Center for the Defense of Free Enterprise
February 8, 2002
Commissioner Charles O. Rossotti
Commissioner of Internal Revenue Service (N:C)
1111 Constitution Avenue, NW
Washington, DC 20224
Re: Environmental Working Group, Inc.
Dear Commissioner Rossotti:
We write to alert the Internal Revenue Service to serious violations of the tax laws governing nonprofit organizations. Public information shows that The Environmental Working Group (EWG), a 501(c)(3) organization, has violated its tax status by unlawfully engaging in excessive lobbying and politicking. The evidence leads us to believe the violations are flagrant and we submit specific documentation for your scrutiny. We believe that EWG's tax exemption should be revoked immediately because the organization:
· Functioned as an illegal political action organization, including pressuring Vice President Gore during his run for President;
· Operates as a lobbying organization, including receiving a $1.6 million grant to lobby the 2002 Farm Bill;
· Lobbied the California legislature for a year without registering as lobbyists
· Submitted false or misleading reports to the IRS about its lobbying expenditures;
· Hid its lobbying political expenditures while operating as a project of the Tides Foundation.
Such actions by a “public charity” are clearly illegal and should (at a minimum) result in revocation of the organization’s tax-exempt status.
The earliest EWG grant records in the Foundation Center database show donations from six foundations to the Environmental Working Group in 1989, when EWG was located in the offices of The Island Press in Washington, D.C.  Two of these 1989 grants show that EWG was one of the roughly 250 “projects” which are operated under the tax-exempt status of The Tides Foundation, which is based in San Francisco. Subsequently, EWG was shifted to the newly-created Tides Center, Inc. (the “Tides Center”), which was established as “the management side” of The Tides Foundation. EWG first appears in the Tides Foundation Form 990 for the fiscal year ending April 30, 1995, with the listing of Kenneth A. Cook, the EWG president, as one of Tides Foundation’s five highest paid employees and the listing of $46,909 in Tides grants to EWG. The non-private foundation status of Tides Foundation was challenged by the IRS between 1977, the filing year, and 1982, when the IRS ruled that Tides Foundation was not a private foundation. Neither the details of EWG’s relationship to Tides Foundation nor EWG’s lobbying and political activities are reported in Tides Foundation’s IRS filings for any year. In effect, EWG was a secret organization hiding under the Tides umbrella.
The organization emerged from the Tides umbrella and formally incorporated as a District of Columbia corporation in February of 1999. Despite the fact that the organization has been operating in San Francisco since at least 1993, the EWG did not register with the State of California as a foreign corporation until March of 2001.
Overview of EWG IRS Returns
EWG describes itself as “a not-for-profit environmental research organization dedicated to improving public health and protecting the environment by reducing pollution in air, water and food.” There are currently two IRS Form 990 returns publicly available for the EWG: one for the two month short period ending December 31, 1999 (a copy of which is appended hereto as Attachment One) and one for the 2000 tax year (a copy of which is appended hereto as Attachment Two).
The 1999 return states that the total revenue for that two month short period equaled $806,941 (line 12). Almost ninety-eight percent of that money is accounted for by $788,667 in “direct public support” (line 1a). EWG’s return also states that the organization spent about twenty-eight percent of all the money raised ($222,590 / line 17) with absolutely none of the funds being used for the purpose of attempting to influence legislation and public opinion.
EWG’s 2000 return states that the total revenue for the calendar year equaled $1,476,213 (line 12). Almost 96.7% of that money is accounted for by $1,427,028 in “direct public support” (line 1a). EWG’s return also states that it spent about 103.5% of all the money raised ($1,476,521 / line 17) with none of the funds being used for the purpose of attempting to influence legislation and public opinion.
Other documents described below show these reports to be false or misleading.
EWG Pattern of Lobbying and Political Activities
For the general public to accept the EWG’s assertion that no funds were expended on lobbying activities during the short period in 1999 and the entire 2000 calendar year would be for the public to completely disregard EWG’s very open lobbying efforts before, during and after 1999 and 2000. When combined with evidence of an overt pattern of intervention in political campaigns, the EWG’s publicly documented lobbying activities in excess of the Part VI-A Section (h) allowance appear clearly in violation of 501(c)(3) standards.
Lobbying Activities Chronicled in the News through 1999.
EWG has served a lobbying function throughout most, if not all, of its existence. The Tides Center’s annual federal returns for the 1997 and 1998 tax years listed payments to “Environmental Group” (which we believe to have been the EWG) as “lobbying grants.” As recently as June of 1998, EWG and the Tides Center were listed by the State of California as being one of the state’s top 100 largest lobbyist employers.
The EWG has repeatedly and continuously exploited the internet in order to advance its causes. In fact, their websites serve as their primary method for distributing materials and information regarding their legislative advocacy, member targeting, and vote reporting. For instance, the Environmental Working Group’s ‘Chicken Little’ site (www.chickenlittle.org) corresponds to the organization’s report released in November of 1997 railing against the U.S. automakers for lobbying against environmental regulations, and more specifically against a global warming treaty. On this website, “surfers can read the eye-popping comments of polluters who fought against the most basic environmental regulations.” The report recommends that Congress and the Clinton Administration rewrite the nation’s transportation law, speed the introduction of alternative fuel sources, and make cars more efficient by raising fuel economy standards.
The EWG has actively lobbied the California legislature with the well-timed release of several reports. In April of 1998, for example, a bill (AB 2617) was introduced in conjunction with an EWG report entitled “Methyl Bromide Use Near California Schools 1995.” The proposed bill would have created a 1,000-foot buffer zone for agricultural methyl bromide applications near schools, day care facilities and home and require notification of people living and working within a mile of the field.
The EWG lobbying activities clearly carried over into the 1999 tax year with the many reports and news releases issued by EWG. For example, in January of 1999 the EWG and Californians for Pesticide Reform released a report entitled “What You Don’t Know Could Hurt You: Pesticides in California’s Air” which stated that toxic pesticides were found in a significant majority of air samples. The report summarized two years of tests--tests which they received assistance in conducting after calling on local communities to participate. In the report’s executive summary, the EWG stated: “DPR’s [the California Department of Pesticide Regulation] head-in-the-sand attitude, symptomatic of the agency’s longstanding accommodation of agricultural interests at the expense of public health, has allowed pesticide air pollution to effectively escape monitoring and needed controls. . .” The report goes on to offer a list of action items for the State of California, including the transfer of authority for the regulation of pesticides in air from DRP to the California Air Resources Board and increased reporting requirements. At the time the report was released, two bills regarding the regulation and possible ban of methyl bromide were expected to be presented to the state legislature.
In May of 1999, the EWG report entitled “Reading, Writing and Risk: Air Pollution Inside California’s Portable Classrooms,” coincided with the announcement of a bill by California Assemblyman Kevin Shelley that would have required the state to set standards for air quality in portable classrooms.
In July of 1999, Senators introduced a bill requiring the EPA to slow its review of thousands of farm pesticides for their impact on children’s health. In a clear attempt to mold public opinion regarding the proposed legislation, the EWG’s president responded by stating, “This is nothing other than a pesticide industry lobbyists’ bill from pesticide companies who are more interested in profits than protecting children’s health.” The EWG had hammered at the pesticide industry’s influence earlier in the month with the release of the EWG’s report entitled “Bureaucrats to FatCats.” This report accused the pesticide program for the Environmental Protection Agency of serving as a “farm team” for the pesticide lobby.
Illegal Political Activities Chronicled in the News through 1999.
The EWG also made attempts to influence the 2000 presidential election. For example, in September of 1999, the EWG responded to the introduction of George W. Bush’s environmental advisors by releasing “George W. Bush’s Anti-Environmental Advisors: Beyond the Official Bios.” The report stated:
“What most voters do not know is that the assembled group of policy advisors typically work for corporate front groups working for goals far outside the mainstream environmental perspective. . .These corporate front groups support everything from ‘takings’ legislation that would pay companies not to break environmental and public health laws and dismantling the Endangered Species Act, to denying the existence of global warming and the seriousness of air pollution. . .A few individuals even have ties to the so-called ‘wise use’ movement, an extreme movement whose 25 states goals include ‘immediate wise development of the petroleum resources of the Arctic National Wildlife Refuge” and ‘creation of National Mining System’ under which ‘all public lands including wilderness and national parks shall be open to mineral and energy production under wise use technologies.’”
This clearly partisan report made no attempt whatsoever to analyze the backgrounds of the other presidential candidates’ environmental advisors.
EWG Legislative Lobbying During 2000.
The pesticide debate also spilled over into the 2000 tax year. The EWG asked Rep. Richard Pombo (R-Calif.) to reveal all the details surrounding the drafting of HR 1592, the Regulatory Fairness and Openness Act of 1999, a bill that it argued would “severely undercut” the 1996 Food Quality Protection Act. The act proposed new procedures for the EPA to use when assessing risks and evaluating data in reassessing existing pesticide tolerances.
With regard to a bill that would make it more difficult for the EPA to ban or restrict the use of pesticides on which the House Agriculture Committee indefinitely delayed action, EWG spokesperson Richard Wiles stated that it is “an election-year nightmare for moderate Republicans and Democrats alike. . .an ethically challenged bill [emphasis added] that poses real threats to children’s health, which is a political third rail for any member of Congress.”
In April of 2000, the EWG released a study which stated that 10 percent of farmers received 61 percent of the $22.9 billion in government payments. The EWG used this study to make a case for distributing farm subsidies based on financial need, rather than on the amount of production. Arguing that the 1996 law was heavily biased in favor of large, corporate farms and agribusiness partnerships, the study recommended that Congress force farmers to document financial need and to limit payments.
In September of 2000, as state environmental regulators lobbied for greater control over regulation, EWG analyst John Coequyt said, “Our fear is that states are taking a much more active and political role in running programs. . .With that comes a higher degree of political accountability. The result can be that states become much less interested in fining corporations.”
EWG’s Illegal Political Activities Chronicled During 2000.
Throughout the 2000 tax year the EWG continued to pursue its political agenda through any means available.
In the spring of 2000, the EWG was among a handful of environmental groups which spent $60,000 on ads, including print ads in The New York Times and in USA Today’s European edition, criticizing Vice President Al Gore over negotiations on a global treaty to ban harmful chemicals linked to cancer, birth defects and other genetic abnormalities. The goal of these ads was to get the administration’s attention and spark action by the vice president. EWG president Ken Cook stated, “Everyone’s expecting some action from the vice president.”
Also in the spring of 2000, the EWG planned a boycott of Sam Wyly’s company Greenmountain.com in response to Wyly’s public criticism of Vice President Gore and his advertising blitz that benefited Gov. Bush just before the March primaries. Wyly and his brother formed an organization and paid about $2.5 million to create and air the spots. The EWG called off the boycott after Wyly announced that he would stay off the air in the general election contest.
The EWG also weighed in on state elections during the 2000 campaign season. Commenting on Rep. David McIntosh (R-IN), who at the time was running as a gubernatorial candidate in Indiana, EWG spokesperson Mike Casey characterized him as “a one-man environmental wrecking ball” and stated that “[h]e is widely viewed here as the polluting industry lobbyist’s best friend, the man to go to if you are a polluting industry lobbyist who wants a favor done. . .[and] has worked hard to establish that role for himself. The man is consistent.”
In April of 2000, Michigan’s top environmental official announced plans to organize a summit between several state environmental officials and top industry executives to discuss environmental issues under a possible Bush presidency. The EWG president criticized the planned meeting calling it “a secret meeting to plot dirtier air” that displayed an “openly partisan approach to environmental policy.” A spokesperson for the EWG stated that Russ Harding’s summit “is a dirty and suspicious little web of backroom dealing” and that it was clearly a move to drum up support for Gov. Bush’s presidential bid.
Finally, an analysis of the inaccuracy of the EWG’s tax return for the 2000 calendar year can almost be summarized by a single report dated October 17, 2000. On that date, the EWG released a report entitled “Lone Smog State: Data from Texas, Other States Show Bush with Worst Anti-Smog Record.” The report stated that of 556 polluters in areas of Texas that do not meet basic clear air standards, 93 were violating laws established by the federal Clean Air Act.
While the EWG spokesperson denied that politics was the main reason for the release, he admitted to the St. Louis Post-Dispatch that politics was a motive. The spokesperson stated, “People need to know what a Bush EPA would look like. Texas is the smoggiest state in the country and Houston is the smoggiest city because, under Bush, Texas doesn’t enforce clean air laws against big industrial polluters.”
The report itself stated the EWG’s political agenda when it stated:
“If applied at the national scale, the Texas approach would cripple ongoing efforts to control one of the nation’s most serious pollution problems. If campaign contributions are any indication, industry interests clearly support Texas-style regulation. Our review of political contributions shows that the chemical plants, refineries and factories violating VOC standards in Texas have given heavily to Gov. Bush’s campaigns for governor and the White House.”
The report continued with a discussion of the Texas environmental laws under Governor Bush and more details on the sources of campaign contributions.
What purpose does a discussion of campaign contributions to Governor Bush serve in a supposedly non-partisan analysis of statistical data regarding smog? Even if the EWG were to assert that the report was released to educate voters under Treas. Reg. 1.501(c)(3)-1(d)(3), there was no “full and fair exposition of the pertinent facts” to permit the members of the public to form their own independent opinions. There was no discussion of Al Gore’s or Ralph Nader’s environmental records or analysis of their campaign contributions. The only non-partisan aspect of this report was the chart on the first page listing the top 17 “law breaking smog polluters in smog non-attainment zones.”
Despite the spokesperson’s disclaimer that the EWG did not endorse presidential candidates, clearly this report, released less than a month before the 2000 presidential election and on the eve of the final presidential debate, was intended to influence voters’ decisions in the election. In Christian Echoes Nat. Ministry, Inc., 470 F.2d 849 (10th Cir. 1972), the court held that an organization intervened in political campaigns even though it did not formally endorse specific candidates. The organization in that instance used its publications and broadcasts to attack candidates and incumbents who it considered too liberal.
The EWG was even among the group of environmentalists, organized labor and other special interest groups that urged Ralph Nader to withdraw from the 2000 presidential elections because he was hurting Vice President Gore’s chances. In a letter to Nader, the EWG president argued that a Bush administration would bring “excruciating consequences” for the public interest community. His appeal to Nader went on to state, “Virtually everything the environmental community has achieved over the past thirty years could be at stake.”
After the 2000 presidential election, the EWG representatives were more than ready to publicly state their disappointment with the outcome and assign blame. Regarding Ralph Nader, EWG president Ken Cook declared, “The public-interest community is going to spend tens of millions of dollars a year for the next four years playing defense. . .I don’t think [Nader’s] going to build a Green Party any more than O.J.’s out there looking for a murderer.” In a separate statement, Mike Casey, spokesman for the EWG, stated “I think he’s [Nader’] building an ego, not a movement. . .we will absolutely blame Ralph Nader directly --and his politically stupid choice of continuing his campaign.” Casey also stated, “Because he put his ego before his commitment, he wakes up today with 3 percent, no federal money, he stands virtually alone in the environmental community and he’s put Bush and his goon squad [emphasis added] in the White House.” In another statement, Casey remarked, “Let the voters who said there’s no difference between Bush and Gore wait until Big Oil’s candidate gets in the White House. . .Bush is going to take those Greens to school and we’re all going to pay the tuition.”
EWG’s 2001 Political and Lobbying Actions.
The EWG continued its aggressive lobbying tactics in the 2001 tax year and for the first time in regulatory filings admitted that its activities were lobbying activities. In August of 2001, EWG finally acknowledged the nature of its activities when it submitted a Lobbying Registration and Lobbying Report Form to the Clerk of the House of Representatives. The transmittal letter states that the organization did not register sooner because “it did not expect to meet the Lobbying Disclosure Act’s $22,500 lobbying expenditure threshold.” (See Attachment Three). The document also discloses that EWG has or will make an election for the first time under I.R.C. Section 501(h) regarding the treatment of its lobbying expenditures. It is ironic that the EWG did not anticipate meeting the legislative threshold despite the fact that during 2000 The Joyce Foundation awarded the EWG a $1,620,000 grant (over 3 years) to “support a concentrated program of agriculture policy reform” according to its website. However, the Joyce Foundation’s Form 990 listed the purpose of this grant more specifically as: “For work on 2002 Farm Bill.”
Of the various links featured on EWG’s website, one of special importance is titled “Farm Subsidy Database.” Selecting this link connects the viewer to a map of the U.S. entitled, “Who Wins and Who Loses in Federal Farm Policy.” If the viewer clicks on a state, the page will display information on how, under current laws, the U.S. government has misspent federal funds on agricultural subsidies. This website also features commentary as to why “current federal programs probably didn’t serve you or your local economy well.” The EWG explains its reasons for posting this information as follows:
Farm assistance is vital for agriculture and rural America. We need robust programs to support farmers’ incomes while helping them protect natural resources and the environment. EWG staff have worked for many years on policies that have brought billions of dollars in support to the farm sector through the Conservation Reserve Program, Wetlands Reserve and other important conservation programs.
We think even more support is warranted.
But we also think current policy has badly failed almost everyone in agriculture but the very largest producers of a few favored crops. Most farmers and ranchers -- indeed, entire regions of the country -- receive little or no assistance. Tens of thousands of farmers who have applied for USDA conservation programs, for instance, have been turned away because those programs are chronically under-funded. In almost every state, there are multi-million dollar backlogs of applications of farmers and ranchers waiting to get into the program.
Before Congress enacts another Farm Bill that will set agriculture policy for the next 5-10 years, at a cost of $170 billion, the entire country should have better information about how taxpayers have already invested $90 billion since ‘Freedom to Farm’ became law. . .” [emphasis added].
The EWG also continues to use its website to influence legislation by attacking specific members of Congress. “Dirty Money,” a feature of EWG’s website, provides the public information on how “money from anti-environmental corporations and coalitions affects environmental decision makers.” To substantiate its claim that “polluters have far more access to political decision makers--and far more influence over environmental decisions--than ordinary citizens do. . .” the EWG provides a spreadsheet presentation featuring “dirty money” given to a representative. The EWG’s insinuations about these representatives are unmistakable: if an elected official is included on their list of “dirty money” recipients, then his or her voting integrity has been compromised and they will vote in favor of their polluting donors to the public’s detriment. The intent is clearly to influence the official’s vote on specific legislation.
During 2001, the EWG has shown a particular affinity for personally attacking House Agriculture Committee Chairman Larry Combest in an effort to get his cooperation. In a May 14, 2001, letter to Chairman Combest, EWG explained their “Farm Subsidy Scorecard” series in which the EWG tracked subsidy payments from 1985 through 2000. In what can only be described as an attempt to influence legislation by embarrassing Chairman Combest, the EWG stated:
“Given your critical role in writing the next farm bill, the first scorecard will be about your district, which EWG will publish and post on our web site this week at www.ewg.org. EWG’s analysis raises important questions about the extent to which farm payments are adequately aiding the family farmers in your district. One issue is the severe concentration of payments among relatively few, large farm operations.”
In an October 3, 2001, press release entitled “Combest Stoops to New Low” the EWG attacked Chairman Combest for allegedly threatening the funding for food stamps and other nutrition programs if House members voted to cut farm subsidies to provide conservation payments to family farms. The press release quotes stating, “Chairman Combest is clearly saying that paying off the big agribusiness in his district is more important then nutrition for poor kids. . .Farm Bill politics used to just be tough, but now Mr. Combest has made them ugly.”
During 2001, the EWG continued pursuit of members of Congress by assembling “subsidy records into a searchable database as part of its campaign to shift the emphasis in farm programs from crop payments to conservation.” What better way to encourage voters not to vote for a particular politician or to embarrass the politician into changing a stance than by assembling such a database.
With regard to agricultural debates in the Congress, Ken Cook explained that the farm bill is a top priority for national environmental groups and that “[t]he goal is to get as many people aware of the opportunity to do something in this farm bill, who don’t normally think of the farm bill as anything but a remote Byzantine unimportant process.” He also stated, “The goal is to get enough people to get the attention of the House Agriculture Committee that there might be a move if there isn’t a solid conservation plank in the bill that’s reported out of committee.”
The EWG flagrantly intervened in several state and national level political campaigns despite clear federal statutes and regulations specifically prohibiting such activities. Moreover, the EWG, an organization that has admitted the lobbying nature of its activities both before and after the relevant tax periods, claims not to have expended any funds for lobbying during 1999 and 2000 even though the organization continued to operate and continued to produce reports, letters and statements on pending legislative issues and against specific politicians, most of which are posted on the EWG’s own website. Had they claimed to have spent any money at all on legislative lobbying activities, their actions would not be so reprehensible. Instead, they chose to claim no lobbying expenditures at all.
The actions of the Environmental Working Group documented here clearly violate the laws governing tax-exempt organizations and require revocation of the organization’s tax-exempt status.
Thank you for your prompt attention to this matter.
Executive Vice President
Center for the Defense of Free Enterprise
 See, The Foundation Center, Foundation Grants database, 1989 grant records to EWG from: The William and Flora Hewlett Foundation ($150,000); The Educational Foundation of America ($40,000); The Ford Foundation ($200,000, 2-year grant); The Andrew W. Mellon Foundation ($250,000); The Charles Engelhard Foundation ($15,000); The Florence and John Schumann Foundation (Bill Moyers, President) ($225,000, 3-year grant).
 The 1989 grant records for The Andrew W. Mellon Foundation and The Charles Engelhard Foundation show the recipient as “Tides Foundation. Environmental Working Group, DC.”
 The Tides Foundation, a public charity, allows people and institutions that, for one reason or another, do not want to be publicly identified with a certain cause to give money to Tides as donor-advised funds. The legally separate Tides Center manages most Tides Foundation “projects.”
 1994 Form 990, attached schedule for Part III(A) and Schedule A, Part I.
 IRS letter to Tides Foundation dated 16 June 1982.
 See, EWG website at http://www.ewg.org/about.html.
 1999 Form 990, Schedule A, Part VI-A.
 2000 Form 990, Schedule A, Part VI-A.
Form 990, Schedule A, Part VII for 1997 and 1998.
The IRS is currently reviewing the issue of internet use by tax-exempt organizations in connection with political and lobbying activities to determine whether specific guidelines should be issued. See, IRS Announcement 2000-84: Request for Comments Regarding the Need for Guidance Clarifying Application of the Internal Revenue Code to Use of the Internet by Exempt Organizations.
See, “Blind Spot” at http://www.ewg.org/pub/home/reports/blindspot/blindhome.html.
“Evolving Activism,” E Magazine, Jan. 1, 2000, p. 8.
 “California bill would require 1,000-foot buffer zone for methyl bromide,” Pesticide & Toxic Chemical News, May 7, 1998, No. 28, Vol. 26.
 Supra, p.5.
 Sharon Bernstein, “Use of Powerful Insecticide Fills Air with Controvers,” March 23, 1997, Los Angeles Times, Part A, Page 1.
 Glen Martin, “Study Finds Toxic Air In Portable Classrooms,” The San Francisco Chronicle, May 27, 1999, Pg. A19.
 Bruce Alpert, “New Criteria Sought On Pesticide Safety; EPA Restrictions Prompt Legislation,” The Times-Picayune, July 31, 1999, National Section.
 “A Few Hints of Green,” The National Journal, August 7, 1999.
 See EWG report, “George W. Bush’s Anti-Environmental Advisors: Beyond the Official Bios” released in September 1999 (citing The Wise Use Agenda, edited by Alan Gottlieb, 1989.)
 “Environmental Group Questions Authorship of House Bill,” Food Chemical News, no. 14, vol. 42, p. 17, May 2000.
 Philip Brasher, “Weekly Farm: $15 billion not enough for farmers,” The Associated Press, State & Local Wire, Sept. 8, 2000.
 See EWG report “Green Acres: How Taxpayers are Subsidizing the Demise of the Family Farm” released in April 2000. Found at http://www.ewg.org/archives/reports-by-year.php?year=2000.
 Rob Hotakainen, “Áid Helped Big Farms the Most. . .” Star Tribune, New Section, p. 1A, Apr. 26, 2000.
 Kara Sissell, “States Lobby for More Environmental Autonomy,” Chemical Week, Sept. 27, 2000, p. 53.
 Laura Meckler, “Environmental Groups Airing Anti-Gore Ad,” The Associated Press, Political News, Mar. 21, 2000.
Jeff Leeds, “Bush Backer Says He’s Through With Ads,” Los Angeles Times, National Desk, Apr. 5, 2000.
“McIntosh Denies Newspaper Reports Calling Him No Friend of Environment,” The Associated Press, Political News Section, State & Local Wire Apr. 18, 2000.
John Mintz, “Bush Backers To Talk About Clean Air Rules; State Officials, Companies See Hope For Relaxation,” The Washington Post, Campaign 2000, Apr. 20, 2000.
Bill Lambrecht, “Texas Leads Nation in Polluting Plants, Report Says; Illinois Is Second; Bush Campaign Questions Group’s Findings,” St. Louis Post-Dispatch, News Section, Oct. 17, 2000.
 See, EWG report “Fuzzy Air: Why Texas is the Smoggiest State,” released Oct. 17, 2000, p.2.
 Eun-Kyung Kim, “Former Nader Allies Urge Him To Yield Field To Gore,” The Associated Press State & Local Wire, Political News, Nov. 2, 2000.
 “Nader: Is There Life After Crucifixion?” The Nation, Dec. 4, 2000, p. 17.
 “Labor and Democrats Vilify Nader, The Bulletin’s Frontrunner, Nov. 9, 2000.
 Eun-Kyung Kim, “Nader, Buchanan See Growing Role For Third-Party Politics,” The Associated Press, Political News, Nov. 8, 2000.
 Richard Willing, “Democrats Blast Nader’s Campaign; Green Party Candidate Shrugs Off Criticism,” USA Today, Nov. 9, 2000.
 See, The Joyce Foundation 2000 Form 990, Grant Activity Report, p. 24, grant to EWG.
 Letter of Kenneth A. Cook and Anne C. Keys, Environmental Working Group, to House Agricultural Committee Chairman, Larry Combest, May 14, 2001, found in the news archive on EWG website http://www.ewg.org.
 See, EWG website, press release of October 3, 2001.
 “Farm Aid Benefits Lawmakers. . .,” The Washington Post, Sept. 1, 2001, A01.
 “Outside Enviro Groups Lobby for Conservation,” The Hill, Sept. 12, 2001, p. 27.