Discussion about this post

User's avatar
The lazy activist's avatar

So Rira,the supplicant without much clout or effective history, went to Risa to borrow some

creds in the grant dept. Risa obliged but, might have questionable parentage, shadowing the transaction. Who cares? Nobody. Why shouldn't good money just go to those who ask or simply take? Money is up for grabs and whoever has the longest arm, gets it. Just shut up and deal with it.

Expand full comment
Frank Farance's avatar

I read your article, and I'd like to add some history and some clarity.

- The Public Purpose monies don't necessarily go towards 501(c)(3) corporations, they go to efforts that serve the Public Purpose. This has been the case since the 1980s and through the 1990s and up to the present.

- In the 2000s RIOC clarified this (see amended Board Resolution of December 11, 2014), that both 501(c)(3) and 501(c)(4) organizations were permitted with the provision "[...] certified as tax exempt under Internal Revenue Code (IRC) section 501(c)(3) or 501(c)(4). Please note that organizations recognized under IRC section 501(c)(4) as tax-exempt social welfare organizations, may apply for PPF only if the requested funds are: (i) not intended or used for lobbying or other political activities; and (ii) are intended and used for an activity that directly relates to a power, duty or purpose of RIOC.". The RIRA PPF Grant for developing a CERT team complies with this provision. See "https://rioc.ny.gov/DocumentCenter/View/471".

- The RIRA PPF grant to develop a Community Emergency Response Team (CERT) is NOT related to NYC Emergency Management's (NYCEM) City-wide CERT program. NYCEM is the sponsor of that program, and completely independent of our work. Precisely, FEMA authorizes several kinds of CERT programs: one sponsored by local law enforcement or emergency services (like NYCEM), one for teenagers (Teen CERT) as a "feeder" program into adult CERTs, one for college campus (Campus CERT), and one for workplaces (Workplace CERT). Our CERT program is a Workplace CERT where RIRA (whose footprint and membership) includes the Island and its residents. We RIRA do not intend to deploy outside of Roosevelt Island and vicinity, and this addresses one of the reasons why the NYCEM-sponsored CERT team had withered: Roosevelt Islanders only wanted to deploy and support their own community here, not the rest of Manhattan or New York City. We had 40 people sign up for the Roosevelt Island CERT on Roosevelt Island Day.

- The original RISA had numerous problems with its executive director taking money, and many of their board went to RIDA. The RISA organization (now branded as RIRA/Good Life) has reinvented itself with new leadership and a board. I have worked with Andrea Jackson for many years, her approach to the organization is very professional and ethical, we are finalizing the formalities to make sure we've satisfied all legal and ethical obligations, and I look forward to a productive collaboration - a very different RISA than the one that existed a decade ago. Likewise, as RIRA President, I take my own responsibilities seriously, and I believe this collaboration with RISA/Good Life will be good for RIRA and our community.

- Regarding the RISA/Good Life fiscal sponsorship for RIRA, I don't believe that money should be counted towards allocating to RISA/Good Life as this money is NOT being spent on RISA/Good Life's priorities/direction, it is spent on RIRA's priorities/direction. RISA/Good Life is merely serving an administrative function to make sure the money is being spent correctly, i.e., on RIRA priorities/direction per the RIRA PPG grant application, which is why RIRA signed documents with NYCT on the grant, and RISA/Good Life is not controlling or directing this $10,000 grant, RIRA is controlling and directing this grant per our grant proposal.

- Regarding Howard Polivy, he was involved as Team Chief in the NYCEM-sponsored "MN8 RI" (Manhattan CB8 Roosevelt Island) team 2006-2019. In 2019, there was a NYCEM City-wide reorganization and Manhattan's 15-20 CERTs were reorganized into 5 divisions, Roosevelt Island was part of Manhattan Division 3, and Howard had a marginal role - and there were only 2 CERTs from Roosevelt Island who participated regularly in a Division 3's approx 50 CERTs, i.e., the Roosevelt Island team has severely withered (as explained above). Regardless, since 2004, Howard, Matt Katz (former RIRA President), and I were the three-some for years who advised on Roosevelt Island's infrastructure, services, and emergency preparedness. Howard is very very knowledgeable, I'm glad he's on the RIOC board, and Howard and I collaborate well - which is of good benefit for Roosevelt Island as I plan on working with Howard in our efforts on the Roosevelt Island CERT team. To my knowledge, Howard's wife Ellen is not involved at all - she has not been part of or referenced in ANY aspect of the RISA/Good Life and RIRA collaboration.

Regarding Public Purpose Funds and Grants, I'd like to add some precision. There were Public Purpose Payments from Manhattan Park's construction in the 1980s. In essence, rather than state taxes collected on the local construction (e.g., sales taxes), those payments would be made directly to the benefit of Roosevelt Island. At the time, it was believed that there would be more efficiency in redirecting the taxes directly - rather than collecting the state tax revenues in one big pot, and then depending upon legislators to distribute directly to Roosevelt Island (this seemed unlikely). Thus, these Public Purpose Payments (see section 3.07 in the Manhattan Park ground lease) would come directly. By the early 1990s (after Manhattan Park had been completed), there was approximately $2 million in available Public Purpose Payments. The document cited above (RIOC Board resolution) provides some history. I've been familiar with the Public Purpose fund distribution since 1996.

In the early 2000s, it appeared that the money was running out from its initial source, RIOC assigned PPF grant evaluation to RIRA in 2008, (I believe) RIOC President Steve Shane sought $100,000 annual funding to assure continuity (annual funding increased since), and Senator Serrano proposed legislation in 2015-2016 (Senate Bill S5813B), which was approved, that provided up to 3% of RIOC's annual operating budget for public purpose distribution:

"Not-For-Profit Grant Distribution. 1. The corporation is authorized to provide financial assistance in the form of grants to not-for-profit corporations or governmental agencies that provide direct services or benefits to the residents of Roosevelt Island, not to exceed 3% of the operating budget of the corporation, and upon the approval of a majority of the entire board of the corporation."

Since then there has been much griping that RIOC is not spending all of the 3% on community benefits and services. Here is some more precision on terminology:

- Public Purpose Payment: the original funding from Manhattan Park's construction, there are no more payments

- Public Purpose: as constructed from the legislation "provid[ing] direct services or benefits to the residents of Roosevelt Island"

- Public Purpose Fund: a separate accounting mechanism withing RIOC to track monies belonging to Public Purpose

- Public Purpose Grant: monies from the Public Purpose Fund that are awarded based upon Public Purpose Grant applications (previously reviewed by RIRA, now administered separately by NYCT)

Although RIOC can spend up to 3% on Public Purpose Funds, it seeks to "color" (an accounting term of art) as much spending as "Public Purpose", e.g., the Roosevelt Island Day, Fall Festival for the Arts, Holiday Tree lighting, the RIOC's Youth Program, RIOC's Youth Program summer camp, and some Public Safety activities as "Public Purpose". Thus, although there are 3% funds available, in fact, some portion is spent upon RIOC itself (a governmental agency) so that is shows that RIOC is complying with the law, but it's not all coming to community not-for-profits. Both 501(c)(3) and 501(c)(4) organizations are considered not-for-profit (see NYS Attorney General's Charities Bureau), and a separate RIOC Board Resolution (cited above) PROHIBITS lobbying and political activities:

"[...] (i) not intended or used for lobbying or other political activities; and (ii) are intended and used for an activity that directly relates to a power, duty or purpose of RIOC. [...]"

Thus, while your statement about 501(c)(4) might be true:

"RIRA is not a 501(c)(3). It’s a 501(c)(4)—a classification that allows for advocacy, political organizing, and lobbying."

A careful reading (via construction) shows that PPF grants do NOT allow for "advocacy, political organizing, and lobbying".

Several other Community Leaders have presented the same concerns: the 3% is not being spent, and it's not being spent on community not-for-profits but government agencies (e.g., RIOC). This is still a concern, and I hope you can shine a light upon this.

Expand full comment
5 more comments...

No posts