Live preview — download the board-ready PDF to attach to your minutes.Download the free PDF
Email yourself a copy:
PeerBasis
Compensation Comparability Determination

Gull Chain Of Lakes Association

Executive Director / CEO

EIN 411272492
MN · NTEE C32Z
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Sue Friedrichs, Executive Director / CEO ($12,619) against every comparable organization that fit the selection criteria — 60 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 13th percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Sue Friedrichs — reported title “SECRETARY/TR”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

60 organizations qualified on sector, size, and geography 60 within the band form the benchmarked peer set.

Distribution of comparable compensation

$2,072 total compensation of comparable organizations → $131,367 $12,619
$8,02610th
$43,48125th
$56,454Median
$73,90375th
$101,58890th
$12,619This org · 13th
p10$8,026
p25$43,481
p50$56,454
p75$73,903
p90$101,588
$12,619

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 MN 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
Hui O Koolaupoko HI$236,830 Project Director $36,775 $33,321 2024
Lifetides Institute SC$239,327 Vice Chair $26,500 $27,979 2024
Madison River Foundation MT$240,092 Former Executive Director $109,125 $122,561 2023
One People One Reef CA$235,610 V Chair&co-dir. $28,000 $25,192 2023
The Great Egg Harbor Watershed Association NJ$233,111 Coordinator $51,611 $48,012 2023
Chesapeake Rivers Association Inc MD$232,603 Secretary $120,000 $113,538 2024
The Beaver Coalition Inc OR$231,797 Executive Director $83,697 $78,661 2024
St Mary's River Watershed Association Inc MD$247,582 Exec. Director $47,400 $44,848 2024
Acton Wakefield Watersheds Alliance NH$248,360 Executive Di $74,862 $69,957 2024
Smithfield Irrigation Company UT$250,811 Trustee $2,000 $2,072 2024
Pudding River Watershed Council OR$250,832 Co-executive Director $62,500 $60,474 2023
Jersey Shore Partnership Foundation Inc NJ$221,167 President $75,063 $67,826 2024
Carrolls Water Association WA$256,946 Treasurer $8,269 $7,492 2024
Pokegama Lake Association MN$218,503 Secretary $2,700 $2,700 2024
Resource Protection Group Inc VA$258,063 Secretary/tr $7,500 $7,329 2024
Project O CA$216,852 President & Ceo $54,000 $48,584 2023
Beyond Our Shores Inc RI$263,786 President $73,150 $73,083 2023
Jones River Watershed Associnc MA$264,493 Exec. Dir. $60,000 $54,566 2024
Missouri Stream Team Watershed Coalition MO$265,034 Executive Director $44,883 $48,110 2024
Malama Na Apapa HI$265,256 Director $10,000 $10,983 2020
Spokane River Forum WA$208,638 Executive Dir. $46,376 $40,937 2025
Jacobs Creek Watershed Association PA$208,570 Executive Director $40,240 $41,811 2023
Friends Of Deckers Creek Inc WV$208,060 Exec. Director $41,273 $45,226 2024
Trinity Edwards Springs Protection Assoc TX$207,231 Executive Dir. $43,500 $44,037 2024
Harney County Watershed Council Inc OR$270,607 Coordinator $52,250 $50,556 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to MN cost of living and 2024 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 MN 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 default13th
Total compensation (D + F), as reported (no adjustments)13th
Reportable pay only (column D), adjusted13th
All sources (D + E + F), adjusted13th

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:

Draft board minutes — executive compensation

  1. The compensation of the Executive Director / CEO (Sue Friedrichs) was approved in advance by [the Board / Compensation Committee], composed of members with no conflict of interest with respect to the arrangement.
  2. Prior to its determination, the authorized body obtained and relied upon appropriate comparability data, namely the PeerBasis Compensation Comparability Determination dated June 9, 2026, comparing compensation against 60 similarly situated organizations (Same NTEE sector (C32), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $12,619 is reasonable (approximately the 13th percentile of comparable organizations) and documented the basis for this determination concurrently, on [date], by a vote of [__ for / __ against].

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.