Why isn't GMC registered with the Milwaukee County Clerk?

We already know that the Greater Milwaukee Committee (GMC) hired an army of lobbyists to help write and ram through AB 85. GMC President Julia Taylor and operative Brian Schupper also are registered with the state as lobbyists.  Given their active involvement in micromanaging Milwaukee County this is certainly no surprise.  What may be a surprise is that neither of those two GMC paid employees are registered as lobbyists with the Milwaukee County Clerk. Furthermore GMC is not even registered as a principal with the Milwaukee County Clerk.  In fact I see no evidence of any GMC registrations for the past several years even though they have been trying to micromanage Milwaukee County government for some time.

So what gives? How could an organization that has employed such a heavy hand to influence Milwaukee County government not even be registered as a principal and their paid operatives as lobbyists?

First take a look at some important definitions taken directly from Milwaukee County Ordinance Chapter 14 which regulates lobbying activities in the county.

What is "lobbying"?

"Lobbying means the practice of attempting to influence legislative or administrative action by oral or written communication with any county official..."

What is a "lobbyist"?

"Lobbyist means any person who is employed by a principal or who contracts for or receives economic consideration...and whose duties include lobbying on behalf of the principal."

There is the following exception to note here:

"If an individual's duties on behalf of a principal are not limited exclusively to lobbying, the individual is a lobbyist only if he or she makes lobbying communications on more than three (3) days within a reporting period."

What is the reporting period?

"Reporting period means any six-month period beginning with January 1 and ending on June 30 or beginning with July 1 and ending on December 31."

As far as I can tell, the only possible way that GMC and their paid operatives could be exempt from the county's ordinance is if those operatives didn't communicate more than 3 times with county officials during the above described reporting periods.  I find that very hard to believe given the way that they have been so heavily involved in trying to micromanage Milwaukee County government.

For example, just consider some of the following contacts by Julia Taylor and Brian Schupper with officials from the County Executive's office last year.   Keep in mind that this doesn't even include any contacts with County Supervisors or other county officials (You can find the below referenced communications in the files that I made public last week).

• Apparently Julia Taylor sought an update from them regarding the LRLF Planning Committee on or around March 6, 2012.
• On March 26, 2012, Brian Schupper emailed an administration official inviting him to a GMC event and mentioned the fact that they had also met earlier that same day. 
• Chris Abele's calendar includes a meeting with Julia Taylor on April 5, 2012 regarding the comptroller issue.
•  On May 7, 2012, Brian Schupper communicates multiple times with Abele administration officials asking them to write a supportive letter related to a grant that they are seeking. In these two emails he also references a conversation day(s) earlier.  
• Chris Abele's calendar includes a meeting on June 25, 2012 with Julia Taylor.  The agenda states that they will discuss Madison's City Camp and doing something similar for the county.  They also were set to discuss "legislative strategy".  
• On July 18, 2012 and July 23, 2012 Brian Schupper again emails Abele administration officials about getting a letter of support from the County Executive. 
•  Chris Abele's calendar shows that he was set to go to the University Club for a GMC County Task Force meeting on July 18, 2012 

Again do these meetings and communications add up to more than 3 for a filing period? Perhaps it is close or maybe they don't by themselves but did these two paid GMC operatives communicate with any other county officials during that time?  For example, while the comptroller issue was being discussed and debated, I've heard that GMC was busy inviting county supervisors across the street to the Wisconsin Club to discuss it.

Since GMC wants to micromanage Milwaukee County so badly they should also make sure that they are in full compliance with basic Milwaukee County ordinances.  Perhaps there is a simple explanation for all of this that I am missing but I still think that the public should get a proper and full explanation. This is especially true given how heavily GMC has imposed itself on our county government.