A Better Cambridge IEPAC Firewall Policy

(Policy last updated May 30, 2023.)

  1. Purpose. The purpose of this firewall policy is to prevent coordination, as defined in CMR 970 2.21, between A Better Cambridge Independent Expenditure Political Action Committee (ABC IEPAC) and Cambridge City Council campaigns, and to rebut any presumptions of coordination that may occur during the campaign season.

  2. Motivation. The bottom-line statement of CMR 970 2.21 is that no IEPAC money may be spent on electoral communications at the suggestion of or in consultation with any candidate for City Council.

  3. Prohibition on Information Flow. At all times this policy prohibits the flow of strategic non-public information from City Council candidates or their campaigns to ABC IEPAC.

  4. Separation of Persons.

    1. Core IEPAC Volunteers are the only persons making independent expenditures or electioneering communications for the IEPAC.

    2. The only staff (paid or otherwise) who will service the Core IEPAC Volunteers in the making of independent expenditures or electioneering communications are the Core IEPAC Volunteers themselves and persons that the IEPAC makes an explicit, written decision to collaborate with (e.g. a graphic designer).

    3. No Core IEPAC Volunteers, nor persons that the IEPAC makes an explicit, written decision to collaborate with, shall provide services to any Cambridge City Council campaigns.

      1. Volunteers who assist A Better Cambridge (ABC) or ABC IEPAC in ways that do not involve the planning of IEPAC expenditures, campaign strategy, or fundraising strategy are referred to as Non-Spoiled Volunteers and are not subject to this restriction.

      2. Persons that the IEPAC receives services from in a non-collaborative manner (e.g. print shops, providers of voter lists) are not subject to this restriction.

  5. Procedures To Ensure Separation.

    1. No strategic non-public information from any City Council candidate or campaign is allowed in the residence or office of any Core IEPAC Volunteer.

    2. No strategic non-public information from any City Council candidate or campaign is allowed in any ABC or ABC IEPAC email lists, Slack channels, Google Drive folders, etc. 

    3. ABC IEPAC will create a private Google Group, Google Drive Folder and a private Slack channel, with membership limited only to Core IEPAC Volunteers, for discussion and planning of IEPAC expenditures, campaign strategy, and fundraising strategy.

    4. ABC and ABC IEPAC will designate Justin Saif a Non-Spoiled Volunteer, to be the ABC Candidate Liaison. The ABC Candidate Liaison will interface with candidates for the purpose of securing their completion of any questionnaires or attendance at any forums which ABC may produce.

    5. In the event that Core IEPAC Volunteers meet with any City Council candidates, they will refrain from discussing any strategic non-public information, including but not limited to future campaign plans of the candidate and future expenditure plans of the IEPAC.

    6. In the event that a Non-Spoiled Volunteer (such as, but not limited to, the Candidate Liaison) becomes aware of any strategic non-public information about a candidate’s campaign plans, they must refrain from sharing it with any Core IEPAC volunteers.

  6. Examples of Permitted Activities. ABC IEPAC does not consider any of the following scenarios to be violations of the Firewall Policy:

    1. Core IEPAC Volunteers donating money to City Council campaigns or attending publicly-advertised events organized by City Council campaigns.

    2. Core IEPAC Volunteers, in their capacity as ABC advocates, meeting with an incumbent City Councillor or a City Council candidate for the sole purpose of discussing housing policy, so long as they ensure the discussion does not involve any strategic non-public information either on the IEPAC’s part or the candidate’s.

    3. Core IEPAC Volunteers, in their capacity as ABC advocates, participating in discussions about who ABC should endorse for election.

  7. Distribution.

    1. This policy shall be made publicly available on the ABC IEPAC website.

    2. The ABC Candidate Liaison shall send a link to this policy to every City Council candidate.

    3. This policy will be referenced and summarized at any event geared towards Non-Spoiled Volunteers, and ABC IEPAC leaders will work to ensure that any Non-Spoiled Volunteers who are particularly likely to be close to any candidate’s campaign are expressly reached out to to ensure they understand this firewall policy.

    4. Any person that the IEPAC makes an explicit, written decision to collaborate with shall be shown this firewall policy, and shall be asked to confirm that they are not providing services to any other Cambridge City Council campaigns (and have not within the past 90 days).

    5. Any person wishing to become a Core IEPAC Volunteer shall be shown this firewall policy, and shall be asked to confirm that they are not providing services to any other Cambridge City Council campaigns (and have not within the past 90 days) and shall be required to sign a statement indicating the understand and will follow the policy.

  8. Violations. ABC IEPAC understands that the existence of this written policy may rebut presumptions of coordination, but it is critical the policy is actually followed. ABC IEPAC also understands that violations of this policy, should they accidentally occur, do not necessarily imply violations of CMR 970 2.21.