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Here’s what PAGR had to say about the regs
PROPOSED LOBBYING DISCLOSURE REGULATIONS
PROPOSED RULEMAKING-53 Pa.B.435 (January 19, 2008)
Sections of the Proposed Regulations attempt to expand and amend, rather than implement, certain of the Act’s provisions. Those sections of the Proposed Regulations are contrary to law and must be revised.
Contrary to the Act’s express provisions, the proposed regulations would expand the definition of “lobbying” to include the monitoring of legislative action or administrative action, without any requirement that there be some effort to influence that legislative action or administrative action.
Contrary to the Act’s express provisions, the Proposed Regulations would redefine lobbying to include merely paying a retainer to a lobbyist or lobbying firm “…even if the lobbyist or lobbying firm does not make direct or indirect communications or take any other action.”
The Proposed Regulations improperly would amend the Act to add “grants, the release of funds from the capital budget, loans and investment of funds” as part of “administrative action” that is subject to the Act.
The Proposed Regulations need to be clarified to make certain that the names of grassroots supporters are not required to be reported as “lobbyists”.
The Proposed Regulations should be clarified to state specifically that accepting the results of indirect communication (such as educational training or publications) does not result in the recipient being a “lobbyist”.
The Proposed Regulations should be clarified to state specifically that volunteers are not “lobbyists”.
Simplification, bright-line standards and substantial additional examples need to be added to the Proposed Regulations.
The proposed regulations would create an unduly complex regulatory system that will present problems to those who must comply with its provisions. The regulations will be read and followed by individuals and groups who may not have sophisticated legal counsel available to assist them.
The preamble to the Proposed Regulations should be revised to describe the actual fiscal impact on the private sector.
The President's Message
by Andy Hilt
 Spring has sprung, and if your calendar looks anything like mine the next few months are shall we say, full. I will be sending almost half of the month of April on the road for meetings, when I am in town I need to run my associations, represent them at the Capitol and my family mentioned something about wanting to see me. But I am working to clear my calendar to attend PAGR’s Lobbypalooza on April 25. We have a great line up for this event, filled with timely information. There will be a post election recap, a panel on campaign finance reform (how many hours would you save a week not sorting through all of those invitations?). We will also have a panel discuss how to use the new Open Records Law to access information for your clients and a session on lobby disclosure from three members of the regulation writing committee. Last but not least everybody’s favorite- Happy Hour.
Speaking of lobby disclosure; I would be remiss if I did not thank the board members would took the time to put together PAGR’s comments on the proposed regulations. There was a dedicated group that took the time out of there busy schedules to meet to discuss the regulations and then took the time to meet with IRRC and the legislature. Although many people contributed to this effort over the years, including Ted Mowatt, Judy Eschberger and Brian Barno who provided leadership as we moved through the process; I want to thank Tony Crisci for taking the bull by the horns and spearheading our comment effort.
I hope to see you at Lobbypalooza!
Lobbypalooza 2008
Will be taking place on April 25, 2008 at the Harrisburg Hilton.
Click here to download the registration form (PDF)
Meeting Notice
Monday April 7, 2008
11:30 am—12:30 pm
Firehouse Restaurant
Third Floor
606 N. 2nd Street • Harrisburg
Our Guests will be:
T.J. Rooney
Chairman, Pennsylvania Democratic Party
and
Luke Bernstein
Executive Director, Pennsylvania Republican Party
ALL 2008 MEMBERS WILL RECEIVE A FREE LUNCH. ALL GUESTS OF MEMBERS WILL BE CHARGED $20.
Questions can be sent to Christine Corrigan at 717-540-4391 OR INFO@PAGR.ORG.
THANK YOU.
2008 Board of Directors
Officers
President...................................Andrew Hilt
Vice President........................Peter Calcara
Secretary.....................................Deb Kisela
Treasurer.................................Gregg Taylor
Board of Directors
Association................Brinda Carroll Penyak
Corporate...................................Kris Snader
Lawyer...............................Judy Eschberger
Independent...............................Ted Mowatt
At Large......................................Tony Crisci
At Large.................................Mark Richards
Immediate Past President
Brian Barno
Executive Director
Christine Corrigan
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