Millions in Federal Study Funds Follow a Well-Worn Lobbying Path
A federal grant cycle linking municipal lobbying retainers to infrastructure study contracts operates largely outside public view, with a 2025 White House executive order now putting the whole...
The single most documented fact in the public record about how infrastructure studies get funded is this: federal law under 31 U.S.C. § 1352 explicitly prohibits grantees from using appropriated funds to lobby Congress or federal agencies for more grants — yet a White House Executive Order issued in August 2025 found it necessary to direct federal agencies to investigate exactly that practice, characterizing identified grants as carrying 'highly political overtones' and describing grant-funded lobbying as 'wasteful, abusive, and potentially fraudulent.' That an executive order was deemed necessary in 2025 is itself a public record admission that the prohibition has not been self-enforcing.
The structural architecture of the problem is traceable through open sources. Federal appropriations flow to municipalities and grantee organizations. A portion of those funds — or local budget dollars freed up by the federal inflow — pays retainers to municipal lobbying firms. Those firms, as described in promotional materials published by the registered lobbying service LobbyIt (lobbyit.com), explicitly market their ability to 'influence legislation' and secure grant access for 'towns, cities, and municipalities.' The lobbying produces larger or more favorable grant awards. Those awards then fund infrastructure feasibility studies contracted to private consulting and engineering firms. Those firms, in turn, contribute to campaigns and fund further lobbying. The loop repeats. The Center for American Progress documented that total federal lobbying expenditure reached $3.2 billion in 2013 alone, with large businesses and their associations constituting the largest share — a figure that, by CAP's own analysis, understates the true total due to disclosure gaps.
The infrastructure study contract is the critical and least-scrutinized node in this chain. When a municipality secures a federal grant for an infrastructure project — whether a water system overhaul, a highway corridor study, or, as has been publicly reported in Los Angeles, a multi-million-dollar feasibility study examining the removal of the Interstate 10 freeway — the grant award itself is only the beginning of the money trail. The study contract that follows is awarded by the municipality using those grant dollars, through procurement processes that vary by jurisdiction and are not centrally disclosed in any single federal database. Whether those contracts are awarded through competitive bidding or through sole-source arrangements, and whether the firms receiving them have financial relationships with the officials authorizing them, is information that exists in public procurement records but is rarely aggregated for public analysis.
The legal framework governing when this cycle crosses from permissible advocacy into prohibited lobbying contains a documented gray zone. The Alliance for Justice, in its published guidance document 'Grants and Lobbying — What Funders Need Grantees to Know' (afj.org, January 2024), distinguishes between direct lobbying — contacting legislators on specific legislation, which is restricted with federal funds — and other forms of policy engagement that may be permissible. Municipalities and their consultants operate within this ambiguity. The OMB Uniform Guidance at 2 C.F.R. § 200.450 explicitly prohibits lobbying costs as allowable grant expenditures, and violations can trigger civil penalties of $10,000 to $100,000 per incident under 31 U.S.C. § 1352, with potential False Claims Act exposure for false compliance certifications. Enforcement, however, rests with the Inspectors General of individual grant-making agencies — bodies that are themselves subject to political appointment pressures.
The August 2025 Executive Order, published on whitehouse.gov under the title 'Use of Appropriated Funds for Illegal Lobbying and Partisan Political Activity by Federal Grantees,' directs federal funding reviews across grant-making agencies. Its practical consequence, if enforced, would fall asymmetrically: large cities with independent budget capacity for federal relations operations would be less exposed than smaller municipalities that rely on the flexibility of grant fund accounting to pay lobbying retainers. That asymmetry is not a bug in the enforcement mechanism — it is a structural feature that favors well-resourced governments over less-resourced ones, regardless of which party controls either level of government.
The campaign finance dimension of this cycle is traceable, imperfectly, through OpenSecrets (opensecrets.org), the merged database of the Center for Responsive Politics and the National Institute on Money in Politics. Engineering and infrastructure consulting firms organized under industry PACs make contributions to members of the Senate Appropriations Subcommittee on Transportation, Housing and Urban Development and its House counterpart — the precise bodies that municipal lobbying firms, per LobbyIt's own published marketing, target on behalf of their municipal clients. Cross-referencing infrastructure industry PAC contributions against committee membership and against grant appropriations votes is a traceable analytical pathway that has not, in the case of any specific freeway removal or comparable urban infrastructure study, been fully executed in public reporting. The 2012 federal election cycle cost $6.3 billion, with 0.02 percent of the U.S. population accounting for contributions of $2,600 or more, according to CAP's analysis of that cycle — a concentration of donor influence that the UIC John Marshall Law Review, in a 2018 article citing the Bipartisan Policy Center's analysis of campaign financing trends from 1980 to 2016, characterized as a structural shift toward fewer donors giving larger amounts, amplifying the leverage of organized industry money over appropriations outcomes.
What remains hidden is substantial and specific. No public database currently aggregates, for any given infrastructure study contract, the following connected facts: the federal grant source and award amount from USASpending.gov; the lobbying firm retained by the recipient municipality and the fees paid, as disclosed in Senate Lobbying Disclosure Act filings at lda.senate.gov; the campaign contributions made by that lobbying firm's principals or by the infrastructure consulting firm that received the study contract, as recorded at OpenSecrets; and the procurement method — competitive or sole-source — used to award the study contract, which would appear in state or municipal procurement databases. Assembling that complete chain for any single infrastructure study would require, at minimum, a targeted USASpending.gov grant query by recipient municipality, a SAM.gov contractor search, a Senate LDA filing review, an OpenSecrets contribution search filtered by infrastructure industry and relevant committee members, and a Freedom of Information Act request to the grant-making agency for subgrant and subcontract disclosure records. Until that chain is assembled and published for specific projects, the public is evaluating expenditures of public dollars without the documentary record necessary to assess whether the outcomes reflect competitive merit or politically mediated access.