8
Clean Water 501(c)(3) and the Sierra Club 501(c)(3) act largely as conduits for their
respective 501(c)(4)s and appear to rely on their partner 501(c)(4)s as the “central command”
for implementation of charitable-purpose program activities. Nature Conservancy and Friends
of the Earth have relatively autonomous program relationships with their 501(c)(4)s, while
League of Conservation Voters is moving from a somewhat reliant to more autonomous
relationship with their 501(c)(4). As the chart shows, all the organizations experienced some
change across time in amounts transferred.
To determine whether the fiscal relationship between components of the complex
organization has implications for advocacy programming, we specifically examined lobbying
activities conducted by 501(c)(3) charitable organizations and compared them with 501(c)(3)
transfers to 501(c)(4) social welfare organizations (as determined above). Table 2 provides a
picture of lobbying expenditures from FY 1998 to 2000 in the 501(c)(3) component. For these
years the data suggest that the existence of and changes in lobbying expenditures of the
501(c)(3) are related to 510(c)(3) transfers to the 501(c)(4) when compared to Table 1. Most
significantly, where a large percentage of 501(c)(3) expenditures are transferred to the
501(c)(4), the 501(c)(3) shows no funded lobbying program activity (Clean Water, Sierra Club).
Table 2: Lobbying Expenditures in Five Environmental 501(c)(3) Organizations
Total Lobbying
Expenditures
Friends of the
Earth
Clean Water
League of
Conservation
Voters
Sierra Club
Nature
Conservancy
FY 1998
$76,468
0
$14,210
0
$993,396
FY 1999
$102,896
0
$23,307
0
$863,667
FY 2000
$111,849
0
$656,071
0
$3,191,930
Source: NCCS Core Files
Convention