Public Comments 2012

The New Progressive Alliance periodically makes Public Comments by itself or with other organizations to federal agencies and legislative bodies in the United States and Canada in support of the Unified Platform. These are the 18 comments we made in 2012. They are also mentioned in the Annual Reports.

  • May 2012 - Good Government Advocates Call on Governor to Sign CT Disclosure Bill: “Stand By Your Ad” Law Would Shine Light on Super PAC Abuses
  • May 2012 - Corporate Reform Coalition Breaks Record for Comments Sent to Securities and Exchange Commission on Corporate Political Spending
  • May 2012 - 38 Organizations Urge Senators to Vote for DISCLOSE Act of 2012
  • May 2012 - Title of Hearing: Hearing on Certain Expiring Tax Provisions concerning extension of the wind energy production tax credit
  • May 2012 - EPA Limit GHGs and Carbon for Coal Plants
  • May 2012 - End Pay-to-Play Politics Through Transparency: Oppose U.S. Senate Bill 1100 that Would Keep Political Spending in the Shadows
  • June 2012 - BLM: No Public Land for Coal
  • June 2012 - Secretary of the  Interior: No Public Land for Coal
  • July 2012 - End Pay-to-Play Politics Through Transparency: Ellison/Eshoo Amendment in US House of Representatives Would Cast Sunlight on Government Contracting
  • July 2012 - North Carolina anti-science bill
  • July 2012 - National Association of Insurance Commissioners (NAIC) on political spending
  • July 2012 - SEC on NAIC political spending
  • August 2012 - Save Jeju Island
  • September 2012 - FHFA allow clean energy home investments
  • September 2012 - Minister Kenney appeal of Kimberly Rivera (Canada)
  • October 2012 - Organizations Show Poll Supports Election Reform
  • November 2012 - The New Progressive Alliance with over 50 other Organizations Issue Joint Statement Pledging to Counter Threats to Free and Fair Elections
  • December 2012 - NPA Urges TRC to Oppose XL Pipeline

May 2012 - Good Government Advocates Call on Governor to Sign CT Disclosure Bill: “Stand By Your Ad” Law Would Shine Light on Super PAC Abuses

Hartford, CT. – A coalition of good government groups including Common Cause, People For the American Way, Public Citizen, Demos, Credo Action, Democracy 21 and the New Progressive Alliance are calling on Connecticut Governor Dannell Malloy to sign H.B. 5556, “Changes to Campaign Finance Laws and other Election Laws,” which just passed just passed the General Assembly. The bill would require public disclosure of major corporate and individual donors to Super PACs and other independent groups, bringing increased transparency and accountability to Connecticut’s elections.

The bill would strengthen existing “Stand By Your Ad” provisions, which require political ads to disclose the five top contributors. Additionally, individuals and corporations would no longer be able to use intermediaries to shield campaign contributions from public view.

“Since Citizens United opened the floodgates to massive amounts of undisclosed, unaccountable political spending, Connecticut has been on the forefront of the effort to limit the outsized influence that corporations and special interests have on our democracy,” said Cheri Quickmire, Executive Director of Common Cause Connecticut. “By signing H.B. 5556 into law, the Governor can help us take an important step toward fairer elections. This bill would protect our candidates from anonymous attacks and corrupting ads. No longer would wealthy special interests be able to take advantage of the system by using shadowy front groups to evade Connecticut law and hijack our democratic system.

“We need H.B. 5556 to take effect and strengthen Connecticut’s disclosure laws before the 2012 elections. Secretive political spending has already had a major impact on Connecticut’s citizens, so we must act now to protect the integrity of our elections.”

http://www.pfaw.org/press-releases/2012/05/good-government-advocates-call-governor-sign-ct-disclosure-bill

 

May 2012 - Corporate Reform Coalition Breaks Record for Comments Sent to Securities and Exchange Commission on Corporate Political Spending

Statement of the Corporate Reform Coalition

A record number of people agree: The Securities and Exchange Commission (SEC) should regulate corporate political spending.

As of today, more than 178,000 comments have flowed into the agency, thanks largely to the unique bedfellows in our Corporate Reform Coalition, which includes institutional investors managing a combined total of $800 billion in assets, as well as public officials, legal scholars, good government groups, environmental organizations and more. This is a huge milestone: We have set the all-time record for comments submitted to the SEC.

Coalition members urged the agency – and encouraged their members and the public to weigh in – to create rules that would push corporate political spending into center stage. Specifically, the SEC should shine light on the corporate political activity of all publicly traded companies.

U.S. Supreme Court Justice Anthony Kennedy’s opinion in Citizens United v. Federal Election Commission – the case that opened the floodgates to corporate cash in elections – strongly endorsed comprehensive disclosure requirements. The SEC could and should put these assumed requirements in place for the publicly traded companies they oversee.

Several prominent law professors filed a petition with the SEC in August, urging it to require publicly traded companies to disclose their political spending. Numerous others have joined their voices to the call for SEC action, from state treasurers to representatives and senators to the former CEO of one of the country’s biggest mutual funds, John Bogle of Vanguard. Now, average investors and the public are getting in on the act and are calling for reform as well.

Mandating transparency is well within the SEC’s authority. The SEC should help the public and shareholders hold CEOs accountable for what they spend in politics. 

For more information about the Corporate Reform Coalition visit: http://corporatereformcoalition.org/.

To read the comments, visit: URL: http://www.sec.gov/comments/4-637/4-637.shtml

Credo Action

American Federation of  State, County, and Municipal Employees (AFSCME)

Center for Accountability in Political Spending (CAPS)

CAPS Members:

   Public Advocate Bill de Blasio, New York City

   Governor Pat Quinn, State of Illinois

   State Comptroller Tom DiNapoli, New York

   State Treasurer Janet Cowell, North Carolina

   State Treasurer Bill Lockyer, California

   State Treasurer Rob McCord, Pennsylvania

   City Controller Wendy Greuel, Los Angeles

   Representative William A. Current, Sr., North Carolina House of Representatives

   Representative James Pilliod, New Hampshire House of Representatives

   County Commissioner Toni Pappas, Hillsborough County, New Hampshire

Center for Corporate Policy

Citizen Works

Common Cause

Democracy 21

Democracy for America

Demos

 

Domini Social Investments LLC

   Adam M. Kanzer, Esq, Managing Director and General Counsel

Green Century Capital Management

   Kristina Curtis, Senior Vice President

Greenpeace

New Progressive Alliance

League of Conservation Voters

People for the American Way (PFAW)

Public Citizen

Social Equity Group

   Ron Freud and Duncan Meany

Sunlight Foundation

U.S. Public Interest Research Group (U.S.PIRG)

 

Trillium Asset Management Corporation, LLC

   Shelley Alpern, Vice President of Shareholder Advocacy

US SIF:  The Forum for Sustainable and Responsible Investment

Walden Asset Management,, a division of Boston Trust

   Timothy Smith, Senior Vice President, Director of ESG Shareowner Engagement

West Virginia Citizen Action

 

May 2012 - 38 Organizations Urge Senators to Vote for DISCLOSE Act of 2012

In a letter sent today, thirty-eight organizations urged all Senators to vote for S. 2219, the DISCLOSE Act of 2012, sponsored by Senator Sheldon Whitehouse and co-sponsored by 43 Senators.

The letter states:

The legislation would provide the public with basic information about campaign expenditures made by outside groups that are influencing federal elections and the donors financing these expenditures. The legislation would also provide timely disclosure by Super PACs and require outside groups which make campaign expenditures to take responsibility for their campaign ads.

According to the letter:

It is a cardinal rule of campaign finance laws that citizens are entitled to know the identities of the donors financing campaign expenditures to influence their votes, and the amounts they gave. This basic right to know has long been recognized by disclosure laws enacted by Congress and by Supreme Court decisions upholding the constitutionality of these laws.

The letter concludes:

The DISCLOSE Act of 2012 only contains disclosure requirements and does not contain special exceptions for any groups. The legislation is effective, fair and constitutional and deserves the support of Senators. Congress should enact the bill and provide citizens with the information they are entitled to know about who is giving and spending money to influence their votes.

A copy of the full letter and the names of the groups signing the letter, is enclosed below:


Dear Senator,

The undersigned organizations support S. 2219, the DISCLOSE Act 2012, sponsored by Senator Sheldon Whitehouse.

The legislation would provide the public with basic information about campaign expenditures made by outside groups that are influencing federal elections and the donors financing these expenditures. The legislation would also provide timely disclosure by Super PACs and require outside groups which make campaign expenditures to take responsibility for their campaign ads.

It is a cardinal rule of campaign finance laws that citizens are entitled to know the identities of the donors financing campaign expenditures to influence their votes, and the amounts they gave. This basic right to know has long been recognized by disclosure laws enacted by Congress and by Supreme Court decisions upholding the constitutionality of these laws.

In the Citizens United decision, the Supreme Court by an 8 to 1 vote upheld the constitutionality of disclosure requirements for outside groups making campaign expenditures. The Court stated:

The First Amendment protects political speech; and disclosure permits citizens and shareholders to react to the speech of corporate entities in a proper way.  This transparency enables the electorate to make informed decisions and give proper weight to different speakers and messages.

Polls show citizens strongly support disclosure by outside spenders.

The DISCLOSE Act of 2012 only contains disclosure requirements and does not contain special exceptions for any groups. The legislation is effective, fair and constitutional and deserves the support of Senators. Congress should enact the bill and provide citizens with the information they are entitled to know about who is giving and spending money to influence their votes. 

We urge you to vote for S. 2219 and to take all steps necessary for its enactment.

Alliance for a Just Society

Americans for Campaign Reform                            

Brennan Center for Justice

Campaign Legal Center  

Center for Media and Democracy                      

Citizens for Responsibility and Ethics in Washington

Citizen Works

Coalition for Accountability in Political Spending

Coffee Party USA 

Common Cause   

Corporate Ethics International/ Business Ethics Network 

Credo Action Network

Democracy 21

Democracy for America

Dēmos

Free Speech for People

Greenpeace

Harrington Investments, Inc.

Heartland Democracy

League of Women Voters

Main Street Alliance

MapLight

Michigan Campaign Finance Network

National People’s Action

New Progressive Alliance

NC Center for Voter Education

Ohio Citizen’s Action Money & Politics Project

People For the American Way

Public Citizen             

Sunlight Foundation

Trillium Asset Management, LLC

Union of Concerned Scientists

United Republic

Walden Asset Management, a division of Boston Trust & Investment Management  

WV Citizen Action Group

Wisconsin Democracy Campaign

Wolf-PAC

Zevin Asset Management, LLC

May 2012 - Title of Hearing: Hearing on Certain Expiring Tax Provisions

            The New Progressive Alliance respectfully urge Congress to extend the wind energy production tax credit (PTC) and make it as permanent as the fossil fuel subsidies. The PTC resulted in billions of dollars in private investment in homegrown American wind power each year. This in turn brings in construction jobs immediately, maintenance jobs in the long term, and generates revenue for our community schools and hospitals over the lifetime of the project. This in turn helps our national security and economic competitiveness. Increasing the amount of power that our country gets from clean, homegrown, affordable resources is an excellent thing for us to do – and this tax credit provides an incentive for the wind industry to continue to do just that.

In the past – unlike fossil fuel subsidies, tax credits, grants, guaranteed loans, and free clean ups – wind energy PTCs have been allowed to periodically expire with the predictable result of less wind energy. Denmark – a country scarcely bigger than metro Atlanta – produces 25% wind energy and is on track to produce 50% wind energy by 2020. The difference is public policy, not lack of technical expertise in the United States.

The New Progressive Alliance urges the committee to take up a permanent extension of the wind energy production tax credit right away.

May 2012 - EPA Limit GHGs and Carbon for Coal Plants

May 14, 2012

 

EPA Docket Center

Environmental Protection Agency

Mailcode: 2822T

1200 Pennsylvania Ave., NW

Washington, DC 20460

Docker ID No. EPA-HQ-OAR-2011-0660

 

Dear Administrator Jackson,

          The New Progressive Alliance respectfully asks you to please approve your proposed carbon pollution rule to limit carbon and greenhouse gas (GHG) emissions from new coal plants. 

Using your authority under the Clean Air Act to take action will do more than protect us from the global warming, perhaps the most serious long term threat to our planet. It will also lessen the threat to public health. In addition to coal plants emissions of arsenic, cadmium, lead, mercury, and selenium estimated to pollute 16 million gallons of water annually coal plants also dump more than two billion tons of dangerous carbon pollution each year. Another after effect is the toxic coal ash. In Georgia alone Coal companies dumped 1,541,900 tons of this toxic coal ash – and Georgia was only the fourth largest toxic ash dumping site. The Tennessee spill of over 106 billion gallons indicates the very real danger to public health. Failure to hold coal plants responsible for their own pollution will result in more asthma attacks, more infectious diseases, more heat-related deaths, more “bad air days,” respiratory complications, and other threats. In addition, global warming means more damage from storms, floods, and similar devastating extreme weather events.

          The New Progressive Alliance just wants a level playing field between fossil fuels and renewable energy. Fossil fuels receive many times the tax breaks, guaranteed loans, land grants, steady funding, and other breaks over renewable energy. In addition externalities such as clean up and health care are paid for by the government. Limiting carbon dioxide emissions from new coal plants is a step in the right direction for leveling the playing field. Please do the right thing for our future.

 

May 2012 - End Pay-to-Play Politics Through Transparency: Oppose Senate Bill 1100 that Would Keep Political Spending in the Shadows

May 15, 2012

The Hon. Joseph Lieberman, Chairman

The Hon. Susan Collins, Ranking Member

Committee on Homeland Security & Governmental Affairs

U.S. Senate

Washington, D.C. 20510

 

Dear Senator:

Our 14 civic organizations write to you in solid opposition to S. 1100, the so-called “Keeping Politics Out of Federal Contracting Act,” and urge the Senate to reject this legislation that would block public disclosure of campaign contributions and spending by government contractors.

This effort to keep the campaign money of government contractors in the shadows runs afoul of the honesty of our elections and the integrity of the government contracting process. Disclosure is the solution, not the problem.

The organizations writing in opposition to S. 1100 include: Campaign Legal Center, Center for Media and Democracy, Citizens for Responsibility and Ethics in Washington, Common Cause, Democracy 21, Demos, League of Women Voters, MapLight, New Progressive Alliance, Project on Government Oversight, Public Citizen, Sunlight Foundation, U.S. PIRG and Union of Concerned Scientists.

“Pay-to-play” is the all-too-common practice of a business entity making campaign contributions or expenditures in support of public officials with the hope of gaining a lucrative government contract. The timing and targeting of campaign contributions demonstrates that contractors seek access to politicians with oversight of contracting,[1] and interviews with contractors reveal that they believe this access helps them win contracts.[2] Just how frequently such pay-to-play corruption takes place is a matter of dispute, but there is no disputing that the public perceives this problem is widespread.

S. 1100, sponsored by Sen. Susan Collins (R-ME), would create a very dangerous obstacle to reining in pay-to-play abuses in government contracting.

Pay-to-play corruption thrives in the shadows. As long as the public is generally kept in the dark as to how much a corporation is spending on behalf of public officials and their respective parties, pay-to-play can be an exceedingly effective tool in winning government contracts. Though it is extraordinarily difficult for the public to connect the dots of which company is spending how much in support of which candidates, contractors and their lobbyists are not at all shy about selectively informing officeholders and party officials who they are supporting and who they oppose.

While officeholders generally know their financial benefactors, the public is routinely left in the dark. This dichotomy between what politicians know and what the public knows about contractor campaign money is the greatest single recipe for pay-to-play abuse in federal contracting.

One of the single most important means to rein in this type of pay-to-play abuse in government contracting is to create a system of full disclosure so that the public also knows which contractors supported which officeholders. This transparency in contractor campaign spending would provide the public with the means to discern when contracts are being awarded based on money rather than merit – and a powerful tool to check pay-to-play abuses in government contracting.

There is nothing new about the idea of requiring government contractors to disclose their campaign financial activity. More than a dozen states already impose special disclosure requirements on government contractors, and federal contractors have been disclosing their PAC contributions for decades.

Full disclosure of money in politics is overwhelmingly supported by the American public, and it is one of the most effective means to ensure that the integrity of the government contracting process is not being compromised by the campaign money of “insider” influence peddlers.

We strongly urge you to vote against S. 1100.

 

Sincerely,

 

Campaign Legal Center

Center for Media and Democracy

Citizens for Responsibility and Ethics in Washington

Common Cause

Democracy 21

Demos

League of Women Voters

MapLight

New Progressive Alliance

Project on Government Oversight

Public Citizen

Sunlight Foundation

U.S. PIRG

Union of Concerned Scientists



[1]  Roland Zullo, “Public-Private Contracting and Political Reciprocity,” Political Research Quarterly (2006) at 273-281.

[2]  Kimberly Palmer, “Schmooze or Lose,” Government Executive (2005) available at: www.govexec.com/features/1205-01/1205-01s4.htm

June 2012 - BLM: No Public land for Coal

 

June 24, 2012

 

Mr. Robert Abbey, Director

Bureau of Land Management

U.S. Department of the Interior

1849 C Street, NW, Room 5665

Washington, D.C. 20240

 

The Bureau of Land Management (BLM) plans to give Peabody Energy the rights to 721 million tons of publicly owned Wyoming coal for about $1 a ton, just so Peabody can sell it in Asia for $80 a ton, unleashing a massive amount of climate-change causing carbon pollution in the process. Coal companies get a huge windfall, the U.S. government gets a pittance in revenue, and climate change gets worse for all of us. Please reconsider.

June 2012 - Secretary of the Interior: No Public Land for Coal

 

June 24, 2012

 

The Honorable Ken Salazar

Secretary of the Interior

US Department of the Interior

1849 C Street, NW, Room 5665

Washington, DC 20240

 

The Bureau of Land Management (BLM) plans to give Peabody Energy the rights to 721 million tons of publicly owned Wyoming coal for about $1 a ton, just so Peabody can sell it in Asia for $80 a ton, unleashing a massive amount of climate-change causing carbon pollution in the process. Coal companies get a huge windfall, the U.S. government gets a pittance in revenue, and climate change gets worse for all of us. Please reconsider.

July 2012 - End Pay-to-Play Politics Through Transparency: Ellison/Eshoo Amendment in US House of Representatives Would Cast Sunlight on Government Contracting

July 18, 2012

U.S. House of Representatives

Washington, D.C. 20515

Dear Representative:

Our organizations write to you in strong support of the government contractor transparency amendment to H.R. 5856, sponsored by Reps. Keith Ellison (D-Minn) and Anna Eshoo (D-Cal.).

“Pay-to-play” is the all-too-common practice of a business entity making campaign contributions or expenditures in support of public officials with the hope of gaining a lucrative government contract. The timing and targeting of campaign contributions demonstrates that contractors seek access to politicians with oversight of contracting,[1] and interviews with contractors reveal that they believe this access helps them win contracts.[2] Just how frequently such pay-to-play corruption takes place is a matter of dispute, but there is no disputing that the public perceives this problem is widespread.

The Ellison/Eshoo amendment would help bring the government contracting process out of the shadows. The amendment would require federal contractors to disclose their contributions to federal political campaigns after a contract is awarded.

Pay-to-play corruption thrives in the shadows. As long as the public is generally kept in the dark as to how much a corporation is spending on behalf of public officials and their respective parties, pay-to-play can be an exceedingly effective tool in winning government contracts. Though it is extraordinarily difficult for the public to connect the dots of which company is spending how much in support of which candidates, contractors and their lobbyists are not at all shy about selectively informing officeholders and party officials who they are supporting and who they oppose.

While officeholders generally know their financial benefactors, the public is routinely left in the dark. This dichotomy between what politicians know and what the public knows about contractor campaign money is the greatest single recipe for pay-to-play abuse in federal contracting.

One of the single most important means to rein in this type of pay-to-play abuse in government contracting is to create a system of full disclosure so that the public also knows which contractors supported which officeholders. This transparency in contractor campaign spending would provide the public with the means to discern when contracts are being awarded based on money rather than merit – and a powerful tool to check pay-to-play abuses in government contracting.

There is nothing new about the idea of requiring government contractors to disclose their campaign financial activity. More than a dozen states already impose special disclosure requirements on government contractors, and federal contractors have been disclosing their PAC contributions for decades.

Full disclosure of money in politics is overwhelmingly supported by the American public, and it is one of the most effective means to ensure that the integrity of the government contracting process is not being compromised by the campaign money of “insider” influence peddlers.

We strongly urge you to support the Ellison/Eshoo government contractor transparency amendment.

Sincerely,

Campaign Legal Center

Center for Media and Democracy

Citizens for Responsibility and Ethics in Washington

Common Cause

Democracy 21

New Progressive Alliance

Project on Government Oversight

Public Citizen

Sunlight Foundation

Union of Concerned Scientists

US PIRG



[1]  Roland Zullo, “Public-Private Contracting and Political Reciprocity,” Political Research Quarterly (2006) at 273-281.

[2]  Kimberly Palmer, “Schmooze or Lose,” Government Executive (2005) available at: www.govexec.com/features/1205-01/1205-01s4.htm

 

July 2012 - North Carolina anti-science bill

July 14, 2012

 

The Honorable Governor Perdue

North Carolina

 

            The New Progressive Alliance urges you to veto H819, the Sea Level Rise Bill for both scientific and personal reasons.

            The scientific basis is North Carolina is particularly vulnerable because it has one of the fastest growing sea level rises in the world. It is important to examine all the evidence and all the options.

            The personal reason is that although the New Progressive Alliance is a nationwide organization with members in Australia and Canada, the principle founder, Anthony Noel, lives in Greenville, North Carolina. Many members live in the southern United States. Please do not embarrass all of us by placing a 4-year ban on using scientific data in coastal policy and regulatory applications. This legislation has already been made fun of on the comedy show The Colbert Report. Surely you see politicians outlawing science will make not just North Carolina but the entire southern United States a laughing stock.

            Please do the right thing for your state and this region.

 

July 2012 - National Association of Insurance Commissioners on political spending

July 16, 2012

Mr. Kevin M. McCarty

National Association of Insurance Commissioners

1100 Walnut Street, Suite 1500

Kansas City, MO 64106-2197

Dear Mr. McCarty,

As groups dedicated to bringing transparency to the political process, we write to request

that the National Association of Insurance Commissioners (NAIC) either adopt a model rule or

add additional questions to its annual statement requiring insurance companies to disclose all

political spending from corporate funds. Recent disclosures have revealed efforts by companies

to illicitly influence the 2012 elections. Corporate shareholders and policy holders are entitled

to know what insurance companies are doing with their investment dollars and hard-earned

insurance payments. Requiring disclosure of political spending also would help the NAIC

fulfill its mission to promote the public interest, guarantee the financial stability and solvency of

insurance companies, and support competitive markets.

The Supreme Court’s 2010 decision in Citizens United v. FEC dramatically changed

campaign finance and invalidated on constitutional grounds numerous rules regarding political

spending.1 As a result, corporations now enjoy the freedom to spend general treasury funds on

independent expenditures and electioneering communications. Since the decision, corporate

political spending has increased every fiscal quarter,2 and American insurance companies such

as Aetna and CIGNA have become major political players.3 Recently, for example, an apparent

filing error by Aetna revealed the company had made contributions of over $7 million to the

American Action Network and the Chamber of Commerce in 2011, with the apparent purpose of

influencing, at least in part, the 2012 elections.4

1 See Citizens United v. FEC, 130 S. Ct. 876 (2010).

2 Christopher P. Skroupa, Investors Want Disclosure of Corporate Political Contributions and

Lobbying Expenditures, Forbes, Apr. 20, 2012, http://www.forbes.com/sites/

christopherskroupa/2012/04/20/ investors-want-disclosure-of-corporate-political-contributionsand-

lobbying-expenditures-2/.

3 Id.; Aetna Life Insurance Company NAIC Annual Statement of Condition and Affairs, Part 1,

2011.

4 Letter from Melanie Sloan, Executive Director, Citizens for Responsibility and Ethics in

Washington (CREW) to Mark T. Bertolini, chairman, CEO and president, Aetna, Inc., June 14,

2012 (attached as Exhibit A).

Kevin M. McCarty

July 16, 2012

Page Two

At the same time, Citizens United upheld a number of disclosure requirements and

envisioned increased transparency in order to ensure corporate accountability and good

governance. The Court explained that “prompt disclosure of expenditures can provide

shareholders and citizens with the information needed to hold corporations and elected officials

accountable for their positions.”5 The expectation of the Supreme Court that more liberal

disclosure would result has, however, been unmet.

As insurance companies and other corporations have increased their political

contributions, shareholders have demanded disclosure of this spending. In a 2006 survey, 94%

of shareholders said corporations should be required to publicly disclose all political

contributions.6 Shareholder resolutions calling for increased transparency have surged, with 62

such resolutions brought for a vote in 2010, and 101 in 2011.7 In 2011, proxy statements for 25

companies in the S&P 100 included shareholder resolutions for greater political disclosure.8

Twenty of these companies received a proposal for increased disclosure from an institutional

investor.9 Indeed, shareholder interest in political expenditures has increased so significantly

that many corporations have voluntarily adopted policies requiring disclosure of political

spending.10 This trend likely will heighten shareholder expectations, increasing the need for all

corporations to disclose their political spending if they wish to maintain widespread support

from individual and institutional investors.

All public corporations are subject to the demands of shareholders, but insurance

companies must also answer to their policyholders. Individual and corporate policyholders have

a variety of insurers to choose from, and an insurance company’s decision to disclose political

5 Citizens United, 130 S. Ct. at 916.

6 Center for Political Accountability, “Corporate Political Spending: A Survey of American

Shareholders,” Mason-Dixon Polling & Research (2006), available at:

http://www.politicalaccountability.net/index.php?ht=a/GetDocumentAction/i/918.

7 Americans for Campaign Reform et al., File No. 4-637, Comments on Petition for Rulemaking

on Corporate Political Spending, Submitted by 21 Civic Organizations and Individuals 14,

available at: http://www.sec.gov/comments/4-637/4637-21.pdf.

8 The Committee on Disclosure of Corporate Political Spending, supra note 3, at 5.

9 Id.

10 Id. at 6.

Kevin M. McCarty

July 16, 2012

Page Three

spending may significantly impact this choice. Recent events prove policyholders have become

increasingly concerned with insurers’ lack of transparency. In April, 2012, for example,

policyholders and public interest advocates protested outside of CIGNA’s annual meeting.11

One protestor lamented that CIGNA “continues to hide how it uses its customers' premiums to

support political efforts.”12 Likewise, protestors surrounded WellPoint’s 2012 annual meeting,

where one demonstrator presented a petition allegedly signed by 15,000 people asking for

greater disclosure of political spending.13 Considering that one in every nine Americans

subscribes to a WellPoint plan, policyholder discontent with the company could have serious

ramifications.14

Refusing to disclose political spending also can negatively impact the financial stability

of an insurance company. A 2010 report analyzing 80 S&P 500 companies that have

voluntarily adopted disclosure policies found these companies had a 7.5 percent higher

industry-adjusted price/book ratio than companies that did not disclose their political spending.15

This correlation demonstrates that disclosure is not only feasible for large corporations, it is

desirable. Companies that are responsive to shareholder interests and communicate with their

investors and the public tend to have higher value. Two-thirds of CEOs surveyed in 2010 agree

that “the lack of transparency and oversight in corporate political activity encourages behavior

that puts corporations at legal risk and endangers corporate reputations.”16 Likewise, the

Committee for Economic Development has warned that where transparency is lacking,

“[c]orporate resources that might be better spent investing in an enterprise or otherwise building

11 Activists, Shareholders Tell CIGNA to Disclose Secret Spending on Political Front Groups,

http://healthcareforamericanow.org/2012/ 04/25/activists-shareholders-tell-cignato-

disclose-secret-spending-on-political-front-groups/ (last visited June 25, 2012).

12 Matthew Sturdevant, Protesters Criticize Cigna Executives' Pay, Money Spent To Squash

Health-Care Reform, Hartford Courant, Apr. 25, 2012.

13 Tom Murphy, Protestors Disrupt WellPoint Annual Meeting, Bloomberg Businessweek, May

16, 2012, available at http://www.businessweek.com/ap/2012-05/.

14 Peter Dreier, Citizens Confront WellPoint: Poster Child for Health Insurance Reform,

Huffington Post, Sept. 22, 2009 available at

http://huffingtonpost.com/peter-dreier/wellpoint-poster-child-fo_b_294343.html.

15 Americans for Campaign Reform, et al., supra note 5, at 13.

16 Committee for Economic Development, “New Business Poll Shows Discontent with

Undisclosed Campaign Expenditures Following Citizens United Decision,” Press Release (Oct.

28, 2010).

Kevin M. McCarty

July 16, 2012

Page Four

shareholder value” may be blindly funneled into political causes irrelevant to the interests and

goals of the company.17

In the wake of Citizens United, campaign finance has taken on an increased importance,

not just for lawyers and politicians but for individuals, institutional investors, and corporations.

Interest in disclosure of political spending has mirrored this expansion. Greater disclosure gives

companies a financial advantage and improves their reputation among investors and customers.

In 2011, the Committee on Disclosure of Corporate Political Spending petitioned the U.S.

Securities and Exchange Commission (SEC) to introduce a new rule mandating greater

disclosure of corporate political spending.18 In response to the petition, individuals,

organizations, company CEOs, government officials and others have submitted over 290,000

comments to the SEC.19

Accordingly, the NAIC should require disclosure of political spending from all insurance

companies, whether through adoption of a new model rule, adding new questions to the annual

statement blank, or by other means. A disclosure requirement from the NAIC would satisfy

shareholder demands, ensure uniformity across the insurance industry, promote the public

interest, ensure stability by preventing further protest and helping insurers retain loyal

customers, and advance the mission of the NAIC. For these reasons, we urge the NAIC to

require greater political disclosure from insurance companies.

Sincerely,

American Federation of State, County and Municipal Employees

Change To Win Investment Group

Citizens for Responsibility and Ethics in Washington

Government Accountability Project

Health Care for America Now

Main Street Alliance

Main Street Alliance of Oregon

17 Committee for Economic Development, “After Citizens United: Improving Accountability in

Political Finance,” Executive Summary (2011).

18 Id. at 1.

19 Comments on Rulemaking Petition: Petition to Require Public Companies to Disclose to

Shareholders the Use of Corporate Resources for Political Activities, File No. 4-637 (Sec. and

Exch. Cmm’n) available at http://www.sec.gov/comments/4-637/4-637.shtml. We understand

this is by far the most comments the SEC has received on any rulemaking petition.

Kevin M. McCarty

July 16, 2012

Page Five

Main Street Alliance of Washington

Maine Small Business Coalition

Mercy Investment Services, Inc.

New Progressive Alliance

OMB Watch

Public Citizen

U.S. PIRG

Walden Asset Management, a division of Boston Trust & Investment Management

West Virginia Citizen Action Group

July 2012 - SEC on NAIC political spending

 July 16, 2012

 

Ms. Elizabeth M. Murphy

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Dear Ms. Murphy,

We write to follow up to our letter of January 6, 2012, encouraging the Securities and Exchange Commission (SEC) to adopt a new rule in response to a Petition for Rulemaking (File No. 4-637) that would require disclosure of corporate political spending above a de minimis threshold. Recent revelations of efforts by companies to illicitly influence the 2012 elections highlight the importance of greater corporate transparency and the need for the SEC to issue regulations requiring greater disclosure of political expenditures by corporations.

The Supreme Court’s 2010 decision in Citizens United v. FEC dramatically changed campaign finance and invalidated on constitutional grounds numerous rules regarding political spending.1 As a result, corporations now enjoy the freedom to spend general treasury funds on independent expenditures and electioneering communications. Since the decision issued, corporate political spending has increased every fiscal quarter.2 In response to this kind of spending, both corporate shareholders and members of the public are calling on corporations to disclose their political expenditures.

1 See Citizens United v. FEC, 130 S. Ct. 876 (2010).

2 Christopher P. Skroupa, Investors Want Disclosure of Corporate Political Contributions and Lobbying Expenditures, Forbes, Apr. 20, 2012, http://www.forbes.com/sites/ christopherskroupa/2012/04/20/ investors-want-disclosure-of-corporate-political-contributions- and-lobbying-expenditures-2/.

3 The Committee on Disclosure of Corporate Political Spending, Petition for Rulemaking 8 (2011) available at http://blogs.law.harvard.edu/corpgov/files/2011/08/SEC-Petition.pdf.

4 Citizens United, 130 S. Ct. at 916.

At the same time, Citizens United upheld a number of disclosure requirements and envisioned increased transparency in order to ensure corporate accountability and good governance.3 The Court explained that “prompt disclosure of expenditures can provide shareholders and citizens with the information needed to hold corporations and elected officials accountable for their positions.”4 The expectation of the Supreme Court that more liberal disclosure would result has, however, been unmet.

Ms. Murphy

July 16, 2012

Page Two

As corporations have increased their political spending, shareholder demands for disclosure of this spending have followed. In a 2006 survey, 87% of shareholders said they would

have more confidence in investing in a corporation that had adopted rules providing for transparency and oversight in political spending.5 A majority of those surveyed said current regulations do not provide sufficient accountability of political spending.6 In 2011, 25 companies in the S&P 100 saw shareholder resolutions for greater political disclosure on their proxy statements.7 Twenty of these companies received a proposal for increased disclosure from an institutional investor.8 In the current proxy season, support for greater disclosure is again high among shareholders at many major corporations, including WellPoint, CVS Caremark, Windstream and CenturyLink, Inc.9 Furthermore, institutional investors plan to propose disclosure rules at several important corporations in 2012, including IBM, Boeing, Bank of American and Home Depot.10 Shareholder interest in political expenditures has increased so significantly that many corporations have voluntarily adopted policies requiring disclosure of political spending.11 This trend likely will heighten shareholder expectations, increasing the need for all corporations to disclose their political spending if they wish to maintain widespread support from individual and institutional investors.

5 Center for Political Accountability, “Corporate Political Spending: A Survey of American Shareholders,” Mason-Dixon Polling & Research (2006), available at: http://www.politicalaccountability.net/index.php?ht=a/GetDocumentAction/i/918.

6 Id.

7 The Committee on Disclosure of Corporate Political Spending, supra note 3 at 5.

8 Id.

9 Press Release, Center for Political Accountability, Strong Shareholder Support for CPA Model Political Disclosure Resolution Continues in 2012 Proxy Season (June 7, 2012).

10 Ronald D. Orol, More Boardrooms Target Political Spending, Wall St. J., Apr. 19, 2012, http://www.marketwatch.com/story/more-boardrooms-targeted-for-political -spending-2012-04-19.

11 The Committee on Disclosure of Corporate Political Spending, supra note 3, at 6.

August 2012 - Save Jeju Island

August 20, 2012

We at the New Progressive Alliance (NPA) support all efforts to save Jeju Island. Its unique ecology and culture cannot be replicated elsewhere. Our support includes the International Action Week and the efforts of the International Forum on Globalization. On September 7, 2012 we will post support on the NPA website and NPA Facebook.

September 2012 - FHFA allow clean energy home investments

September 13, 2012

Mr. Alfred Pollard, General Counsel

Attn: Comments/RIN 2590-AA53

Federal Housing Finance Agency, Eighth Floor

400 Seventh Street, SW.

Washington, DC  20024

Dear Mr. Pollard:

The New Progressive Alliance urges the Federal Housing Finance Agency (FHFA) to immediately drop its opposition to PACE. Investments as PACE  (Property Assessed Clean Energy) increase the value of a home, mean more jobs, and increase the ability of a homeowner to pay through less utility bills. This is in addition to a cleaner environment and less global warming for the next generation.  There is no evidence to contradict this and much to support it. 

Out of approximately 37,000 special assessment programs across the United States, apparently the only one FHFA is going out of its way to invalidate an entire home loan is this one concerning clean energy and energy efficiency. There is no factual basis to support this.

Finally, the Federal Housing Finance Administration (FHFA) is interfering in a homeowners right to invest in energy efficiency and renewable energy.

Please take the right action for homeowners, our environment, our economy, and our country.

September 2012 - Minister Kenney appeal of Kimberly Rivera (Canada)

September 19, 2012

The Honorable Immigration Minister Jason Kenney

Canada

            The New Progressive Alliance urges you to consider the appeal of Kimberly Rivera and let her stay in Canada on compassionate and humanitarian grounds.

Please consider the following in light of the experience of Manning and others under similar circumstances in the United States.


- Deserters are actually internationally protected in international law and refugee status can and should be granted to deserters who refuse to participate in a condemned military conduct, if they come from the US or anywhere. In the U.S., deserters are not protected by international law.
- Obama's administration has nothing to do with a decision to prosecute Rivera, it is up to her military command in Fort Carson which has already said it will arrest and lay charges for desertion immediately upon return to the US.
- It is not the prosecution that is persecution. The persecution is being imprisoned up to five years for refusing to be associated with war crimes - ie, refusing to commit breaches of the Geneva Conventions (and essentially losing her children, two of whom are Canadian).
- Kimberly would be unable to offer any evidence about war crimes in Iraq at her court martial. She cannot advance any reasons why she is refusing to serve. Such evidence is inadmissible, for example about breaches of the Geneva Conventions (or the breach of the UN Charter about going to war with Iraq - DR). She simply cannot present any argument or case why she deserted the military. (On the other hand, the court martial would hear evidence that Kimberly spoke out in support of deserting the military while in Canada and against the war itself, which would make her jail sentence longer. - DR)
- So far all three US war resisters deported by the Harper government served lengthy sentence in a military prison for doing the right thing.
- The point that Kimberly joined the army voluntarily is irrelevant. Kimberly did not join the military to commit breaches of the Geneva conventions, but came to understand the true nature of the war after joining.

Some day all these wars will be over. Please make sure Canadians will look back upon this time proud they did the right thing.

October 2012 - Organizations Show Poll Supports Election Reform

For Immediate Release:                                                         Contact:

October 25, 2012                                                                    Lauren Strayer, Demos

                                                                                                Lisa Gilbert, Public Citizen     

                                                                                                Mary Boyle, Common Cause

 

New Poll: Americans condemn high levels of corporate political spending, overwhelmingly support strong transparency and accountability reforms

 

Nearly 9 in 10 Americans agree that there is way too much corporate money in politics, and 51 percent strongly agree, according to a new poll released today by the Corporate Reform Coalition. The survey, conducted by Bannon Communications, found overwhelming support for strong, common sense reforms to ensure transparency and accountability for corporate political spending.

  • 81 percent of Americans agree that companies should only spend money on political campaigns if they disclose their spending immediately; 80 percent agree that companies should only spend money on political campaigns if they get prior shareholder approval.
  • Huge majorities of Americans across the political spectrum condemn corporate political spending and support strong reforms. For example, requiring corporations to get shareholder approval before spending money on politics is supported by 73 percent of both Republicans and Democrats, and 71 percent of Independents.
  • 84 percent of Americans agree that corporate political spending drowns out the voices of average Americans, and 83 percent believe that corporations and corporate CEOs have too much political power and influence.

 

More than 8 in 10 Americans (81%) believe that the secret flow of campaign spending is bad for democracy, and 87 percent agree that prompt disclosure of political spending would help voters, customers and shareholders hold companies accountable for political behavior. Unfortunately, the sources of corporate funds directed through third party intermediaries like the U.S. Chamber of Commerce remain largely hidden.

 

Americans are strongly in favor of common sense, achievable reforms that would increase transparency and accountability for corporate political spending, fight corruption, and lead to a more responsive and representative government.

  • 76% of Americans support a requirement that companies publicly disclose their contributions to groups - like the U.S. Chamber - that funnel money into politics.
  • 74% of Americans support a plan allowing candidates to run for Congress without raising large contributions by collecting small contributions and receiving limited public funds.
  • 74% of Americans favor requiring that the name of the company and its CEO appear in ads paid for by corporate political spending. 

Finally, Americans are ready to act to prevent their voices from being drowned out by corporate political spending. To protest a company’s political spending, 79% would refuse to buy a company’s product or services and 76% would sign a petition to the SEC supporting corporate disclosure.

“Americans deserve a democracy in which all people are equal and all voices are heard, not one where corporations can spend secret millions and create dependencies so our elected representatives are beholden to their interests,” said Liz Kennedy, Counsel at Demos, whose analysis of the poll results can be read here. “Americans have a right to know who is trying to buy our elections, and the time is long since past to enact strong, common sense requirements to ensure transparency and accountability. 

 “Secret corporate spending is appalling in a representative democracy, and this poll shows that the public agrees. One key remedy - critical for shareholders whose investments allow corporations to generate massive profits - is that the SEC move forward on issuing rules to require publicly traded companies to disclose their political spending,” said Lisa Gilbert, Director of Public Citizen’s Congress Watch division.

“This poll reflects what we are seeing at the state level,” said Susannah Goodman, Director of Corporate Accountability at Common Cause.  "Americans are fed up with secret corporate spending. They are ready to take action -- boycotts, divesting stock, signing petitions, protests - whatever it takes to send a strong message to corporations to keep their money out of our elections."

 

“The American people agree: money does not equal speech. But the Roberts’ court need not have the last word here. Though our pension funds and through regulators like the Securities and Exchange Commission, we can shed light on shadowy corporate spending in our elections. It’s time our rules and our laws matched the will of the people,” said CAPS Founder NYC Public Advocate Bill de Blasio.

 

“Americans across the political spectrum have long held transparency in campaign finance to be crucial to the success of democracy. This poll shows that the public wants to close the backdoors to secret political spending. Americans are ready to take action to bring secret corporate spending to the light and to hold accountable those companies – and their conduits like the U.S. Chamber of Commerce - who attempt to hide their spending” said Blair Bowie, Democracy Advocate at the U.S. Public Interest Research Group.

 

“Since Citizens United, nearly every poll that has asked about money in politics has shown that Americans are fed up with the amount of influence that money can buy. Those feelings have only gotten stronger during this election season that has been dominated by undisclosed corporate spending. Simple corporate disclosure measures aren’t just the right thing to do – they’re overwhelmingly supported by voters,” said Margery F. Baker, Executive Vice President for Policy and Program, People for the American Way.

 

Public Citizen, Demos, Common Cause, the Coalition for Accountability in Political Spending, U.S. PIRG, Greenpeace, People For the American Way, Public Campaign, Service Employees International Union, New Progressive Alliance, Citizens for Responsibility and Ethics in Washington, Main Street Alliance, Alliance for a Just Society, and Green Century Capital Management are working together as part of the Corporate Reform Coalition to bring transparency and accountability to corporate political spending.

 

Bannon Communications Research interviewed a randomly and scientifically selected group of 804 Americans who are 18 and over. The sample is based on demographic data from the U.S. Census Bureau to reflect age, area and gender distributions in the 2010 count. The margin of error for the entire national sample is plus or minus 3.8%. BCR conducted the interviewing on October 8- October 10, 2012. Brad Bannon of Bannon Communications can be reached at 202-320-4182 or brad@bannoncr.com.

Resources:

Read the Executive Summary from Bannon and the topline results: LINK

Read Demos’ Analysis of the Poll Results: LINK

Read Demos Explainer: What is a Corporation?: LINK

                                                                        ###

November 2012 - The New Progressive Alliance with over 50 other Organizations Issue Joint Statement Pledging to Counter Threats to Free and Fair Elections 

This week the New Progressive Alliance with more than fifty organizations to express their concern about two critical threats to our democratic system: corporate influence in elections and laws and official actions that suppress the vote.  Under the banner “Money Out, Voters In,” the organizations issued a joint statement pledging to fight special interest money in politics and to support the rights of all voters.

The statement reads:

Within the next week, citizens in every state will come together to cast their votes for President, Congress, and other state and local offices. The right to cast those votes – to elect leaders who represent us – is at the heart of our democratic system. But this year, that right is in danger.

Our system of fair and free elections is under attack on multiple fronts. The Supreme Court’s decision in Citizens United opened the floodgates for special interest money and corporate influence in politics. At the same time, a rash of voter suppression laws in more than 30 states has threatened to make voting difficult, if not impossible, for millions of Americans.

Throughout the history of our nation, powerful politicians and interest groups have tried to block eligible voters from casting a ballot. For much of the twentieth century, they used literacy tests or demanded poll taxes. Today they ask for photo voter ID, or create restrictive voter registration schemes. These laws, combined with the challenge posed by limitless corporate influence, strike at the very core of our democracy.

Our nation’s history has been a journey towards true equality and the promise of a government of, by and for the people. Just as we have overcome many obstacles to achieve that promise, we are now committed to standing up against the pervasive, corrupting influence of an electoral system that auctions offices to the highest bidder and suppresses the vote of millions of Americans.

No matter what happens on November 6th, these threats must be addressed on November 7th and beyond. Together with our allies across the political spectrum, we pledge to fight for the rights of all voters in our nation and to move that much closer to creating a more perfect union. The future of our democracy depends on it.

The New Progressive Alliance  helps the causes of peace, people, and the planet through ten goals at http://newprogs.org/unified-progressive-platform-ratified  Verification of these needs with references can be found at the following places.

Economy – http://newprogs.org/blog/2011/11/10/economy-under-democraticrepublican-uni-party 

Economic Graphs – http://newprogs.org/blog/2012/03/02/economic-graphs  

Election Reform - http://newprogs.org/blog/2012/10/01/election-reform

Transparency – http://newprogs.org/blog/2012/02/27/transparency-under-democraticrepublican-uni-party

Whistleblowers – http://newprogs.org/blog/2011/11/09/whistleblowers-under-democraticrepublican-uni-party

It is being released jointly by the following organizations: 350.org; AFL-CIO; AIDS United; All Education Matters; Alliance for a Just Society; Alliance for Justice; American Sustainable Business Council; American-Arab Anti-Discrimination Committee (ADC); Asian & Pacific Islander American Vote; Ben & Jerry’s; Center for Media and Democracy; CODEPINK; Common Cause; Communications Workers of America; Constitutional Accountability Center; Consumer Action; CREDO Action; DC Vote; Democracy 21; Democracy Unlimited; Democrats.com; Demos; Ethical Markets Media, Florida; Food & Water Watch; Franciscan Action Network; Free Speech For People; Greenpeace; Institute for Agriculture and Trade Policy; International Union, United Automobile, Aerospace and Agricultural  Implement Workers of America, UAW; Leadership Conference on Civil and Human Rights; Main Street Alliance; Move to Amend Coalition; MoveOn.org Political Action; NAACP; National Center for Transgender Equality; National Congress of Black Women, Inc.; National Council of Jewish Women; National Gay and Lesbian Task Force; The New Bottom Line; New Progressive Alliance; People For the American Way; Pesticide Action Network North America; Project Vote; Public Campaign; Public Citizen; Rock the Vote; RootsAction.org; Sierra Club; U.S. PIRG; United for a Fair Economy; United Steelworkers International Union; unPAC; WarIsACrime.org; and We the People Campaign.

It is also available at http://www.moneyout-votersin.com.

December 2012 - NPA Urges TRC to Oppose XL Pipeline

The Sunset Commission

The Texas Railroad Commission (TRC)

December 18, 2012

      I am writing on behalf of the New Progressive Alliance. Although we supported candidates in 23 states in the recent election, the largest number of supported candidates by far was from Texas.

      Our concern is the complete lack of supervision and due process shown by the Texas Railroad Commission in granting Keystone XL eminent domain authority. Under eminent domain law, private property is allowed to be taken only for public use and only after just compensation. Neither of these requirements was met.

      The solution would both save money and follow the law.  Allow the TRC to expire and have the Texas Legislature pass the following laws.

  • Require full disclosure through a Material Data Safety Sheet on any hazardous materials transported. Tar Sands/Dilbit is much more toxic to both humans and the environment than conventional crude oil. There should be no “proprietary chemical” rights. Public safety is far more important.
  • That common carrier status be granted only after public hearings with full notice to landowners. The landowners should have a right to contest and appeal any adverse findings. The landowners should also be entitled to be compensated for the diminished value of their land because of any pipeline.
  • That there be a fee for any common carrier to cover court proceedings.

Both justice and long established case law suggest these common sense remedies.

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