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PeerBasis
Compensation Comparability Determination

Western Growers Foundation

Executive Director / CEO

EIN 931201791
CA · NTEE K20
FY ending 2023-06-30
June 9, 2026

This analysis benchmarks the total compensation of David Puglia, Executive Director / CEO ($51,830) against every comparable organization that fit the selection criteria — 45 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 62nd percentile of comparable organizationswithin the typical range

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

How comparable organizations were selected

45 organizations qualified on sector, size, and geography 45 within the band form the benchmarked peer set.

Distribution of comparable compensation

$60 total compensation of comparable organizations → $131,081 $51,830
$3,72010th
$18,58525th
$40,795Median
$63,42475th
$83,38290th
$51,830This org · 62nd
p10$3,720
p25$18,585
p50$40,795
p75$63,424
p90$83,382
$51,830

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 CA 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
Bionutrient Food Association Inc MA$191,809 Executive Di $61,890 $62,559 2024
Honore Farm And Mill CA$203,746 Executive Director $49,087 $49,087 2023
Grower-shipper Association Foundation CA$185,507 Executive Director $83,820 $83,820 2023
Georgia Minority Outreach GA$211,029 Program Mana $49,820 $58,012 2023
Oklahoma Wheat Research Foundation Inc OK$180,818 Sec/treasurer $10,000 $12,067 2025
Kindness Farm OR$213,995 President $38,961 $41,901 2023
Lewis Educational Agricultural Farm CT$217,126 Executive Director $17,900 $19,436 2023
Lee County Fair Association IL$217,716 Secretary $3,900 $4,201 2025
Iglesias Gardens Co PA$218,244 Board Member $5,950 $6,674 2024
The Village Agricultural Cooperative MN$219,056 Ceo $60,385 $69,099 2023
Project Alianza Inc MA$220,721 Executive Director $88,400 $89,356 2024
Gathering Ground Inc WI$222,314 Board Member $16,000 $18,796 2024
Foothills Farmers Market NC$222,743 Market Manag $37,760 $43,888 2024
Fauquier Education Farm Inc VA$168,827 Executive Director $74,180 $80,567 2024
0brien County Livestock Show IA$165,697 Secretary $2,160 $2,660 2024
Proctor Farmers Market WA$227,086 Market Manager $68,948 $69,437 2024
Paicines Ranch Learning Center CA$228,466 Director/board $82,725 $82,725 2023
Save Family Farming WA$229,935 Executive Director (Starting May 2024) $86,548 $87,161 2024
Oregon Ag Fest Inc OR$234,516 Executive Di $48,000 $51,622 2023
Jefferson Growers Artisans And Prod WV$154,971 Executive Director $15,514 $18,895 2024
Patrons Of Husbandry Maine State Grange ME$151,737 Master $16,500 $18,585 2024
Texas Farmers Union Inc TX$149,966 President $35,807 $41,480 2023
Farm & Community Collaborative Inc MA$243,008 Director $20,833 $21,680 2023
Malibu Agricultural Project's Cornucopia Farms CA$245,656 President $69,785 $67,783 2024
Giving Gardens Of Indiana Inc IN$245,726 Executive Di $31,800 $37,722 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to CA 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 CA 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 default62nd
Total compensation (D + F), as reported (no adjustments)71st
Reportable pay only (column D), adjusted0th
All sources (D + E + F), adjusted100th

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 (David Puglia) 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 45 similarly situated organizations (Same NTEE sector (K20), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $51,830 is reasonable (approximately the 62nd 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.