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PeerBasis
Compensation Comparability Determination

Natural Resources Defense Council Inc

Executive Director / CEO

EIN 132654926
NY · NTEE C300
FY ending 2023-06-30
June 9, 2026

This analysis benchmarks the total compensation of Manish Bapna, Executive Director / CEO ($739,686) against every comparable organization that fit the selection criteria — 19 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 63rd percentile of comparable organizationswithin the typical range

Benchmarked executive: Manish Bapna — reported title “PRESIDENT/CEO”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

19 organizations qualified on sector, size, and geography 19 within the band form the benchmarked peer set.

Distribution of comparable compensation

$106,963 total compensation of comparable organizations → $3,139,658 $739,686
$238,18510th
$361,70725th
$556,934Median
$854,69875th
$1,226,80290th
$739,686This org · 63rd
p10$238,185
p25$361,707
p50$556,934
p75$854,698
p90$1,226,802
$739,686

Comparable organizations

Each figure is Form 990 Part VII columns D + F (reportable pay plus other compensation and benefits; column F may include amounts from related organizations), normalized to NY cost of living (BEA RPP, 2023) and to its filing year (CPI-U); the reported amount is on each linked 990.

OrganizationStateRevenueMatched titleComp
(reported)
Comp
(adjusted)
FY
Sixteen Thirty Fund DC$181,353,252 President $196,168 $190,502 2023
National Audubon Society Inc NY$156,129,262 Chief Executive Officer $653,284 $653,284 2023
Conservation International Foundation VA$235,131,545 Chief Executive Officer $1,040,432 $1,111,723 2023
Energy Trust Of Oregon Inc OR$251,243,122 Executive Director $319,926 $319,354 2024
Vermont Energy Investment Corporation VT$130,939,426 Chief Executive Officer $413,194 $447,041 2024
🔒 14 more comparable organizations — included in the purchased report

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to NY cost of living and 2023 dollars. Click any organization to verify the figure on ProPublica.

Methodology

Comparable organizations were drawn from electronically filed IRS Form 990 returns and matched on sector (NTEE code), budget (a size-adaptive revenue band that tightens as the organization grows), and geography (same-state first, broadening only when too few peers qualify); every organization within the band forms the peer set. To compare fairly across regions and years, peer compensation is normalized to NY cost of living (BEA Regional Price Parities, 2023) and to the subject's filing year (CPI-U). The figure benchmarked is Form 990 Part VII, Section A, columns D + F — reportable pay plus other compensation, benefits, and deferred amounts (column F may include amounts from related organizations) — with the chief executive matched by role. Related-organization amounts (column E) and institutional trustees are excluded. Full methodology: peerbasis.org/methodology.

Sample, role match & sensitivity

Sensitivity — the subject's percentile under alternative compensation definitions:

BasisSubject percentile
Total compensation (D + F), cost-of-living + inflation adjusted — the PeerBasis default63rd
Total compensation (D + F), as reported (no adjustments)68th
Reportable pay only (column D), adjusted63rd
All sources (D + E + F), adjusted63rd

If the percentile moves materially across these definitions, the result is sensitive to methodology choices, and the board should weigh which basis best fits its facts.

Rebuttable presumption of reasonableness · 26 CFR 53.4958-6

Compensation paid by a tax-exempt organization is presumed reasonable — shifting the burden to the IRS — when three requirements are met. This report supplies the comparability data for the second. The board should record the following in its minutes concurrently with its decision:

Ready-to-adopt board minutes — executive compensation

🔒 The complete minutes language — three numbered resolutions pre-filled with this organization, the 19-organization comparison, the date, and the percentile finding, ready to paste into your minutes — is included in the purchased report.

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Sources: IRS Form 990 e-file data (apps.irs.gov); IRS Business Master File (NTEE classification). Every figure traces to an original public filing — click any organization above to verify it on ProPublica. PeerBasis is a service of Prismind Analytics; its methodology is published, was commissioned for independent adversarial review, and discloses its own limitations. This report is comparability data to support a board's good-faith determination under IRC 4958; it is not legal or tax advice. Generated by PeerBasis on June 9, 2026.