Grassroots Lobbying

Definition

Grassroots lobbying is defined as a program addressed to the general public, a substantial portion of which is intended, designed or calculated primarily to influence state legislation. RCW 42.17A.640

Typical grassroots lobbying expenditures include:

• newspaper advertisements to support proposed legislation,
• hiring a person to organize public meetings in order to influence action on issues being considered by the legislature,
• creating or maintaining websites, purchasing e-mail lists, or hiring someone to conduct other online activities, and
• hiring signature gatherers to circulate petitions for an initiative to the Legislature.

The Washington State Legislature recently updated legislation regarding grassroots lobbying through House Bill 1317. Click here to see the updated sections of RCW 42.17A.640.

Disclosure

Registration Requirement

Any person or entity making grassroots lobbying expenditures not reported by a registered lobbyist, a candidate, or a political committee exceeding $700 in the aggregate in a one-month period or exceeding $1,400 in the aggregate in any three-month period must register as a sponsor of a grassroots lobbying campaign. Exception: If an organization sends a notice about pending legislation to its members, or a corporation sends a similar message to its stockholders, the expenses related to these activities are not reportable as grassroots lobbying.

A campaign must register and file its initial grassroots lobbying report (PDC Form L-6) within 24 hours of the initial presentation to the public when that occurs during the period beginning 30 days before the regular legislative session through the end of that session, or during any special session.

Any other time of the year, grassroots lobbying campaigns must register with the PDC within five days of the initial presentation to the public. Thereafter, sponsors file monthly reports on the 10th of the month covering the preceding calendar month. When the campaign is finished and the last report is being filed, check the final report box.

Please note that any grassroots lobbying campaigns that also meet the definition of electioneering communication will need to also report via a C-6. (WAC 390-16-063)

Sponsor Identification

Any advertising or mass communication produced as part of the campaign must include the following disclosures.

• All written communications need to include the sponsor’s name and address and all radio and television communications need to include the sponsor’s name. 
• If the sponsor is a political committee controlled directly or indirectly by an individual, corporation, union, association or other entity, the communications need to include the name of that individual or entity.
• If a communication or advertisement costs $1,000 or more, it needs to include a list of the campaign’s top five contributors as described in RCW 42.17A.350. If one of those contributors is a political action committee, follow disclosure requirements under RCW 42.17A.350(2).
• RCW 42.17A.640 describes the requirements for sponsor identification on written communications, television and radio broadcasts. 

Alternative Disclosure Methods

Lobbyists can relieve their employers from the responsibility of filing an L-6 report by including grassroots lobbying expenditures on their L-2 reports, provided that the grassroots campaign is financed out of the employer's existing funds. If the employer conducts a special fundraising effort or accepts funds from other sources to finance the grassroots lobbying, L-6 reporting is required (and expenses would not be included on the L-2).

Note that even if a lobbyist employer files an L-6 report covering grassroots lobbying activities, a lobbyist must still disclose on his or her L-2 any of his or her employer's lobbying-related expenditures for public relations, telemarketing or polling activities.

Candidates and political committees who sponsor grassroots lobbying campaigns do not need to file L-6 reports, whether they use existing funds or receive funds from outside sources. Instead, the contribution and expenditure activity, including that related to grassroots lobbying, is fully reported on their campaign disclosure reports (the "C" series).