Comments to JCOPE on Proposed Guidance on the Scope of Lobbying

SUMMARY

In a comment letter on proposed guidance issued by the NYS Joint Commission on Public Ethics (JCOPE), the Committee on Government Ethics supported JCOPE’s effort to expand the definition of “lobbying” to incorporate those who use their influence with government officials to facilitate lobbying, directly and through grassroots efforts. With regard to direct lobbying, the committee believes that the proposal should include not only persons having direct interaction with a public official but also those who participate directly in crafting or delivering the communication at issue. With respect to grassroots lobbying, the committee supports the proposal as written but noted a few relatively minor exceptions.