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B-182398 1 (1977-08-10)

handle is hein.gao/gaobachii0001 and id is 1 raw text is: COMPTROLLER GENERAL OF THE UNI M'ATES UI B.182398 August !0, 1977 The -bnorable Jesse Helms United States Senate Dear Senator Helms; This is in response to your letter of July 21, 1977, re-questing that the General Accounting Office (GAO) undertake an audit of the NAationl-l Commission on the Observance of International Women's Year (pWY) o determine if it has complied with relevant Federal laws. You were p.rtcularly concerned with allegations that the Coanisslon has 977/.. violated the anti-lobbying provisions of Pub. L. No. 94-167, Japproved December 23, 1975, and Pub. L. No. 94-303 approved June 1, 1976, as 4 well as the Federal Advisory Conmittee Act of 192-- U.S.C. Appl (1975, Supp. v)). The GAO has already conducted an extensive investigation of the use ud expenditure of Federal funds for and by the National Con- mission last year in response to an inquiry from Representative Olin E. Teague and several other Congressmen. A copy of our January 13, 1977, report to Mr. Teague, which concluded that the activities of the WY Commission did not violate the anti-lobbying provisions of any Federal statute, is enclosed. We explained that the term lobbying and the advocacy of a particular point of view are not necessarily synonymous, and that in our view, lobbying means direct communication to a member or members of a legislative body, State and Federal, to influence the vote on legislation pending before or proposed to that body or the vote on the ratification of constitutional amendments. We believe that many people who oppose ratification of the Elual Rights Amendment (ERA) believe--or have been led to believe--that Federal law prohibits a Federal agency, such as the IWYj from adopting an advocacy position on this issue. Thus they protest the composition of the Conference as not comprising a bala'i e of points of view. howeveri we must point out that section 3(a)Vof Pub. L. No. 94-167 only requires a mix of representatives from local, State, regional, and national agencies, groups, etc. which work to advance the rights of women, and of members of the public with special emphasis on the representa- tion of low-income women, members of diverse racial, ethnic, and religious groups, and women of all ages. Nowhere in any applicable statute is there a requirement that the Conference members must represent different points of view on ratification of the ERA.

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