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PeerBasis
Compensation Comparability Determination

Clean Water Professionals

Executive Director / CEO

EIN 621450591
KY · NTEE C022
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Valerie Lucas, Executive Director / CEO ($117,329) against every comparable organization that fit the selection criteria — 729 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 94th percentile of comparable organizationsabove the 90th percentile — board review recommended

Benchmarked executive: Valerie Lucas — reported title “EXECUTIVE DI”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

729 organizations qualified on sector, size, and geography 729 within the band form the benchmarked peer set.

Distribution of comparable compensation

$284 total compensation of comparable organizations → $410,253 $117,329
$14,62910th
$37,18325th
$59,660Median
$80,32575th
$104,25490th
$117,329This org · 94th
p10$14,629
p25$37,183
p50$59,660
p75$80,325
p90$104,254
$117,329

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 KY 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
Greenscape Of Jacksonville Inc FL$325,928 Executive Di $85,000 $74,324 2024
Silvix Resources OR$325,497 Executive Dir. $37,500 $33,372 2023
Key West Garden Club Inc FL$325,395 Director $12,285 $10,742 2024
Oahu Agriculture And Conservation Assoc HI$325,224 Executive Dir. $95,881 $79,901 2024
Fossil Free California CA$327,050 Executive Dir. $79,782 $66,018 2023
Iowa Stormwater Education Partnership IA$324,644 Executive Dir. $97,999 $99,875 2024
Wildlife Ecology Institute MT$327,259 Executive Dir. $100,039 $100,372 2024
Wyoming Petroleum Foundation WY$327,364 Ex-officio Member $76,831 $76,577 2024
Utah Dine Bikeyah UT$324,369 Executive Dir. $130,000 $123,842 2024
Michigan Municipal Wetland Alliance Inc MI$324,309 Executive Director $52,008 $49,965 2024
Peconic Baykeeper Inc NY$327,883 Executive Di $123,903 $104,212 2024
Environmental Law And Policy Center IL$323,436 President & Ass't Treasurer $99,349 $93,596 2023
Carbon Offsets To Alleviate Poverty CA$323,251 Ceo $59,583 $49,303 2023
South Hero Land Trust Inc VT$328,626 Executive Director $53,479 $51,582 2023
Northern California Regional Land Trust CA$328,743 Executive Director $97,154 $76,073 2025
Northwoods Wildlife Center WI$328,808 Vice Preside $5,000 $5,626 2021
Fruitful Commons TX$329,111 Executive Director $33,046 $30,768 2024
Middlesex Land Trust CT$322,665 Executive Di $66,111 $59,400 2023
Clean Air Institute DC$322,593 Director $78,500 $66,012 2023
Life Frames Inc CA$322,566 Executive Dir. $46,170 $38,205 2023
Cement Kiln Recycling Coalition VA$322,206 Executive Director $177,030 $163,798 2023
Scenic Walton Inc FL$322,166 Executive Director $120,705 $105,544 2024
Santa Barbara Audubon Society CA$322,002 Executive Dir. $67,866 $53,140 2025
Western Rivers Forestry OR$330,485 President $56,937 $50,669 2023
Western Pa Coalition For Abandoned PA$330,871 Executive Di $73,442 $70,183 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to KY 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 KY 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 default94th
Total compensation (D + F), as reported (no adjustments)90th
Reportable pay only (column D), adjusted94th
All sources (D + E + F), adjusted91st

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 (Valerie Lucas) 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 729 similarly situated organizations (Same NTEE major group (C), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $117,329 is reasonable (approximately the 94th 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.