What is NWRA’s Political Action Committee?
The National Waste & Recycling Association Political Action Committee (NWRA PAC) is chartered as a “separate segregated fund” under NWRA’s direction and governed by federal law administered by the Federal Election Commission. NWRA PAC collects individual personal contributions from NWRA members as well as from member companies’ own PACs and distributes those funds to candidates for the U.S. Senate and the U.S. House of Representatives who share the views of the waste and recycling industry.
Can we contribute corporate money to NWRA PAC?
No. Under federal law, NWRA PAC contributions to congressional candidates may only come from money raised from personal, partnership, (non-corporate) LLC or company PAC funds— corporate funds are strictly prohibited.
However, NWRA member companies can contribute corporate funds to the NWRA PAC Administrative Fund to help pay for the PAC’s operating expenses such as credit card processing fees, recognition gifts for our major donors, printing, postage, among other expenses. Supporting the Administrative Fund as an NWRA PAC Corporate Sponsor makes NWRA PAC contributions go further and allows those dollars to be put to their intended use.
Does NWRA PAC accept cash, check or credit card for contributions?
NWRA PAC accepts personal checks, Visa, Master Card, American Express and Discover cards. NWRA PAC also allows contribution pledges to be paid in installments. While federal law permits cash contributions of up to $100, NWRA PAC does not accept cash contributions.
Are there limits on how much one person can contribute?
Yes. An individual may contribute a maximum of $5,000 per calendar year to NWRA PAC.
Does a contributor to NWRA PAC have to fill out a contribution form?
Yes. Federal law requires a political action committee to have a completed form listing the contributor’s name, mailing address, business and title/occupation.
Can an individual contribute to more than one political action committee?
Yes. There is no limit to the number of PACs to which an individual may contribute.
Can a chapter set up a “check-off” plan so NWRA PAC contributions may be automatically deducted from dues and service charges, or can it send out an annual “NWRA PAC statement” billing its members?
No. Federal law forbids business groups from using “check-off” plans. A “billing” scheme would be an illegal solicitation under federal law. Furthermore, funds received would be corporate funds and this would also be illegal.
Who can ask for contributions?
NWRA national and chapter staff falls under a series of complex rules regarding solicitation. They must fulfill several requirements before they may ask someone for a contribution to NWRA PAC. NWRA members, however, are not employees of NWRA or NWRA PAC and are free to solicit contributions at will.
Can a chapter send a check as a contribution prorated among its members?
Usually not. A chapter is an incorporated entity and is also considered an affiliate of NWRA. Since it’s illegal to contribute corporate funds to a federal PAC, chapter funds cannot be used. However, as an affiliate of NWRA, a chapter may act as a “collection agent,” accept personal contributions from its members and forward them to NWRA PAC in a single chapter check.
This is allowable provided that (a) the funds all were collected from individuals as personal checks or cash and (b) the chapter forwards a list of the individual contributors and all their required information along with the chapter check. The chapter may hold the required signatures on file. For NWRA PAC’s recordkeeping purposes, however, it is better if all of the individual contribution cards accompany the chapter check.
Can a chapter form its own federal PAC or a statewide PAC to contribute to federal candidates?
No. Chapters are considered affiliates of NWRA. As such, the funds they raise and distribute for federal candidates would be considered as coming from NWRA PAC itself. Contributions and campaign disbursement limits would be aggregated, and any such local federal PACs would have to report to the Federal Election Commission (FEC) in conjunction with NWRA PAC. NWRA chapters may form their own state PACs for the purpose of contributing to state and local candidates as may be permissible under their states’ laws.
Does NWRA PAC accept contributions from a chapter’s state/local PAC?
No. Many states allow corporate contributions to state-level PACs and political candidates. On account of federal prohibitions on corporate funds, transfers of funds to NWRA PAC from local PACs in those states where corporate contributions are legal are not permissible. In order to maintain strict compliance with federal law, NWRA PAC errs on the side of caution and does not accept any funds from state/local PACs.
Can NWRA PAC accept contributions from an individual who is not affiliated with a NWRA member?
Yes. While NWRA and chapter staff are prohibited from soliciting such contributions, if such contributions are volunteered, they may be accepted. The same information is required as for an NWRA member.
Can someone other than a United States citizen contribute to NWRA PAC?
No. Only U.S. citizens may contribute to federal political campaigns. Contributions from foreign sources are illegal.
Will NWRA PAC accept anonymous cash contributions?
Although a PAC may accept anonymous cash contributions of up to $50, such contributions raise the scrutiny level of the FEC and, therefore, NWRA PAC will not accept anonymous contributions.
How do you decide which candidates receive NWRA PAC support?
NWRA asks its members and state chapter leadership for recommendations of candidates they believe would be helpful with NWRA’s national legislative priorities and these suggestions are given the most weight. In addition, NWRA conducts an examination of candidates’ legislative records (federal and/or state if they are elected officials) and stated positions on the issues, which helps inform the process. Membership on committees of jurisdiction over issues of importance to the waste and recycling industry is an important factor, while congressional leadership is also a key element. Some campaign contributions are recommended based upon longstanding relationships that Association members or staff have with candidates. The need to develop, maintain and enhance relationships beneficial to the waste and recycling industry is an overarching consideration. A race’s competitiveness helps determine the likelihood of a contribution. Contributions are not made in out-of-cycle races nor to both candidates running in the same race.
Does NWRA contribute to contested primary campaigns?
Not usually; however, if a candidate in a primary has a close relationship with a chapter or an NWRA member and if that candidate has a reasonable chance of success, he or she may be eligible to receive NWRA PAC support in the primary.
Does NWRA PAC contribute only to one party?
No. Candidates are judged on a wide variety of criteria relating to their potential value in achieving the goals of the waste and recycling industry. Party affiliation is not one of those criteria.
Is there a maximum level that a PAC may legally contribute to a campaign?
Yes. A PAC is limited to a maximum contribution to a candidate of $5,000 per election. In most election cycles (two years for the House of Representatives, six years for the Senate), that would mean allowable contributions of $5,000 for a primary and $5,000 for a general election. In cases of a special election or run-off election, this would allow the PAC an additional maximum contribution of $5,000 for each.
Is there a minimum level for a PAC to contribute to a campaign?
No. However, the primary reasons for contributing to a candidate are to help get that candidate elected and to gain the candidate’s attention so we may develop, maintain and enhance a relationship beneficial to the waste and recycling industry. Small contributions do little to further either objective. On account of this, NWRA PAC has set its own limit of a minimum contribution of $1,000 to a candidate for the U.S. House of Representatives or the U.S. Senate.
Who hands out NWRA PAC campaign contributions?
One objective of our political program is to develop long-term relationships between candidates and their own constituent NWRA members. To develop these relationships, NWRA encourages NWRA PAC donors to deliver these contributions from the PAC to candidates in their home states or districts whenever possible and NWRA staff attends Washington, D.C., events based upon those contributions. This doubles the impact of every contribution made. NWRA PAC checks will never be mailed into a candidate without there being a corresponding fundraising event or in-person meeting between him or her and an NWRA member or staffer.
