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The Center for Organizational Research and Education (CORE), formerly the Center for Consumer Freedom (CCF) and prior to that the Guest Choice Network, is an American
non-profit entity A nonprofit organization (NPO) or non-profit organisation, also known as a non-business entity, not-for-profit organization, or nonprofit institution, is a legal entity organized and operated for a collective, public or social benefit, in co ...
founded by Richard Berman. It describes itself as "dedicated to protecting consumer choices and promoting common sense." Experts on non-profit law have questioned the validity of the group's non-profit status in ''
The Chronicle of Philanthropy ''The Chronicle of Philanthropy'' is a magazine that covers the nonprofit world of philanthropy. Based in Washington, DC, it is aimed at charity leaders, foundation executives, fund raisers, and other people involved in philanthropy. ''The Chroni ...
'' and other publications, while others, including political commentator
Rachel Maddow Rachel Anne Maddow (, ; born April 1, 1973) is an American television news program host and liberal political commentator. Maddow hosts ''The Rachel Maddow Show'', a weekly television show on MSNBC, and serves as the cable network's special eve ...
and author Michael Pollan, have treated the group as an entity that specializes in
astroturfing Astroturfing is the practice of masking the sponsors of a message or organization (e.g., political, advertising, religious or public relations) to make it appear as though it originates from and is supported by grassroots participants. It is a p ...
. Projects and campaigns of CORE include Humane Watch, a watchdog of the Humane Society of the United States; the Environmental Policy Alliance, which criticizes
environmental activists The environmental movement (sometimes referred to as the ecology movement), also including conservation and green politics, is a diverse philosophical, social, and political movement for addressing environmental issues. Environmentalists advo ...
; and Activist Facts, a site dedicated to tracking tax-exempt nonprofits. The organization has been critical of organizations including the
Centers for Disease Control and Prevention The Centers for Disease Control and Prevention (CDC) is the national public health agency of the United States. It is a United States federal agency, under the Department of Health and Human Services, and is headquartered in Atlanta, Georgi ...
, the Center for Science in the Public Interest,
Mothers Against Drunk Driving Mothers Against Drunk Driving (MADD) is a non-profit organization in the United States, Canada and Brazil that seeks to stop drunk driving, support those affected by drunk driving, prevent underage drinking, and strive for stricter impaired drivi ...
, the Humane Society of the United States, People for the Ethical Treatment of Animals, and the Physicians Committee for Responsible Medicine.


History and background

CORE was founded in 1995 as the Guest Choice Network by Richard Berman, owner of the public affairs firm Berman and Company, with $600,000 from the
Philip Morris Phil(l)ip or Phil Morris may refer to: Companies *Altria, a conglomerate company previously known as Philip Morris Companies Inc., named after the tobacconist **Philip Morris USA, a tobacco company wholly owned by Altria Group **Philip Morris Inter ...
tobacco company to fight smoking limitations in restaurants. In 2005, Berman told ''
The Washington Post ''The Washington Post'' (also known as the ''Post'' and, informally, ''WaPo'') is an American daily newspaper published in Washington, D.C. It is the most widely circulated newspaper within the Washington metropolitan area and has a large nati ...
'' that the organization was funded by a coalition of restaurant and food companies as well as some individuals. , according to the group's website it is supported by companies, foundations and individual consumers. Sponsors were reported to include Brinker International, RTM Restaurant Group (the owner of Arby's), Tyson Foods, HMSHost Corp, and Wendy's.


Guest Choice Network

The forerunner to the CCF was the Guest Choice Network, organized in 1995 by Berman with money from Philip Morris, "to unite the restaurant and hospitality industries in a campaign to defend their consumers and marketing programs against attacks from anti-smoking, anti-drinking, anti-meat, etc. activists..." According to Berman, the mission was to encourage operators of "restaurants, hotels, casinos, bowling alleys, taverns, stadiums, and university hospitality educators" to "support hementality of 'smokers rights' by encouraging responsibility to protect 'guest choice.'" In November 2001, the group launched a website, ActivistFacts.com, which selected information gathered from IRS documents and media reports, describing the funding and activities of groups it opposed, listing key activists and celebrity connections. In January 2002, the Guest Choice Network became the Center for Consumer Freedom, a change of name the group said reflected that "the anti-consumer forces ereexpanding their reach beyond restaurants and taverns ndgoing into your communities and even your homes." In 2013, CCF became the Center for Organizational Research and Education.


Governance

The group is a tax-exempt
501(c)(3) A 501(c)(3) organization is a United States corporation, trust, unincorporated association or other type of organization exempt from federal income tax under section 501(c)(3) of Title 26 of the United States Code. It is one of the 29 types of 50 ...
nonprofit organization, and as such it is not required to disclose the identity of its funders. IRS records show that in 2013 CCF paid more than $750,000 to Berman and Company.


Employees

As of 2020, Will Coggin is the managing director. Previous CORE directors included Joseph Kefauver, Daniel Mindus, David Browne, James Blackstock, Richard Verrechia, F. Lane Cardwell, and Nelson Marchioli.


Activities

In 2002, CCF spokesman John Doyle described nationwide radio ads put out by the group as efforts to attract people to their website and "draw attention to our enemies: just about every consumer and environmental group, chef, legislator or doctor who raises objections to things like
pesticide Pesticides are substances that are meant to control pests. This includes herbicide, insecticide, nematicide, molluscicide, piscicide, avicide, rodenticide, bactericide, insect repellent, animal repellent, microbicide, fungicide, and lampri ...
use,
genetic engineering Genetic engineering, also called genetic modification or genetic manipulation, is the modification and manipulation of an organism's genes using technology. It is a set of technologies used to change the genetic makeup of cells, including t ...
of crops or
antibiotic An antibiotic is a type of antimicrobial substance active against bacteria. It is the most important type of antibacterial agent for fighting bacterial infections, and antibiotic medications are widely used in the treatment and prevention of ...
use in beef and poultry." CCF gave out annual "Tarnished Halo" awards to so-called "animal-rights zealots, celebrity busybodies, environmental scaremongers, self-appointed "public interest" advocates, trial lawyers, and other food activists", and its Guest Choice Network affiliate gave out the "Nanny Awards" to "food cops, anti-
biotech Biotechnology is the integration of natural sciences and engineering sciences in order to achieve the application of organisms, cells, parts thereof and molecular analogues for products and services. The term ''biotechnology'' was first used b ...
activists,
vegetarian Vegetarianism is the practice of abstaining from the consumption of meat (red meat, poultry, seafood, insects, and the flesh of any other animal). It may also include abstaining from eating all by-products of animal slaughter. Vegetarianism m ...
scolds and meddling bureaucrats". CCF criticized statistics used by nutrition groups to describe a global "obesity epidemic", and in 2005, it filed a series of
Freedom of Information Act Freedom of Information Act may refer to the following legislations in different jurisdictions which mandate the national government to disclose certain data to the general public upon request: * Freedom of Information Act 1982, the Australian act * ...
requests against the U.S.
Centers for Disease Control and Prevention The Centers for Disease Control and Prevention (CDC) is the national public health agency of the United States. It is a United States federal agency, under the Department of Health and Human Services, and is headquartered in Atlanta, Georgi ...
in response to a CDC study stating that 400,000 Americans die each year as a consequence of being obese. After CCF campaign CDC reduced its estimates to 112,000 annual deaths, leading CCF to advertise widely that it had discredited the study. Recently, CCF launched a campaign targeting
plant-based meat A meat alternative or meat substitute (also called plant-based meat or fake meat, sometimes pejoratively) is a food product made from vegetarian or vegan ingredients, eaten as a replacement for meat. Meat alternatives typically approximate qua ...
products like
Beyond Meat Beyond Meat, Inc. is a Los Angeles–based producer of plant-based meat substitutes founded in 2009 by Ethan Brown. The company's initial products were launched in the United States in 2012. History Founding Ethan Brown founded the company in ...
and
Impossible Foods Impossible Foods Inc. is a company that develops plant-based substitutes for meat products. The company's signature product, the Impossible Burger, was launched in July 2016. In partnership with Burger King, Impossible Whoppers were released ac ...
. CCF claims the
plant-based meat A meat alternative or meat substitute (also called plant-based meat or fake meat, sometimes pejoratively) is a food product made from vegetarian or vegan ingredients, eaten as a replacement for meat. Meat alternatives typically approximate qua ...
is nothing more than "ultra-processed imitations." The organization has run full-page ads in ''
The New York Times ''The New York Times'' (''the Times'', ''NYT'', or the Gray Lady) is a daily newspaper based in New York City with a worldwide readership reported in 2020 to comprise a declining 840,000 paid print subscribers, and a growing 6 million paid ...
'' and ''
The Wall Street Journal ''The Wall Street Journal'' is an American business-focused, international daily newspaper based in New York City, with international editions also available in Chinese and Japanese. The ''Journal'', along with its Asian editions, is published ...
''—in one comparing the product contents to dog food. As for why CCF is pursuing
plant-based meat A meat alternative or meat substitute (also called plant-based meat or fake meat, sometimes pejoratively) is a food product made from vegetarian or vegan ingredients, eaten as a replacement for meat. Meat alternatives typically approximate qua ...
,
Berman Berman is a surname that may be derived from the German and Yiddish phrase ( ‘ bear-man’)https://dbs.anumuseum.org.il/skn/en/c6/e250048/Family_Name/BERMAN or from the Dutch , meaning the same. Notable people with the surname include: * Abba ...
said, "The rhetoric is ahead of the facts...I’m not trying to say their stuff is going to kill you. What I am going to say is it is not healthier for you...These are not burgers or sausages or chicken strips that have been constructed with crushed celery." The project has included advertisements, reports, and
commercials A television advertisement (also called a television commercial, TV commercial, commercial, spot, television spot, TV spot, advert, television advert, TV advert, television ad, TV ad or simply an ad) is a span of television programming produce ...
. One ad that aired during the 2020 Super Bowl was met with a parody commercial from
Impossible Foods Impossible Foods Inc. is a company that develops plant-based substitutes for meat products. The company's signature product, the Impossible Burger, was launched in July 2016. In partnership with Burger King, Impossible Whoppers were released ac ...
. Most recently, CORE launched a campaign called China Owns Us. Its
website A website (also written as a web site) is a collection of web pages and related content that is identified by a common domain name and published on at least one web server. Examples of notable websites are Google Search, Google, Facebook, Amaz ...
contains a
white paper A white paper is a report or guide that informs readers concisely about a complex issue and presents the issuing body's philosophy on the matter. It is meant to help readers understand an issue, solve a problem, or make a decision. A white paper ...
called "China’s Global Supply Chain: How Chinese Communism Threatens American Interests."


Activism websites

In addition to its own websites the CCF, which since 2014 also uses the name "Center for Organizational Research and Education"(CORE), operates several dozen websites specifically targeting organizations and agencies working on social issues including animal rights, fair wages, transfats, drunken driving, sugar, labor union activities, and mercury content in fish. One CORE-run site, "Activist Facts", claims that "The organizations we track on this site are tax-exempt nonprofits, many of which engage in anti-consumer activism." The site features generally negative profiles of various groups it believes oppose consumer freedom, such as the Center for Science in the Public Interest,
Greenpeace Greenpeace is an independent global campaigning network, founded in Canada in 1971 by Irving Stowe and Dorothy Stowe, immigrant environmental activists from the United States. Greenpeace states its goal is to "ensure the ability of the Earth t ...
,
The Humane Society of the United States The Humane Society of the United States (HSUS) is an American nonprofit organization that focuses on animal welfare and opposes animal-related cruelties of national scope. It uses strategies that are beyond the abilities of local organizations. ...
,
PETA Peta or PETA may refer to: Acronym * Pembela Tanah Air, a militia established by the occupying Japanese in Indonesia in 1943 * People for the Ethical Treatment of Animals, an American animal rights organization * People Eating Tasty Animals, an ...
, the Restaurant Opportunities Center and
Mothers Against Drunk Driving Mothers Against Drunk Driving (MADD) is a non-profit organization in the United States, Canada and Brazil that seeks to stop drunk driving, support those affected by drunk driving, prevent underage drinking, and strive for stricter impaired drivi ...
. It hosts "biographies" offering negative portrayals of key activists and celebrity supporters of various groups. The site reports what it claims are links between profiled groups and extremism, and argues, in general, that the groups profiled hold extreme views that are contrary to the public interest. It claims to have examined 500,000 IRS documents in its profiling, listing—for each group—major donors, income and expenditure, key supporters and connections with other groups. CORE also manages campaigns critical of environmental groups. According to its site, the Environmental Policy Alliance (EPA) "is devoted to uncovering the funding and hidden agendas behind environmental activist groups and exploring the intersection between activists and government agencies." Green Decoys, a project of EPA, was reported to "argue...environmental organizations camouflage an activist agenda to influence policymakers and the public, funded by millions of dollars from huge foundations." More CCF-created websites include HumaneWatch.org, PhysicianScam.com, Trans-FatFacts.com, Animalscam.com, Obesitymyths.com, and CSPIScam.com. MercuryFacts.com and FishScam.com contain a mercury calculator that offers an alternative calculation of amount of a fish that can be eaten before getting an unsafe dose of mercury, calculated as ten times the
reference dose A reference dose is the United States Environmental Protection Agency's maximum acceptable oral dose of a toxic substance.Reference doses are most commonly determined for pesticides. The EPA defines an oral reference dose (abbreviated RfD) as: es ...
recommended by the EPA. CCF has also claimed (counter to research findings) that dieting and meal tracking do not lead to weight loss.


Funding

CORE says it receives funding from individuals, businesses and
foundations Foundation may refer to: * Foundation (nonprofit), a type of charitable organization ** Foundation (United States law), a type of charitable organization in the U.S. ** Private foundation, a charitable organization that, while serving a good cause ...
. Initial funding for the original Guest Choice Network organization came from Philip Morris, with the initial donation of $600,000 followed by a $300,000 donation the following year. Philip Morris attorney Marty Barrington wrote in a 1996 internal company memorandum: "As of this writing, PM USA is still the only contributor, though Berman continues to promise others any day now." By December, 1996, supporters consisted of Alliance Gaming (slot machines),
Anheuser-Busch Anheuser-Busch Companies, LLC is an American brewing company headquartered in St. Louis, Missouri. Since 2008, it has been wholly owned by Anheuser-Busch InBev SA/NV (AB InBev), now the world's largest brewing company, which owns multiple glo ...
(beer), Bruss Company (steaks and chops), Cargill Processed Meat Products,
Davidoff Davidoff is a Swiss premium brand of cigars, cigarettes and smoker's accessories. The Davidoff cigarette brand has been owned by Imperial Brands after purchasing it in 2006. The non-cigarette portion of the Davidoff tobacco brand is owned by O ...
(cigars), Harrah's (casinos), Overhill Farms (frozen foods),
Altria Altria Group, Inc. (previously known as Philip Morris Companies, Inc.) is an American corporation and one of the world's largest producers and marketers of tobacco, cigarettes and related products. It operates worldwide and is headquartered in ...
, and Standard Meat Company. The group's advisory panel comprised representatives from most of these companies, plus further representatives from the restaurant industry, including former Senator
George McGovern George Stanley McGovern (July 19, 1922 – October 21, 2012) was an American historian and South Dakota politician who was a U.S. representative and three-term U.S. senator, and the Democratic Party presidential nominee in the 1972 pres ...
, and Carl Vogt of the law firm Fulbright & Jaworski. Acknowledged corporate donors to the CCF include
Coca-Cola Coca-Cola, or Coke, is a carbonated soft drink manufactured by the Coca-Cola Company. Originally marketed as a temperance drink and intended as a patent medicine, it was invented in the late 19th century by John Stith Pemberton in Atlanta ...
,
Wendy's Wendy's is an American international fast food restaurant chain founded by Dave Thomas (1932–2002) on November 15, 1969, in Columbus, Ohio. Its headquarters moved to Dublin, Ohio, on January 29, 2006. As of December 31, 2018, Wendy's was the ...
,
Outback Steakhouse Outback Steakhouse is an American chain of Australian-themed casual dining restaurants, serving American cuisine, based in Tampa, Florida. The chain has over 1,000 locations in 23 countries throughout North and South America, Asia, and Australia ...
,
Cargill Cargill, Incorporated, is a privately held American global food corporation based in Minnetonka, Minnesota, and incorporated in Wilmington, Delaware. Founded in 1865, it is the largest privately held corporation in the United States in ter ...
, Tyson Foods, and
Pilgrim's Pride Pilgrim's Pride Corporation is an American, multi-national food company, currently one of the largest chicken producers in the United States and Puerto Rico and the second-largest chicken producer in Mexico. It exited bankruptcy in December 2009 ...
. , the CCF reported more than 1,000 individual donors as well as approximately 100 corporate supporters.


Criticism

Some of the CCF's various critics, including targets, fight back. Labor groups pushing to increase the minimum wage have taken a tough line against Berman and his clients.
The Humane Society of the United States The Humane Society of the United States (HSUS) is an American nonprofit organization that focuses on animal welfare and opposes animal-related cruelties of national scope. It uses strategies that are beyond the abilities of local organizations. ...
, has carried out its own investigations of CCF and founder Richard Berman, and filed complaints about CCF with the IRS. Together, MADD and HSUS filed a complaint against Berman and Company, Berman's firm, with the New York Commission on Public Integrity. CCF has filed its own complaint with the IRS against HSUS.
PETA Peta or PETA may refer to: Acronym * Pembela Tanah Air, a militia established by the occupying Japanese in Indonesia in 1943 * People for the Ethical Treatment of Animals, an American animal rights organization * People Eating Tasty Animals, an ...
created a website to counter the charges of Berman and CCF, calling them a "front group" which "devotes considerable manpower, time, and money in an attempt to make people who care about animals believe false and misleading information about PETA's work." Physicians Committee for Responsible Medicine has responded "If you are in the business of putting veal or beef on the tables of America, and slaughtering more than a million animals per hour, and making an awful lot of money at it, you are going to try to neutralize PETA or other animal-rights groups."
David Nibert David Alan Nibert (born 1953) is an American sociologist, author, activist and professor of sociology at Wittenberg University. He is the co-organizer of the Section on Animals and Society of the American Sociological Association. In 2005, he re ...
says that the CCF receives significant funding from businesses that make up the
animal–industrial complex The term animal–industrial complex (AIC) refers to the systematic and institutionalized exploitation of animals. It includes every economic activity involving animals, such as the food industry (e.g., meat, dairy, poultry, apiculture), anima ...
in order to conduct public relations campaigns to challenge any criticism of their practices. According to ''The Washington Post'',
Citizens for Responsibility and Ethics in Washington Citizens for Responsibility and Ethics in Washington (CREW) is a nonprofit 501(c)(3) and nonpartisan U.S. government ethics and accountability watchdog organization.''Washington Information Directory 2017-2018''; CQ Press; 2017; Pg. 327 Founded ...
(CREW), a watchdog group, asked the Internal Revenue Service in 2005 to revoke CCF's tax-exempt status, alleging that Berman and his company had used CCF to direct over $7 million charitable money to himself and his company since 1997, an allegation Berman rejects. In its complaint to the
IRS The Internal Revenue Service (IRS) is the revenue service for the United States federal government, which is responsible for collecting U.S. federal taxes and administering the Internal Revenue Code, the main body of the federal statutory tax ...
, CREW attacked CCF's claims that its advocacy campaigns were "educational" in nature. In March 2013, independent nonprofit evaluator
Charity Navigator Charity Navigator is a charity assessment organization that evaluates hundreds of thousands of charitable organizations based in the United States, operating as a free 501(c)(3) organization. It provides insights into a nonprofit’s financial s ...
issued a Donor Advisory warning potential donors that "the majority of the Center for Consumer Freedom's program expenses are being directed to its CEO Richard Berman's for-profit management company, Berman and Company." This mirrors the findings of Bloomberg News, which disclosed that from 2008 to 2010, Berman and Company was paid $15 million from donations to his five nonprofit organizations. The CCF has drawn criticism for having taken its startup funding from the
Philip Morris Phil(l)ip or Phil Morris may refer to: Companies *Altria, a conglomerate company previously known as Philip Morris Companies Inc., named after the tobacconist **Philip Morris USA, a tobacco company wholly owned by Altria Group **Philip Morris Inter ...
tobacco company and for lobbying on behalf of the
fast food Fast food is a type of mass-produced food designed for commercial resale, with a strong priority placed on speed of service. It is a commercial term, limited to food sold in a restaurant or store with frozen, preheated or precooked ingredien ...
,
meat Meat is animal flesh that is eaten as food. Humans have hunted, farmed, and scavenged animals for meat since prehistoric times. The establishment of settlements in the Neolithic Revolution allowed the domestication of animals such as chic ...
, and tobacco industries while claiming to represent consumers. Some commentators have questioned the CCF's ethics and legitimacy. A ''
USA Today ''USA Today'' (stylized in all uppercase) is an American daily middle-market newspaper and news broadcasting company. Founded by Al Neuharth on September 15, 1982, the newspaper operates from Gannett's corporate headquarters in Tysons, Virgini ...
'' journalist said that they should change the name of their website to FatForProfit.com. Michael Pollan writes in his ''
New York Times ''The New York Times'' (''the Times'', ''NYT'', or the Gray Lady) is a daily newspaper based in New York City with a worldwide readership reported in 2020 to comprise a declining 840,000 paid print subscribers, and a growing 6 million paid d ...
'' blog that the CCF is an astroturf organization that works on behalf of large food companies to protect their ability to sell junk food. It has also been criticized for its efforts to portray groups such as
The Humane Society of the United States The Humane Society of the United States (HSUS) is an American nonprofit organization that focuses on animal welfare and opposes animal-related cruelties of national scope. It uses strategies that are beyond the abilities of local organizations. ...
as "violent" and "extreme," and for its opposition to banning the use of trans fats. Jack Reilly, a former
Internal Revenue Service The Internal Revenue Service (IRS) is the revenue service for the United States federal government, which is responsible for collecting U.S. federal taxes and administering the Internal Revenue Code, the main body of the federal statutory ta ...
lawyer, told ''
The New York Times ''The New York Times'' (''the Times'', ''NYT'', or the Gray Lady) is a daily newspaper based in New York City with a worldwide readership reported in 2020 to comprise a declining 840,000 paid print subscribers, and a growing 6 million paid ...
'' that he thought the Berman nonprofits could be seen as having been established to provide business for Berman's firm, and thus were really commercial in nature. Some corporations, including
PepsiCo PepsiCo, Inc. is an American multinational food, snack, and beverage corporation headquartered in Harrison, New York, in the hamlet of Purchase. PepsiCo's business encompasses all aspects of the food and beverage market. It oversees the manuf ...
and Kraft Foods, have declined to work with the CCF, saying they disagree with some of the group's arguments or with its approach to advocacy. Following a CCF call for a retraction of a ''New York Times'' story about mercury levels in sushi as "bad science," ''
Newsweek ''Newsweek'' is an American weekly online news magazine co-owned 50 percent each by Dev Pragad, its president and CEO, and Johnathan Davis (businessman), Johnathan Davis, who has no operational role at ''Newsweek''. Founded as a weekly print m ...
'' senior editor Sharon Begley has criticized the CCF's interpretation of
Environmental Protection Agency A biophysical environment is a biotic and abiotic surrounding of an organism or population, and consequently includes the factors that have an influence in their survival, development, and evolution. A biophysical environment can vary in scale f ...
statistics and critiques of
Food and Drug Administration The United States Food and Drug Administration (FDA or US FDA) is a List of United States federal agencies, federal agency of the United States Department of Health and Human Services, Department of Health and Human Services. The FDA is respon ...
restrictions on tuna and other fish. In a document released by the ''New York Times'' on October 30, 2014, from a talk Berman gave to the Western Energy Alliance while he was unaware of being recorded, Berman described the approach of his various organizations as one of "Win Ugly or Lose Pretty." He also reassured potential donors about the concern that they might be discovered as supporters: "We run all of this stuff through nonprofit organizations that are insulated from having to disclose donors. There is total anonymity."


See also

* Center for Science in the Public Interest *
Center for Union Facts The Center for Union Facts (CUF) is an American interest group that is critical of labor unions. It is one of several advocacy and public relations groups founded by Richard Berman, whose Washington, D.C.-based public affairs firm, Berman and Comp ...
*
Employment Policies Institute The Employment Policies Institute is a fiscally conservative, non-profit American think tank that conducts and publishes research on employment issues, particularly aimed towards reducing the minimum wage. It was established in 1991 by Richard ...
* Restaurant Opportunities Center


References


External links

*
MSNBC Rachel Maddow interviews Richard Berman60 Minutes: Meet Rick Berman, A.K.A. "Dr. Evil"
* ttp://www.bermanco.com/rick-berman/ Berman and Company websitebr>investigative report on Berman and Company by HSUS
{{DEFAULTSORT:Center For Consumer Freedom Political advocacy groups in the United States Charities based in Washington, D.C. Organizations of environmentalism skeptics and critics Critics of animal rights