FEDERAL ELECTION COMMISSION

Washington, DC 

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of ) 

 ) 

Katie Arrington for Congress ) MUR 7510

and Kathleen Randall in her official capacity as treasurer ) 

Katherine E. Arrington ) 

Fix Our Flooding, Inc. ) 

1st Street Foundation, Inc. ) 

Matthew Eby ) 

 

STATEMENT OF REASONS OF CHAIRMAN ALLEN DICKERSON AND 

COMMISSIONER JAMES E. “TREY” TRAINOR, III

This Matter arose from a complaint alleging that Fix Our Flooding, Inc. (“FOF”) and 

Katie Arrington for Congress (the “Arrington Committee”) jointly produced and distributed 

a television advertisement that qualified as a coordinated communication under Commission 

regulations, resulting in a prohibited corporate in-kind contribution from FOF to the 

Arrington Committee.1 The Complaint also alleges that the advertisement lacked the proper 

disclaimer required by the Federal Election Campaign Act of 1971, as amended (“the Act”).2

On November 9, 2021, the Commission voted to dismiss these allegations.3 Although we agree 

with our Office of General Counsel (“OGC”) that dismissal was the correct course of action in 

this Matter, our reasoning regarding the alleged coordinated communication differs from the 

analysis contained in the First General Counsel’s Report.

The advertisement at issue—which one press outlet reported as airing on television 

on August 23, 2018,4 outside the 60-day electioneering communication period for the 2018 

general election—featured an interview of then-federal candidate and sitting state 

representative Katie Arrington discussing the dangers of coastal flooding in South Carolina’s 

Low Country, which is largely located within the state’s first congressional district. Both the 

Arrington Committee and FOF acknowledge that Arrington participated in a videotaped 

interview with FOF, which in turn used the footage to create the ad, but they collectively 

deny that Arrington had any involvement with the creation of the ad after the interview 

1 Compl. at 1–2, MUR 7510 (Oct. 5, 2018). 2 Id. at 12 n.23. 3 Certification, MUR 7510 (Nov. 9, 2021).

4 Jamie Lovegrove, Flooding Advocacy Group Pulls TV Ad Featuring Katie Arrington Ahead of 

Election, THE POST AND COURIER (Aug. 24, 2018).

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occurred.5 FOF further asserts that it cancelled its broadcast media buy before the 

advertisement ever aired and that it did not authorize or pay for placement of the ad.6

In its recommendation to the Commission, OGC maintains that FOF’s ad qualified as

a coordinated communication under Commission regulations, but recommends dismissal 

based on FOF’s assertion that the ad was preemptively cancelled and the lack of evidence 

that the ad aired for more than a single day.7 OGC also recommends dismissal of the 

disclaimer-related allegations on the basis that FOF is not a registered federal political 

committee and the ad did not contain express advocacy or solicit contributions to Arrington.8

We agree with OGC’s dismissal recommendations, but we disagree that the FOF ad 

qualified as a “coordinated communication” under Commission regulations. In our view—

even leaving aside the unresolved questions of whether FOF expended funds for its quicklycancelled ad, or whether the ad actually aired on broadcast television—the ad, to the extent 

it relies upon filmed interview footage, falls within 11 C.F.R. § 109.21(f)’s safe harbor for

candidates’ responses to inquiries about their position on legislative or policy issues that do 

not involve campaign plans, projects, activities, or needs. Additionally, the Complaint seeks 

to ground a violation in Arrington’s discussion of coastal flooding at a press conference 

preceding the airing of the advertisement, and her campaign website’s listing of coastal 

flooding as a key issue for her campaign. Both the press conference and the information on 

the website, however, fall within the coordination regulation’s safe harbor for information 

obtained from a publicly available source. 

FOF’s advertisement is pure issue speech addressing a topic of significant public 

concern: coastal flooding arising from severe thunderstorms, hurricanes, and other weatherrelated conditions, which has plagued South Carolina’s Low Country in recent years. The 

coordinated communication regulations are not in place to restrict communications or 

discussions regarding pending legislation or other issues of public policy,9 and OGC’s view 

that the non-electoral speech of public figures on issues of public importance should be subject

to the Act ultimately collapses a key practical distinction between regulated political speech 

and unregulated issue speech. Because FOF’s advertisement represents the latter, which

falls outside the reach of the Act, we voted to dismiss.

I. FACTUAL BACKGROUND

Katie Arrington served as a South Carolina State Representative between 2017 and 

2019,10 and was a candidate in the 2018 general election for the U.S. House of 

Representatives in South Carolina’s first congressional district.11 Katie Arrington for 

5 FOF Resp. at 4, MUR 7510 (Nov. 2, 2018); Arrington Resp. at 2, MUR 7510 (Dec. 6, 2018).

6 FOF Resp. at 2–3.

7 First Gen. Counsel’s Report at 2, MUR 7510.

8 Id. at 3.

9 See Coordinated and Independent Expenditures, 68 Fed. Reg. 421, 441 (Jan. 3, 2003) (Explanation 

and Justification) (“E&J”). 10 See https://www.scstatehouse.gov/member.php?code=0052272721. 11 Katie Arrington, FEC Form 2, Amended Statement of Candidacy (Oct. 23, 2018). Arrington 

defeated Mark Sanford in the Republican primary but lost the general election to Democratic 

candidate Joe Cunningham. https://www.enr-scvotes.org/SC/92124/Web02-state.222648/#/.

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Congress is her principal campaign committee, and Kathleen Randall is the committee’s 

treasurer.12 

Fix Our Flooding, Inc. is a Delaware nonprofit corporation that was incorporated on 

August 10, 2018.13 FOF states that it is a § 501(c)(4) social welfare organization, and that its 

activities include “issue advocacy focused on educating citizens in coastal areas about sea 

level rise and the associated flooding, along with practical solutions that can be implemented 

to prevent it.”14 Matthew Eby is FOF’s Director.15 FOF is the advocacy arm of First Street,16

a § 501(c)(3) organization registered in the District of Columbia and in New York.17 First 

Street focuses on providing education on issues related to sea level rise.18 Eby is also the 

Founder and Executive Director of First Street.19 

On August 21, 2018, Arrington held a press conference with municipal, county and 

state leaders to discuss the topic of flooding in South Carolina’s Low Country.20 On August 

23, 2018, two days after the press conference, FOF’s advertisement featuring Arrington 

reportedly aired on WTAT Fox 24, a local Charleston television station, and possibly other 

Charleston area stations, according to the Complaint.21 A transcript of the ad22 follows: 

On Screen Audio

Katie Arrington Speaking on Screen

Graphic next to Arrington: 

Katie Arrington 

South Carolina Representative

Katie Arrington: 

My friend and I were driving down to Hilton 

Head and we’re in a head on collision with a 

drunk driver. Time was of the essence.

Graphic: The Post and Courier Newspaper 

Headline:

Katie Arrington:

If that team at MUSC were not able to take us, 

how rapidly they were able to get to us that 

12 Katie Arrington for Congress, FEC Form 1, Amended Statement of Organization (Oct. 23, 2018). 

13 See State of Delaware, Division of Corporations, Entity Info. (Fix Our Flooding). 14 FOF Resp. at 2.

15 See Designation of Counsel for FOF (Oct. 24, 2018). 

16 First Street Resp. at 2, MUR 7510 (Nov. 7, 2018).

17 Id. First Street was incorporated in DC on October 27, 2016 and in New York on February 6, 2019. 

See DC Department of Consumer and Regulatory Affairs, Filing, First Street Foundation, Inc.; NYS 

Department of State, Division of Corporations, Entity Info. (First Street Foundation).

18 See First Street Resp. at 2. 

19 Id. 20 See Compl. at 3 (citing Press Release, Katie Arrington for Congress, Katie Arrington Announces 

Lowcountry Plan (Aug. 21, 2018), available at 

https://www.votekatiearrington.com/2018108121/arringtonannouncesfloodingplan/; Heather Olinger, 

Katie Arrington announces Lowcountry flooding plan, V/CBD-TV News 2 (Aug. 21, 2018), available 

at https://www.counton2.com/news/local-news/katie-arrington-announces-lowcountry-flooding-plan/. 21 See Compl. at 4–5 (citing Jamie Lovegrove, Flooding Advocacy Group Pulls TV Ad Featuring Katie 

Arrington Ahead of Election, THE POST AND COURIER (Aug. 24, 2018)). 22 See Fix Our Flooding Katie Arrington Ad (Aug. 23, 2018), available at 

https://www.postandcourier.com/fix-our-flooding-katie-arrington-ad/video_b7525732-a712-11e8-b7a2-

4f2446d5f418.html. 

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Katie Arrington, in critical but stable 

condition, to face more surgery after 

crash. By Schuyler Kropf, June 23, 2018

Graphic: The State Newspaper Headline:

South Carolina lawmaker Arrington had 

two major surgeries Sunday, but ‘full 

recovery’ expected. By Noah Feit, June 

24, 2018

Images of Flooding in Charleston While 

Arrington is Speaking

Graphic: Fix Our Flooding logo

Watch Katie’s full story at Fix Our 

Flooding.org. 

Text: Paid For By Fix Our Flooding, Inc.

night, neither one of us would have survived. 

High tide and a decent rain I wouldn’t be here. If 

they had to go around to avoid the cross town I 

wouldn’t be here. This is a problem. When 

seconds count and you don’t have that option. 

How do you save people’s lives? We have sea 

levels rising. We have some of the most valuable 

resources on the peninsula. We have MUSC. We 

have Roeper. We have the VA. Literally 

hundreds of yards from the harbor. We need to 

start looking at it in a pro-active manner. We 

don’t right now. It’s reactive. We need to build a 

sea wall. Protect the hospital district in South 

Carolina. It’s simple. This community. The low 

country. Our life is worth it.

According to a press report cited by the Complaint, filings with the Federal 

Communications Commission (“FCC”) indicate that FOF paid at least $75,000 to air the ad 

from August 23 through September 6 on three different local television stations.23 In addition, 

FOF reportedly hired Push Digital, a business and political consulting firm, to manage the 

creative aspects of the ad campaign.24 The firm also provided services to the Arrington 

Committee, as reflected on the committee’s disclosure reports.25 FOF purportedly sought to 

pull the ad before it was broadcast, but local media reported that it was aired by one outlet 

for one day, on August 23, 2018.26 In its response, FOF concedes that it purchased a media 

buy but states it cancelled the buy on August 22, 2018 and that the ad was subsequently

“leaked.”27

Publicly available filings from the FCC show that a media buyer, Tanya Renicker/GRP 

Buying LLC, filed an “Agreement Form for Non-Candidate/Issue Advertisements” on July 

12, 2018, requesting broadcast time for FOF.28 Eby is listed on the form as the officer/director 

for FOF. Additional filings for the ad buy include contracts with various broadcasters 

showing contract dates from August 22 through September 6, 2018, and cost information.29

The scheduled start date for the ad campaign appears to have been changed from August 22 

23 See Compl. at 5 (citing Lovegrove, supra n.21). 24 See id. at 6.

25 Disclosure reports filed by the Arrington Committee show a $2,500 disbursement to Push Digital 

on September 7, 2017. See 2017 October Quarterly Report, Schedule B (FEC Form 3) at 24. 

26 Lovegrove, supra n.21. 27 FOF Resp. at 4–5. 

28 See FCC Filings at https://publicfiles.fcc.gov/find/fix%20our%20flooding/page-offset-0/order-bestmatch/filter-[]/#files.

29 Id. 

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to August 23.30 A document dated August 27, 2018, four days after the ad apparently aired, 

includes an instruction to cancel the ad buy order on WCSC-TV: “Cancel Order Before Start 

Per Buyer’s Direction, Total is $0, Please Confirm Thanks Emily.”31 The filing does not 

indicate when the cancel order was confirmed and acted upon.

The day after the ad allegedly aired, Arrington posted a link to the advertisement on 

her campaign’s Facebook page, along with an article describing the withdrawal of the ad.32

In addition, Arrington posted a rebuttal to the newspaper article in which she defends her 

decision to provide the interview to FOF: “[s]o when a non-profit group dedicated to fixing 

the flooding problems around MUSC asked me to sit down and tell my story on camera — I 

didn’t hesitate. I want to fix this problem. It’s why I’m running for Congress in the first 

place ....”33

II. APPLICABLE LAW

The Act prohibits corporations from making contributions to federal candidates or 

their committees, and corporate officers and directors from consenting to such 

contributions.34 It also prohibits federal candidates or their committees from knowingly 

accepting corporate contributions.35 Expenditures made by any person “in cooperation, 

consultation, or concert with, or at the request or suggestion of” a candidate or his authorized 

committee or agent qualify as an in-kind contribution to the candidate and must be reported 

as expenditures made by the candidate’s authorized committee.36

A communication that is coordinated with a candidate or his or her authorized 

committee is considered an in-kind contribution and is subject to the limits, prohibitions, and 

reporting requirements of the Act.37 The Commission’s regulations provide that a 

communication is coordinated with a candidate, his or her authorized committee, or an agent 

of either if it meets a three-prong test: (1) it is paid for, in whole or in part, by a person other 

than the candidate or authorized committee; (2) it satisfies a content standard in 11 C.F.R. § 

109.21(c); and (3) it satisfies a conduct standard in 11 C.F.R. § 109.21(d).38 All three prongs 

must be satisfied for a communication to be considered coordinated.39

“Payment” occurs when a communication is paid for by a person other than the 

candidate (or his or her authorized committee) with whom it is coordinated.40 A 

communication satisfies the “content” prong if it qualifies as an electioneering 

30 Id. 31 See First Gen. Counsel’s Report at 6 n.30.

32 See Compl. at 6–7 (citing

https://www.facebook.com/pg/VoteKatieArrington/posts/?ref=page_internal).

33 Id. 34 52 U.S.C. § 30118(a).

35 Id.

36 52 U.S.C. § 30116(a)(7)(B)(i); 11 C.F.R. § 109.20(b).

37 52 U.S.C. § 30116; 11 C.F.R. § 109.21(b).

38 11 C.F.R. § 109.21(d).

39 11 C.F.R. § 109.21(a); see also E&J at 453.

40 11 C.F.R. § 109.21(a)(1).

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communication; or as a public communication41 that either (1) republishes campaign 

materials; (2) contains express advocacy or its functional equivalent; or (3) refers to a clearly 

identified House or Senate candidate, is publicly distributed or disseminated 90 days or fewer 

before an election, and is directed to voters in the jurisdiction of the clearly identified 

candidate.42 A communication satisfies the “conduct” prong if it is created, produced, or 

distributed at the request, suggestion, or assent of a candidate or their authorized committee 

or agent; if a candidate, candidate committee, or their agent was “materially involved” in 

decisions regarding the communication; if the communication was the result of “substantial 

discussion” between the payor and the clearly identified candidate or their opponent (or their 

respective authorized committees) regarding specific campaign plans, projects, activities, or 

needs; if a common vendor or former employee paid for or conveyed material non-public 

information relating to the campaign plans, projects, activities, or needs of the clearly 

identified candidate or their opponent to the payor; or if the communication contains 

republished campaign materials.43

The coordinated communication regulation also contains several regulatory safe 

harbors with respect to the conduct standard, which encompass, inter alia, candidates’

responses to inquiries about legislative or policy issues and campaign information obtained 

from a public source.44

III. LEGAL ANALYSIS

The threshold question in this Matter is whether FOF’s advertisement is governed by 

the coordinated communication regulation. As noted above, such communications must 

satisfy all three prongs—payment, content, and conduct—of the test set forth at 11 C.F.R. § 

109.21. 

With respect to the payment and content prongs of this test, the facts are disputed by 

the parties. The Complaint, citing a press report, asserts that FOF’s ad was aired on 

television for a single day (August 23, 2018) by FOX’s Charleston, South Carolina affiliate, 

and that FOF disbursed $75,000 to air the commercial on three major Charleston area TV 

stations in addition to $2,500 to a vendor for “digital consulting” attributable to the ad.45

FOF, however, asserts that the ad buy was cancelled prior to broadcast and payment to the 

FOX affiliate was refunded, and therefore that the advertisement does not qualify as a “public 

communication” under our regulations.46 FCC records do not definitively affirm either 

account: although FOF’s media buyer requested broadcast time on FOF’s behalf, FOF also 

submitted instructions to cancel that ad buy “Before Start”—and while the document

41 “Public communication” is a defined term that includes communications made by means of 

broadcast, cable, or satellite; newspaper; magazine; outdoor advertising facility; mass mailing; 

telephone bank, or any other form of general public political advertising. It does not include Internet 

communications, except if they are placed for a fee on another person’s website. 11 C.F.R. § 100.26. 42 11 C.F.R. § 109.21(c).

43 11 C.F.R. § 109.21(d). 44 11 C.F.R. §§ 109.21(d)(2)-(5); (f)–(i).

45 Compl. at 5–6.

46 FOF Resp. at 2.

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addressing the cancellation bears a date after the ad allegedly aired, it does not indicate when 

the cancel order was confirmed or acted upon.47

These facts offer meaningful—but, in our view, circumstantial and indirect—evidence 

suggesting that the ad may have aired on broadcast television for one day in August 2018. It 

is certainly possible that the ad was broadcast, thus qualifying it as a public communication 

under our regulations and satisfying the first two prongs of the coordinated communications 

test. But even if we were to stipulate to this evidence and agree with Complainant’s (and 

OGC’s) view that FOF’s ad satisfied the payment and content prongs, we believe that the

ad—and the interview that generated its content—falls under 11 C.F.R. § 109.21(f)’s safe 

harbor for candidates’ responses to inquiries about their position on legislative or policy 

issues that do not involve campaign plans, projects, activities, or needs. 

Although FOF’s Response cites this safe harbor as an affirmative defense,48 OGC’s 

analysis summarily dismisses the possibility that it applies.49 The basis for this conclusion 

is, apparently, the notion that because coastal flooding was a key issue for voters and a 

specific focus for Arrington’s campaign,50 FOF’s interview necessarily represented a 

discussion between FOF and Arrington regarding her campaign’s plans, projects, activities, 

or needs. This position relies on an inherently imprecise determination as to which issues are 

sufficiently central to a campaign and which are legally unimportant. We doubt whether such 

a task could be accomplished consistently and objectively, or that the government should be 

in the business of parsing the campaign messages of federal candidates—especially when 

elevating an issue, as here, would not only silence some issue speech, but influence which 

issues are discussed at all. After all, the end result of OGC’s reasoning is that FOF’s 

advertisement was illegal but that another near-identical ad, discussing a less-salient issue, 

might be perfectly lawful under § 109.21(f).

These vagueness concerns are not new. As the Supreme Court recognized in Buckley 

v. Valeo, “the distinction between discussion of issues and candidates and advocacy of election 

or defeat of candidates may often dissolve in practical application. Candidates, especially 

incumbents, are intimately tied to public issues involving legislative proposals and 

governmental actions.”51 Indeed, this insight is among the reasons § 109.21(f) exists. When 

the Commission promulgated that provision in response to the First Circuit’s decision in 

Clifton v. FEC, it noted that the coordinated communication regulations “are not intended to 

restrict communications or discussions regarding pending legislation or other issues of public 

policy,” and that although Clifton specifically related to voter guides produced by 

corporations or labor organizations, the safe harbor is explicitly more permissive than the 

regulations at issue in that case.52 Section 109.21(f) is, therefore, specifically aimed at 

47 See supra n.28–31 and accompanying text.

48 FOF’s Response mentions the safe harbor for responses to inquiries about legislative or policy 

issues in the context of its rebuttal to the “content” prong, but the safe harbor is appropriately 

characterized as a defense to the “conduct” prong.

49 First Gen. Counsel’s Report at 10–11.

50 Arrington’s campaign, like many campaigns before and since, maintained a campaign website that 

listed her views and positions on certain key issues, and in Arrington’s case, 

“Infrastructure/Flooding” was one of the nine issues listed.

51 424 U.S. 1, 42 (1976) (per curiam).

52 See E&J at 440–41; Clifton v. Fed. Election Comm’n, 114 F.3d 1309 (1st Cir. 1997).

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protecting the First Amendment right of public figures to talk about public issues, and for 

citizens and civil society groups to engage in discussions with elected leaders and engage in 

issue-based activism. FOF’s ad was created and produced by a nonprofit advocacy group that 

specifically names coastal flooding awareness as one of its raisons d’être. It did not discuss 

or even mention the 2018 general election or Arrington’s status as a federal candidate, let 

alone engage in express advocacy for or against her candidacy. It involves and reflects 

precisely the sort of communications § 109.21(f) contemplates and protects.

The Complaint also argues that Arrington’s statements at the August 21, 2018 press 

conference (e.g., that her campaign planned to hold monthly coastal flooding roundtables), as 

well as her campaign website’s listing flooding and infrastructure as one of nine key election 

issues, illustrate her “material involvement” in the creation, production, or distribution of 

FOF’s advertisement.53 However, our coordinated communication regulation provides that 

the “material involvement” factor within the conduct prong is not satisfied if the information 

in question “is obtained from a publicly available source.”54 Publicly available sources include 

candidate speeches and interviews, campaign press releases, and candidates’ websites.55

Arrington’s statements at the press conference and on her campaign website plainly fall 

within this definition. 

Finally, the Complaint and OGC also appear to offer Arrington’s actions in the days 

following the ad—namely, the fact that her campaign posted the ad on its Facebook page—

as after-the-fact justification for the view that she (or her campaign) were materially involved 

in its making.56 However, the “request or suggestion” and “material involvement” portions of 

the coordinated communications regulation, which only address conduct occurring before the 

creation, production, or distribution of a communication, do not provide for such a

presumption. There is simply is no basis in the Act or Commission regulations for the notion 

that a candidate or campaign satisfies the conduct prong when it ratifies or endorses an 

outside group’s communication after its initial dissemination. Apart from the existence of the 

FOF interview itself—which we view as falling under the safe harbor at section 109.21(f)—

the Commission has not been presented with evidence indicating that Arrington and FOF 

discussed her campaign plans, projects, activities, or needs; that Arrington had material 

involvement in decisions relating to the ad’s intended audience, means or mode of 

distribution, timing, frequency, or duration; or that a common vendor conveyed material 

information from the Arrington campaign to FOF.

IV. CONCLUSION

Coastal flooding arising from severe thunderstorms, hurricanes, and other weatherrelated conditions has been—and continues to be—an issue of concern in South Carolina’s 

Low Country.57 At the time of Arrington’s interview with FOF, she was a sitting state official 

53 Compl. at 11–12.

54 See 11 C.F.R. §§ 109.21 (d)(2)-(5); see also Revised Explanation & Justification, Coordinated 

Communications, 71 Fed. Reg. 33,190, 33,205 (June 8, 2006).

55 Id.

56 First Gen. Counsel’s Report at 13 (incorrectly described as posted on campaign website); Compl. at 

11. 

57 See, e.g., NAT’L WEATHER SERV., HISTORIC FLOODING - OCTOBER 1-5, 2015, available at

https://www.weather.gov/chs/HistoricFlooding-Oct2015; Tori B. Powell, South Carolina braces for 

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in the South Carolina legislature. The idea that the Act could prohibit a sitting state official 

who happens to be running for federal office from discussing an issue of public concern with 

an advocacy group that specifically focuses on that issue is constitutionally suspect and runs 

counter to the Explanation and Justification provided by the Commission when it 

promulgated the safe harbor at 11 C.F.R § 109.21(f). 

We agree that dismissal was the appropriate outcome in this Matter, but we are 

unconvinced that FOF’s ad—which contains no electoral portion and does not identify 

Arrington as a federal candidate—satisfies the conduct prong of the coordinated 

communications test. Accordingly, we agreed with OGC’s recommendation and voted to 

dismiss these allegations.

January 24, 2022 

Date

___________________________ 

Allen Dickerson

Chairman

___________________________ 

James E. “Trey” Trainor, III

Commissioner 

major coastal flooding and high tides, CBS NEWS (Nov. 5, 2021), available at 

https://www.cbsnews.com/news/flooding-south-carolina-tides/.

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