Athachment to Fair Political Practices Commission Sworn Com laint Form Additional Persons Who Allegedly Violated the Political Reform Act: Name. California Local Ener --Advancing Renewables Address: City: San Die 0 State:CA Zip:92105 Telephoneh Fax: unknown Email: Last Name: Stump First Name: John Address: City: San State: CA Zip: 92105 Telephone. Fax: unknown Email: Describe, With as Much Particularity as Possible, the Facts Constituting the Alleged Violation(s) and How You Have Personal Knowledge that it Occurred. The FPP must ac immediatel -- bef comin lection -- in order to make certain that before the oublic votes on Measure in San Diego County the know who is fundin the osition to this ballot measure. On September 12, 2016 an organization named "California Local Energy -- Advancing Renewables" made a $110.000 contribution to "Save Our Forest and Ranchlands Opposed to Measure a primarily formed ballot measure committee opposing San Diego County Measure B. (See attached FPPC Form 460.) Aweek later, SOFAR used these funds to make a $45,000 contribution to "Citizens and Taxpayers Opposed to Lilac Hills Ranch Measure (No on Measure Committee"), another committee activer opposing Measure B. I already filed a complaint against SOFAR because it clearly solicited funds to give to the No on Measure Committee without disclosing its donors. SOFAR has since disclosed its donor -- CLEAR -- but the individuals or entities who are the true source of these funds are still unknown. CLEAR is a 501(c)(3) organization based in San Diego, CA and its Chairman is John Stump. (See attached SOS business search, Cal AG Charity summary page, IRS Form 990 cover page, and June 7, 2016 letter to the San Diego City Clerk.) As you know, multipurpose organizations (such as a 501(c)(3)s) will qualify as recipient committees by making contributions totaling $50,000 or more in a 12 month period. (California Government Code section After qualification, these "calendar year filers" are required to identify their donors within three business days. (FPPC Regulation The law presumably requires nonprofits which get involved in ballot measure campaigns to file reports disclosing their donors within three days so the public can have information about who is funding a ballot measure effort before they vote. As of the date of this letter, CLEAR has not filed a FPPC Form 460 or Form 496 disclosing its donors, even though it contributed well over $50,000 to SOFAR. (See attached SOS, SD County, and SD City campaign finance search printouts.) Using a 501(c)(3) organization to avoid revealing the true source of a political contribution is a blatant violation of the both the letter and spirit of the Political Reform Act. The FPPC is duty-bound to fiJlfill its mission of ensuring transparency in the campaign finance system by taking immediate action to ensure that CLEAR registers as a recipient committee and discloses its contributors to the public. At the very least, CLEAR qualified as a "Major Donor" and was required to file a "24-hour report" disclosing its contribution to the Committee. (Cal. Govt. Code sections 84203 CLEAR has not yet filed a 24-hour report for this contribution. (See attached SOS, SD County, and SD City campaign finance search printouts.) In light of these blatant violations, the FPPC must compel CLEAR to register as a political committee, compel them to file applicable campaign reports disclosing their donors, and levy an appropriate penalty for their violations of these important public disclosure laws. Because the public has the right to this information before they go to the polls, the FPPC must act immediately. By copy of this complaint, I am also asking the Registrar of Voters to levy a late filing fee for failing to timely file these reports, and also asking the District Attorney's office to take action against CLEAR and its officers. Name and Addresses of Potential Vlfitnesses, other than Yourself, if Known: Last Name: McFetridge First Name Duncan Address -- City: Des State: CA Zip: 91916 Fax: unknown Email: Last Name: Clark Sanders First Name: Jana Address: unknown City: Descanso Telephone: unknown Fax: unknown Email: unknown cc: State: CA Zip: 91916 San Diego District Attorney Bonnie Dumanis San Diego Registrar of Voters Michael Vu