Department of the Treasury Internal Revenue Service
Public Charity Status and Public Support
Complete if the organization is a section 501(c)(3) organization or a section
4947(a)(1) nonexempt charitable trust.
Attach to Form 990 or Form 990-EZ. See separate instructions. Information about Schedule A (Form 990 or 990-EZ) and its instructions is at www.irs.gov/form990.
OMB No. 1545-0047
2013
Open to Public Inspection
Name of the organization
Great Rivers Environmental Law Center
Employer identification number
43-1943334
Part I
Reason for Public Charity Status
(All organizations must complete this part.) See instructions.
The organization is not a private foundation because it is: (For lines 1 through 11, check only one box.)
1
2
3
4
5
section 170(b)(1)(A)(iv). (Complete Part II.)
6
7
8
9
receipts from activities related to its exempt functions—subject to certain exceptions, and (2) no more than 331/3% of
its support from gross investment income and unrelated business taxable income (less section 511 tax) from businesses
acquired by the organization after June 30, 1975. See section 509(a)(2). (Complete Part III.)
10
11
e
By checking this box, I certify that the organization is not controlled directly or indirectly by one or more disqualified persons other than foundation managers and other than one or more publicly supported organizations described in section 509(a)(1) or section 509(a)(2).
f
If the organization received a written determination from the IRS that it is a Type I, Type II, or Type III supporting organization, check this box
..................................................
g
Since August 17, 2006, has the organization accepted any gift or contribution from any of the following persons?
(i) A person who directly or indirectly controls, either alone or together with persons described in (ii)
Yes
No
and (iii) below, the governing body of the supported organization?
................
11g(i)
(ii)
A family member of a person described in (i) above?
......................
11g(ii)
(iii)
A 35% controlled entity of a person described in (i) or (ii) above?
................
11g(iii)
h
Provide the following information about the supported organization(s).
(i) Name of supported organization
(ii) EIN
(iii) Type of organization (described on lines 1- 9 above or IRC section (see instructions))
(iv) Is the organization in col. (i) listed in your governing document?
(v) Did you notify the organization in col. (i) of your support?
(vi) Is the organization in col. (i) organized in the U.S.?
(vii) Amount of monetary support
Yes
No
Yes
No
Yes
No
Total
For Paperwork Reduction Act Notice, see the Instructions for Form 990 or 990EZ.
Cat. No. 11285F
Schedule A (Form 990 or 990-EZ) 2013
Schedule A (Form 990 or 990-EZ) 2013
Page 2
Part II
Support Schedule for Organizations Described in Sections 170(b)(1)(A)(iv) and 170(b)(1)(A)(vi) (Complete only if you checked the box on line 5, 7, or 8 of Part I or if the
organization failed to qualify under Part III. If the organization fails to
qualify under the tests listed below, please complete Part III.)
Section A. Public Support
Calendar year (or fiscal year beginning in)
(a) 2009
(b) 2010
(c) 2011
(d) 2012
(e) 2013
(f) Total
1
Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") ....
212,180
194,814
226,936
257,142
302,439
1,193,511
2
Tax revenues levied for the organization's benefit and either paid to or expended on its behalf.......
3
The value of services or facilities furnished by a governmental unit to the organization without charge..
4
Total. Add lines 1 through 3
212,180
194,814
226,936
257,142
302,439
1,193,511
5
The portion of total contributions by each person (other than a governmental unit or publicly supported organization) included
on line 1 that exceeds 2% of the amount shown on line 11, column (f)..
585,151
6
Public support. Subtract line 5 from line 4.
608,360
Section B. Total Support
Calendar year
(or fiscal year beginning in)
(a) 2009
(b) 2010
(c) 2011
(d) 2012
(e) 2013
(f) Total
7
Amounts from line 4..
212,180
194,814
226,936
257,142
302,439
1,193,511
8
Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources...
33
47
88
192
91
451
9
Net income from unrelated business activities, whether or not the business is regularly carried on..
10
Other income. Do not include gain or loss from the sale of capital assets (Explain in Part IV.)..
78
78
125
97
128
506
11
Total support (Add lines 7 through 10).
1,194,468
12
Gross receipts from related activities, etc. (see instructions)
..................
12
325,469
13
First five years.
If the Form 990 is for the organization's first, second, third, fourth, or fifth tax year as a 501(c)(3) organization,
check this box and stop here.................................................
Section C. Computation of Public Support Percentage
14
Public support percentage for 2013 (line 6, column (f) divided by line 11, column (f))
.........
14
50.930 %
15
Public support percentage for 2012 Schedule A, Part II, line 14
...............
15
52.750 %
16a
33 1/3% support test—2013.
If the organization did not check the box on line 13, and line 14 is 33 1/3% or more, check this box
and stop here. The organization qualifies as a publicly supported organization
.......................
b
33 1/3% support test—2012.
If the organization did not check a box on line 13 or 16a, and line 15 is 33 1/3% or more, check this
box and stop here. The organization qualifies as a publicly supported organization
.....................
17a
10%-facts-and-circumstances test—2013.
If the organization did not check a box on line 13, 16a, or 16b, and line 14
is 10% or more, and if the organization meets the "facts-and-circumstances" test, check this box and stop here. Explain
in Part IV how the organization meets the "facts-and-circumstances" test. The organization qualifies as a publicly supported
organization
.....................................................
b
10%-facts-and-circumstances test—2012.
If the organization did not check a box on line 13, 16a, 16b, or 17a, and line
15 is 10% or more, and if the organization meets the "facts-and-circumstances" test, check this box and stop here.
Explain in Part IV how the organization meets the "facts-and-circumstances" test. The organization qualifies as a publicly supported organization
................................................
18
Private foundation.
If the organization did not check a box on line 13, 16a, 16b, 17a, or 17b, check this box and see
instructions
.....................................................
Schedule A (Form 990 or 990-EZ) 2013
Schedule A (Form 990 or 990-EZ) 2013
Page 3
Part III
Support Schedule for Organizations Described in Section 509(a)(2) (Complete only if you checked the box on line 9 of Part I or if the organization
failed to qualify under Part II. If the organization fails to qualify under
the tests listed below, please complete Part II.)
Section A. Public Support
Calendar year (or fiscal year beginning in)
(a) 2009
(b) 2010
(c) 2011
(d) 2012
(e) 2013
(f) Total
1
Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") .
2
Gross receipts from admissions, merchandise sold or services performed, or facilities furnished in any activity that is related to the organization's tax-exempt purpose......
3
Gross receipts from activities that are not an unrelated trade or business under section 513..
4
Tax revenues levied for the organization's benefit and either paid to or expended on its behalf...
5
The value of services or facilities furnished by a governmental unit to the organization without charge..
6
Total. Add lines 1 through 5.
7a
Amounts included on lines 1, 2, and 3 received from disqualified persons...
b
Amounts included on lines 2 and 3 received from other than disqualified persons that exceed the greater of $5,000 or 1% of the amount on line 13 for the year.
c
Add lines 7a and 7b..
8
Public support (Subtract line 7c from line 6.)
0
Section B. Total Support
Calendar year (or fiscal year beginning in)
(a) 2009
(b) 2010
(c) 2011
(d) 2012
(e) 2013
(f) Total
9
Amounts from line 6...
10a
Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources..
b
Unrelated business taxable income (less section 511 taxes) from businesses acquired after June 30, 1975.
c
Add lines 10a and 10b.
11
Net income from unrelated business activities not included in line 10b, whether or not the business is regularly carried on.
12
Other income. Do not include gain or loss from the sale of capital assets (Explain in Part IV.)
..
13
Total support. (Add lines 9, 10c, 11, and 12.)..
14
First five years.
If the Form 990 is for the organization's first, second, third, fourth, or fifth tax year as a 501(c)(3) organization,
check this box and stop here.............................................
Section C. Computation of Public Support Percentage
15
Public support percentage for 2013 (line 8, column (f) divided by line 13, column (f))
.........
15
0 %
16
Public support percentage from 2012 Schedule A, Part III, line 15
...............
16
Section D. Computation of Investment Income Percentage
17
Investment income percentage for 2013 (line 10c, column (f) divided by line 13, column (f))
......
17
0 %
18
Investment income percentage from 2012 Schedule A, Part III, line 17
.............
18
19a
33 1/3% support tests—2013.
If the organization did not check the box on line 14, and line 15 is more than 33 1/3%, and line 17 is not more than 33 1/3%, check this box and stop here. The organization qualifies as a publicly supported organization
........
b
33 1/3% support tests—2012.
If the organization did not check a box on line 14 or line 19a, and line 16 is more than 33 1/3% and line 18 is not more than 33 1/3%, check this box and stop here. The organization qualifies as a publicly supported organization
.....
20
Private foundation.
If the organization did not check a box on line 14, 19a, or 19b, check this box and see instructions
.....
Schedule A (Form 990 or 990-EZ) 2013
Schedule A (Form 990 or 990-EZ) 2013
Page 4
Part IV
Supplemental Information.
Provide the explanations required by Part II, line 10; Part II, line 17a or 17b; and Part III, line 12. Also complete this part for any additional information. (See instructions).
Facts And Circumstances Test
Explanation
Schedule A (Form 990 or 990-EZ) 2013
Additional Data
Software ID:
13000178
Software Version:
-
TIN:
SCHEDULE O (Form 990 or 990-EZ)
Department of the Treasury Internal Revenue Service
Supplemental Information to Form 990 or 990-EZ
Complete to provide information for responses to specific questions on
Form 990 or to provide any additional information.
Attach to Form 990 or 990-EZ.
Information about Schedule O (Form 990 or 990-EZ) and its instructions is at
www.irs.gov/form990.
OMB No. 1545-0047
2013
Open to Public Inspection
Name of the organization
Great Rivers Environmental Law Center
Employer identification number
43-1943334
Return Reference
Explanation
Pt VI, Line 2
Kathleen Henry, the president of Great Rivers, has a
Pt VI, Line 2
family relationship with Louise Green, a member of the
Pt VI, Line 2
board of directors. The board makes decisions
Pt VI, Line 2
according to the Missouri statutes governing
Pt VI, Line 2
nonprofit corporations - a majority vote of a quorum
Pt VI, Line 2
of the board is necessary to take action. Consequently
Pt VI, Line 2
the relationship could not create any undue influence
Pt VI, Line 2
on decisions of the board of directors.
Pt VI, Line 11b
The 990 draft was emailed to all board members for
Pt VI, Line 11b
review. Each was requested to respond within the
Pt VI, Line 11b
comment period with either an approval or with
Pt VI, Line 11b
additions/corrections. Responses were then summarized
Pt VI, Line 11b
and any changes forwarded to the tax preparer for
Pt VI, Line 11b
inclusion in the final return.
Pt VI, Line 12c
Each board member and member of a committee with
Pt VI, Line 12c
governing board-delegated powers annually signs a
Pt VI, Line 12c
statement which affirms that the person: a. Has
Pt VI, Line 12c
received a copy of the conflict of interest policy;
Pt VI, Line 12c
b. Has read and understands the policy; c. Has agreed
Pt VI, Line 12c
to comply with the policy; and d. Understands the
Pt VI, Line 12c
organization is charitable and in order to maintain
Pt VI, Line 12c
its federal tax exemption it must engage primarily
Pt VI, Line 12c
in activities which accomplish one or more of its
Pt VI, Line 12c
tax-exempt purposes. In addition, every time the
Pt VI, Line 12c
board discusses whether to accept a new case, the
Pt VI, Line 12c
board members must disclose any interests that
Form 990, Part IX, Line 24f
OTHER
Pt VI, Line 12c
might give rise to a conflict.
Pt VI, Line 15a
In 2013 there were four attorneys and one office manager who
Pt VI, Line 15b
worked for Great Rivers. One attorney is President, one is
Pt VI, Line 15a
the General Counsel and Secretary/Treasurer, and two
Pt VI, Line 15b
are staff attorneys. The President and General Counsel
Pt VI, Line 15a
reviewed the salaries of attorneys and personnel
Pt VI, Line 15b
at small law firms in St. Louis and determined that
Pt VI, Line 15a
the salaries of Great Rivers' employees are less than
Pt VI, Line 15b
those with equivalent experience. Consequently, staff were
Pt VI, Line 15a
offered. with board approval, a 3% raise to begin in January 2013.
Pt VI, Line 19
Great Rivers makes its governing documents, conflict
Pt VI, Line 19
of interest policy, audited financial statements, and
Pt VI, Line 19
990's available to the public upon request. Our 990's
Pt VI, Line 19
and other information can be found on the Guidestar
Pt VI, Line 19
website.
Pt VIII, Line 8c
On occasion there is a small loss (fair market value
Pt VIII, Line 8c
of tickets less the direct costs) on line 8 due to
Pt VIII, Line 8c
several reasons. Expenses for postage and printing
Pt VIII, Line 8c
of invitations, program printing, awards, and other
Pt VIII, Line 8c
misc. expenses are not part of the FMV of the ticket
Pt VIII, Line 8c
so become expenses not offset by revenue on line 8.
Pt VIII, Line 8c
Another reason is that it's difficult to determine the
Pt VIII, Line 8c
FMV of a ticket. If you offset the small loss with
Pt VIII, Line 8c
the contributions on line 1c, you will see that the
Pt VIII, Line 8c
sponsorships, general contributions, and ticket
Pt VIII, Line 8c
prices in excess of FMV more than make up for the loss.
Pt.IX,Line 26
Joint costs - All the specific expenses for the
Pt.IX,Line 26
creation, printing, and mailing of the newsletters
Pt.IX,Line 26
and other direct mail solicitations and website costs
Pt.IX,Line 26
are considered 100% fundraising expenses in column D
Pt.IX,Line 26
when they don't meet the SOP 98-2 (ASC 958-720)
Pt.IX,Line 26
criteria of purpose, audience, and content.
Pt.IX,Line 26
Staff time expended on combined educational campaigns
Pt.IX,Line 26
and fundraising solicitations sometimes meets the
Pt.IX,Line 26
joint cost allocation criteria and sometimes it
Pt.IX,Line 26
doesn't. Tracking time by specific task (fundraising
Pt.IX,Line 26
solicitations, newsletter production, speaking
Pt.IX,Line 26
engagements, meetings with donors and community
Pt.IX,Line 26
members, writing grants, updating the website,
Pt.IX,Line 26
working with current and potential volunteers, etc.),
Pt.IX,Line 26
calculating the cost of each task, then determining
Pt.IX,Line 26
the allocation based on the joint cost criteria would
Pt.IX,Line 26
be onerous. All expenses that include some fundraising
Pt.IX,Line 26
are allocated to the other one or two categories based
Pt.IX,Line 26
on estimates that are reasonable for those costs.
Pt.VII,lines 1&2
Officers of the organization -
Pt.VII,lines 1&2
Kathleen Henry and Bruce Morrison, both officers of
Pt.VII,lines 1&2
the organization, are also employees. Missouri law
Pt.VII,lines 1&2
allows employees to be officers of the organization. They
Pt.VII,lines 1&2
are not separately paid for their officer duties nor are they
Pt.VII,lines 1&2
board members.
Pt.X,line 27
Board Designated Net Assets - Due to the uncertainty of
Pt.X,line 27
when grants will be awarded and contributions received,
Pt.X,line 27
it's now considered a best practice for not-for-
Pt.X,line 27
profit organizations to have funds set aside as an
Pt.X,line 27
Operating Reserve that can be used when revenue is
Pt.X,line 27
less than anticipated. The board of directors is
Pt.X,line 27
committed to ensuring the long-term financial health
Pt.X,line 27
of the organization and, as such, adopted a policy
Pt.X,line 27
in 2013 to set aside funds for an Operating Reserve that
Pt.X,line 27
is included in Unrestricted Net Assets on the 990,
Pt.X,line 27
Pt. X, line 27. However, the breakdown is shown on a
Pt.X,line 27
supplementary statement.
For Paperwork Reduction Act Notice, see the Instructions for Form 990 or 990-EZ.