asking the CEO to address the board on this is entirely appropriate as the comment concerns a public action.
73
Ria
N2RJ
On Tue, Mar 19, 2019 at 2:36 PM <jbellows@skypoint.com> wrote:
If the question was truly for CEO Michel it is interesting that you chose to address it on ODV rather than directly with him.
Are asking if an ARRL employee is precluded from expressing his or her views in an FCC individual comment to a Rule Making proceeding as a condition of employment or suggesting an ARRL employee may only comment if permitted by the ARRL Board?
Jay, KØQB
From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> On Behalf Of John Robert Stratton
Sent: Tuesday, March 19, 2019 12:51 PM
To: arrl-odv@reflector.arrl.org; Michel, Howard, WB2ITX (CEO) <wb2itx@arrl.org>
Subject: [arrl-odv:28047] Regarding The Filing of Comments to RM-11828 By An ARRL Employee
Howard
All Board Members — Directors and Vice-Directors — are prohibited from filing individual comments on FCC petitions filed or supported by the League. To my knowledge, the Board has not authorized employees to make such filings.
In light of the foregoing, would you be so kind as to please explain Mr. Fusaro's most recent filing in connection with RM-11828?
Thanks.______________________________________
John Robert Stratton
N5AUS
Director
Legislative Director
West Gulf Division
Office: 512-445-6262
Cell: 512-426-2028
P.O. Box 2232
Austin, Texas 78768-2232
______________________________________
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Ria Jairam, N2RJ
Director, Hudson Division
ARRL - The national association for Amateur Radio™
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n2rj@arrl.org
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-- Howard E. Michel, WB2ITX Chief Executive Officer ARRL, The National Association for Amateur Radio® 225 Main Street, Newington, CT 06111-1494 USA Telephone: +1 860-594-0404 email: hmichel@arrl.org