The latest filing from the U.S. Chamber of Commerce reports that the trade association, which represents 300,000 members–mostly businesses–spent a whopping $34,690,000 on lobbying in the third quarter of 2009. So what does this number actually mean? What are they spending their money on?

Part of it was spent on other lobbying firms. Outside lobbyists reported receiving $508,100 from the Chamber to lobby (that number should really be $510,000–one firm didn’t round to the nearest $10,000) in the third quarter (slightly less than the $526,000 spent in the second quarter, when the Chamber reported spending a lusty but much lower total of $7,430,000). So that still leaves us with $34,180,000.

It’s third quarter report shows 81 in-house lobbyists. That works out to $421,975 per lobbyist. For three months work. I doubt they’re being paid that much.

The Chamber elects to report how much it spends on lobbying using section 162(e) of the Internal Revenue Code, which says that businesses can’t deduct lobbying expenses and then defines what lobbying is. Here’s the IRS’ definition of lobbying:

(A) influencing legislation,

(B) participation in, or intervention in, any political campaign on behalf of (or in opposition to) any candidate for public office,

(C) any attempt to influence the general public, or segments thereof, with respect to elections, legislative matters, or referendums, or

(D) any direct communication with a covered executive branch official in an attempt to influence the official actions or positions of such official.

It’s letter C that likely explains the huge upsurge in spending: the Chamber has launched a lot of issues ads; I’ll call them tomorrow to make sure.

How much they’re spending on ads relative to lobbyists is anyone’s guess–but should be disclosed. And how one can compare the nearly $35 million that the Chamber discloses on its reports to the $776,000 that the Service Employees International Union discloses is beyond me. The SEIU uses the Lobbying Disclosure Act definition of lobbying, which does not include spending on efforts to influence the general public.

For those interested in plunging deeper into lobbying disclosure rules, via Googlebooks comes this book from the American Bar Association on lobbying — the link goes to the chapter on 162(e).

Arnold and Porter also has an explanation of what filing under section 162e entails (note that the only covered executive branch officials are the President, the Vice President, members of the cabinet and their deputies).