Tnx for the expansion on definitions, Dave. I wasn't sure if there was a legal difference between someone taking a message clearly written and distributed only to members and passing it out (e.g. via BB) or a message intended for members but sent to groups we knew would be about 50% nonmembers. 73, CU sn. Jim Weaver, K8JE, Director ARRL Great Lakes Division 5065 Bethany Rd. Mason, OH 45040 E-mail: k8je@arrl.org, Tel.: 513-459-1661 ARRL - The national association for Amateur Radio -----Original Message----- From: Sumner, Dave, K1ZZ [mailto:dsumner@arrl.org] Sent: Tuesday, May 12, 2009 11:03 AM To: arrl-odv Subject: [arrl-odv:17747] RE: [arrl-odv:17734] RE: [arrl-odv:17731] Clubs in PA14? Jim, the distinction is between direct lobbying and grassroots lobbying. Direct lobbying includes anything we encourage our members to do to influence legislation. Grassroots lobbying encompasses anything we encourage the general public (i.e. non-members) to do to influence legislation. We are not prohibited from engaging in grassroots lobbying. However, 501(c)(3) organizations are much more limited in how much they can spend on grassroots lobbying than on direct lobbying. It is my understanding that communications directed at members but that incidentally may reach non-members fall into the direct lobbying category, particularly if the expenditure is minimal. I don't think communicating with affiliated clubs is a problem, although a purist probably would distinguish between the clubs that are required to have 51% ARRL membership and those that are not. 501(c)(3) organizations have the option to elect to have the provisions of 501(h) of the Internal Revenue Code apply to expenditures to influence legislation. We have not elected to do so because our expenditures have never come close to exceeding the loose "insubstantial" test that has traditionally applied to lobbying by 501(c)(3) organizations. Making the 501(h) election would establish clear limits on what we could spend, which would be somewhat safer (particularly if we anticipate that our lobbying activity might increase). It would change how we complete Part VI of the Form 990, which might require an accounting change. 73, Dave K1ZZ -----Original Message----- From: K8JE [mailto:K8JE@ARRL.org] Sent: Monday, May 11, 2009 6:37 PM To: arrl-odv Subject: RE: [arrl-odv:17734] RE: [arrl-odv:17731] Clubs in PA14? Dave, The following questions relates to the reason that we do not make positions in the Legislative Action Program available to non-ARRL members. Affiliated clubs are loosely required to have no fewer than 51% percent of their members belong to ARRL. If one assumes that all clubs have no more than 51% of members as ARR: members, would there be a concern that sending requests for support of our legislative activities to all affiliated clubs represent a risk of the League promoting these activities to an excessive number of nonmembers? Would we need to be sure to send these requests only to clubs that have a minimal percent (to be defined) of ARRL members rather than to send them to all affiliated clubs? Jim Jim Weaver, K8JE, Director ARRL Great Lakes Division 5065 Bethany Rd. Mason, OH 45040 E-mail: k8je@arrl.org, Tel.: 513-459-1661 ARRL - The national association for Amateur Radio -----Original Message----- From: Bill Edgar [mailto:n3llr@earthlink.net] Sent: Monday, May 11, 2009 6:01 PM To: arrl-odv Subject: RE: [arrl-odv:17734] RE: [arrl-odv:17731] Clubs in PA14? Dave, Thanks for your reply. I agree with you that some clubs will have membership overlap with congressional districts, but I don't think all of them do. A DX club would undoubtedly have memberships in multiple congressional districts, but we have some local affiliated clubs that membership would be in a single congressional district. I would think a representative or senator getting a letter from a club with their constituents as members would get more attention. What would it hurt for a club to send a letter advocating a position to a representative? Would it be easier to run the affiliated club address through the same database that we got the congressional districts for our members and then add the club mailing and email addresses to the list so as to make it easier for our legislative action volunteers to solicit member action? Thanks! - Bill N3LLR -----Original Message----- From: Sumner, Dave, K1ZZ [mailto:dsumner@arrl.org] Sent: Monday, May 11, 2009 10:49 AM To: arrl-odv Subject: [arrl-odv:17734] RE: [arrl-odv:17731] Clubs in PA14? Bill, in many if not most cases a club's membership is going to overlap into multiple Congressional districts. A targeted approach to affiliated clubs based on the club's mailing address is likely to generate a lot of confusion. Clubs certainly can be included in a general call to contact Congress. That said, it only took me a couple of minutes to pull the list of communities in PA-14 off the House Web site, compare it to the list of affiliated clubs in WPA, and determine that the only club addresses that are potentially in the district are those in Pittsburgh itself. Dave K1ZZ -----Original Message----- From: n3llr@earthlink.net [mailto:n3llr@earthlink.net] Sent: Monday, May 11, 2009 10:02 AM To: arrl-odv Subject: [arrl-odv:17731] Clubs in PA14? Please understand this is in no way a complaint with Dan Henderson. Both our DLAC and I see tremendous opportunity here. I received the attached note from our division's DLAC. What would it take to add affiliated clubs to the grass roots member listing by congressional districts so the clubs are included in legislative action bulletins and requests? - Bill N3LLR -----Original Message----- From: David Prestel Subj: Clubs in PA14? Date: Mon May 11, 2009 8:27 am To: n3llr@arrl.org Bill: I have sent out messages regarding House Bill HR2160 to all 100 of the 140 members in PA14 for whom we have email addresses. I asked Mr. Henderson if we had any way of identifying clubs in PA14 and he said that there was no way to do that. Something to think about for the future: Get lists of clubs for each of the House and Senate districts in the Atlantic Division. While our 501(c)3 status prevents the League from lobbying folks who are not members, nothing would prevent Joe or Jane Ham from speaking up about legislation at their local club meeting. Dave