Unelected Power — The Weber County Hive · UP 400.01
Community Alliance for Main Street (CAMS) runs Heber City's downtown revitalization work under a sole-source contract negotiated, approved, and signed for the City by a man who also sits on CAMS's own board. What the arrangement is supposed to buy, who actually pays for it, and what still isn't accounted for.
Cities partnering with an independent nonprofit to run downtown revitalization work is a well-established, nationwide model — not, by itself, a red flag.
Utah's own state Main Street Program, run through the State Historic Preservation Office, follows the same national framework used in over 1,200 communities across 40 states: a professionally managed downtown organization, "whether that entity is housed with a city or county, or is a stand-alone nonprofit," typically sustained by modest local government support alongside sponsorships and grants. CAMS holds Tier 2 accreditation in that statewide network.
So the basic shape of this arrangement — a city funds a nonprofit that handles beautification, downtown events, and business support — is ordinary. What follows is not a case against that model. It's an account of how this particular version of it was built and run.
CAMS's own materials answer the natural follow-up question directly: if local government already exists, why does a Main Street need its own nonprofit at all? Its stated answer is that city government manages a broad range of responsibilities and can lack a group focused specifically on a niche like a single downtown corridor. CAMS describes itself as filling that gap — not replicating the City's work, but complementing it, acting as a dedicated "specialist team" for Main Street's specific needs.
Pulled directly from CAMS's own website and public materials — its stated deliverables, in its own words:
CAMS's own website lists Kahler under a page header reading "Here are just a few of the individuals who volunteer at CAMS," alongside three actual unpaid board members. Her Executive Director role is CAMS's one paid, City-funded position — describing it as volunteer service alongside genuine volunteers is a factual mismatch worth noting plainly, not a claim about anyone's intent.
Separately, CAMS's own January 2024 blog post names "Policy Influence" — engaging directly with local policymakers — as one of its four core activities. That claim predates CAMS's 501(c)(3) conversion by roughly two years, and sits in tension with the federal political-activity restrictions that came with it. See "A nonprofit that describes its own advocacy," below.
CAMS's own materials state it does not collect membership dues from Main Street businesses. The actual cost structure runs through the City's general tax base instead:
Set against the deliverables list above — planters, murals, seasonal events, a modest annual calendar — the City funds nearly all of CAMS's cost of doing business while CAMS retains the revenue those same taxpayer-funded events generate. The City's own fiscal justification for the HMOM split says as much directly: staff wrote that the arrangement "should provide the City with a net increase in revenue as only a fraction of the weekly sponsorship[s] were sold in previous years" — meaning the City had been leaving that money on the table itself before handing the relationship to CAMS.
CAMS's own history page describes a continuous, 22-year organization. The state's own corporate filings tell a different story.
Counted from the actual legal filings — not the informal founding story — the entity that signed the City's current contract is seven years old, not twenty-two, and its predecessor spent more of its existence dissolved than active.
On that same state filing, every director's address of record is a personal or business address — except one. Matt Brower's listed director address is 75 N Main St, Heber City: Heber City's own City Hall. The City Manager's board seat at an independent nonprofit is registered, on the state's own record, at the government building itself.
Three independently-sourced records of who sits on CAMS's board — and none of them agree:
| Source | Directors listed |
|---|---|
| Utah Division of Corporations (state filing, updated 9/19/2024) | Koecher, Bradshaw, Brower, Stone, Ferguson — 5 |
| Heber City's own Jan./April 2026 staff reports | Stone, Brower, Koecher, Bradshaw, Fritzsche, Berg, Rowland, Ferguson — 8 |
| CAMS's own public "About" page (published 4/22/2026) | Stone, Koecher, Rosendahl, Bradshaw, Rowland, Berg — 6, plus Kahler as staff |
The state's own official record — the legally operative account of who actually directs this corporation — is missing three of the eight people everyone else treats as sitting board members: Ryan Fritzsche, Kelsey Berg, and Erik Rowland. Utah law (§16-6a-1607) requires nonprofits to file an annual report naming current directors, but the only consequence for missing or outdated filings is the same delinquency/dissolution mechanism already documented on this page — the law doesn't require this filing to match what a city reports or what the organization's own website says, so a three-way mismatch like this one isn't something the statute is built to catch. That makes this a real caveat, not a reason to set the discrepancy aside: state nonprofit filings only update when a renewal is filed, so this could reflect an administrative lag rather than proof those three were never properly added. Per Heber City's own staff reports, current voting members are: Tom Stone (Chair), Matt Brower, Dallin Koecher, Jeff Bradshaw (Treasurer), Ryan Fritzsche, Kelsey Berg, Erik Rowland, and Nicole Ferguson. Executive Director Rachel Kahler is staff, not a board member.
City Manager
Matt Brower
Board member since 2019. Sole city signatory on the CAMS contract; authored the staff report recommending it; approved it as a CAMS board member a week before the City Council vote. Full profile →
Heber Valley Chamber/CVB Exec. Director
Dallin Koecher
Also on the Wasatch Open Lands Board; his posted WOLB disclosure lists only his Chamber role, omitting CAMS. Full profile →
Chair / President
Tom Stone
Heber resident since 1986; co-founded CAMS with Bradshaw. Disqualified from a 2024 school board race over a late disclosure; that suit was dismissed against him.
Treasurer
Jeff Bradshaw
Co-founded CAMS with Stone; registered agent on its original, later-dissolved 2005 entity. A practicing CPA and partner at his own firm, Bradshaw Smith & Co, since 1974. CAMS's federal tax filing is filed under his name, from his firm's own office.
Board Member
Ryan Fritzsche
Owner of a Heber City payment-processing company (MSS Pay). Runs a business address on the same Main Street corridor as CAMS's own PSA notice address.
Board Member
Kelsey Berg
Government Relations lead for the Utah 2034 Olympic Organizing Committee; previously VP of Government Relations at the Larry H. Miller Company.
Wasatch Co. Council, Seat C
Erik Rowland
Filed a blanket "no conflict of interest" county disclosure covering eight documented positions and entities, CAMS among them.
Board Member
Nicole Ferguson
Main Street furniture-store owner; has publicly described Main Street as effectively unwalkable — the exact problem CAMS's own mission targets.
Executive Director (staff)
Rachel Kahler
Former Heber City Council Member. CAMS's Utah nonprofit filing status shows "Delinquent"; her 2026 county disclosure has an unresolved gap.
The City's Professional Services Agreement with CAMS runs Jan. 1, 2026 through Dec. 31, 2028, auto-renewing annually, awarded through sole-source procurement rather than competitive bidding. The staff report's stated justification: CAMS's history, its downtown relationships, and the cost/time of transitioning to a new vendor.
The agreement was re-noticed as sole-source with 10 days' legal notice after a complaint to the Utah State Auditor. Out of what staff called "an abundance of caution," the City solicited comparison quotes from two Park City-based nonprofits — both of which indicated the work would cost significantly more than CAMS's $39,900.
The signed agreement recites that the City "caused this Agreement to be signed by its mayor and attested by its city recorder." The actual signature block contains only one line — Matt Brower, City Manager. No Mayor's signature, no Recorder attestation. The same person negotiated the deal, approved it as a CAMS board member, authored the staff report recommending it, and is its sole named city signatory.
CAMS's own bylaws separately require formal Board approval of any "self-dealing transaction." Whether the City contract was ever reviewed under that provision is not established in any document obtained so far.
Three CAMS-originated documents describe the same 2024 fiscal year with three different totals:
| Source | 2024 figure |
|---|---|
| Form 990-EZ, Line L ("gross receipts") | $193,966 |
| Schedule A, Part III ("public support") | $191,115 |
| CAMS's own internal balance sheet (total income) | ~$387,933 |
The first two are close enough to plausibly reconcile through ordinary accounting differences. The third is not — it's roughly double either federal figure, on the same year, from CAMS's own books.
CAMS's Form 990-EZ is filed "% Jeffery M. Bradshaw," using the address and phone number of Bradshaw Smith & Co — Bradshaw's own private CPA practice, not a CAMS office. He's held the Treasurer role since co-founding the organization. That means CAMS's federal financial reporting runs through one board member's own accounting firm, which makes the three-figure discrepancy above a narrower, more answerable question than it might otherwise be: the person best positioned to reconcile it is already on the board.
Separately, 2024 spending was dominated almost entirely by a single line: $347,465.54 for "Main Street Beautification," about 90% of that year's budget, with no itemization available anywhere public and no board minutes on file for the year it occurred. The following year, that same line fell roughly 99%, while total income fell roughly 73% — a pattern that reads as a single large, unexplained project rather than routine year-to-year spending.
CAMS's January 2024 blog post, "CAMS Advocacy Initiatives," states plainly: "Advocacy is at the core of our mission... engag[ing] in dialogues with local policymakers to influence decisions impacting Main Street." That post predates CAMS's 501(c)(3) conversion, which took effect Nov. 22, 2024 — meaning it describes CAMS's own self-understanding as an advocacy organization from before, not after, its current tax status began.
The rule CAMS is required to follow right now, as of Nov. 22, 2024, is the 501(c)(3) standard — not the looser rules that applied to the 501(c)(6) classification it says it held before. Specifically: lobbying cannot be a "substantial part" of its activities (the IRS has never set an exact percentage, but a 1955 court case treated roughly 5% of an organization's time and effort as the outer edge of "insubstantial"), and it is absolutely barred from supporting or opposing any candidate or political party, in any form. A 501(c)(6) business league — what CAMS says it operated as for most of its earlier history — was never subject to either of those restrictions in the same way. Violating them can cost an organization its tax-exempt status outright.
So the plain answer to "are they allowed to do politics": no campaign involvement of any kind, ever, under their current status — and only a small, non-dominant amount of legislative lobbying. What isn't established by anything in hand is whether CAMS's "Policy Influence" activity continued, unchanged, after Nov. 22, 2024 took effect. The Jan. 2024 post shows what CAMS considered its own mission before the conversion; it doesn't show what it's actually done since.
This scorecard measures oversight and accountability — whether the public can see, question, and check this arrangement. It does not measure whether the flowers get planted or the events happen. Nothing in the record reviewed here suggests CAMS's actual programming has failed; the deliverables list above is real. What follows is a separate question: is anyone positioned to catch it if something goes wrong?
Net score: −14 of a possible +21 — verdict: structurally compromised
| Dimension | Net | Why |
|---|---|---|
| Transparency | −3 | Three unreconciled revenue totals for the same year; no public board minutes despite a bylaws requirement; a $347,465.54 expense with no itemization anywhere public. |
| Conflicts of interest | −3 | One person — the City Manager — sits on both sides of the transaction: board member, contract negotiator, staff-report author, and sole city signatory. |
| Appointment accountability | −2 | CAMS's own public board list conflicts with the City's staff report from one day earlier, with three names dropped and one added, unexplained. |
| Public participation | −2 | No evidence of public comment or posted agendas at CAMS's own board level; the only public input on record happened at City Council, not at CAMS. |
| Structural independence | −2 | The City provides police, insurance, marketing, and storage, negotiates through a sitting board member, and CAMS's Executive Director is a former City Council Member. |
| Compliance / enforcement | −3 | The active entity was listed as delinquent with the state when checked (this may have changed) while holding an active public contract, with no evidence of any consequence. |
| Mandate specificity | +1 | Bylaws and contract both define CAMS's scope, services, and payment terms in specific, checkable language. |
Scored against the same seven-dimension rubric used for the Prosecutor Conduct Commission and other appointed Utah bodies. Design and outcome are graded separately in this project's methodology — a structure can be run this way and still produce acceptable results, or the reverse. This score addresses the structure only.
None of this requires CAMS to stop existing or the City to stop funding downtown work. Most Main Street organizations nationally operate with the following as baseline practice — the gap here is between that baseline and what's currently documented, not between CAMS and some impossible standard.
Every gap on this page has a body that's nominally responsible for catching it. Laid out plainly, most of those checks turn out to be reactive, self-reported, or triggered only by someone filing a complaint — not routine verification.
| What needs checking | Who's nominally responsible | Grade | What that means in practice |
|---|---|---|---|
| Corporate good standing | Utah Division of Corporations | D | Enforcement is automatic and slow — a missed renewal shows as "Delinquent" and eventually triggers administrative dissolution if never fixed, the same as CAMS's own 2005 entity. No one there reviews governance, finances, or contracts; it's a renewal-fee system, not an oversight body. |
| Whether CAMS's books match what it reports | No one, at this size | F | Utah imposes no independent-audit requirement for nonprofits at any revenue level — state law (§16-6a-1607, §13-22-15) only requires filing a copy of the same federal return already sent to the IRS. CAMS's 990-EZ, filed under its own Treasurer's name from his own accounting firm, is not independently verified by anyone before or after filing. |
| Federal 501(c)(3) compliance | IRS | D | Oversight exists but is complaint- or audit-driven; the IRS does not routinely monitor a small nonprofit's day-to-day spending or verify individual expense lines like the 2024 Beautification total. |
| Charitable solicitation registration | Utah Division of Consumer Protection | D | Required under §13-22-6 for nonprofits soliciting public donations — not yet confirmed whether CAMS is registered; a separate, checkable open item. |
| Sole-source procurement compliance | Heber City itself | F | The City both grants and reviews its own procurement exception. The only outside check that occurred here was a complaint filed with the Utah State Auditor — reactive, not routine. |
| The City Manager's outside board seats | Heber City Council | F | The Council hires, sets contract terms for, and can terminate the City Manager for cause — but the same Council approved the sole-source CAMS contract 5-0 the same night its own minutes recorded "no conflicts disclosed." No state body independently reviews a city manager's outside nonprofit roles. |
| CAMS deals that benefit its own board members (what its bylaws call “self-dealing”) | CAMS's own Board | F | The bylaws require the Board to approve any “self-dealing” transaction (the bylaws' term) — but the Board approving a deal that benefits one of its own members is self-review, not independent review, and whether this provision was ever formally invoked here is unconfirmed. |
Overall oversight grade: D−
Not a flat F, because the pieces of a real oversight system technically exist on paper — a corporate registry, an IRS enforcement power, a Council with hire/fire authority, bylaws with a “self-dealing” clause. The grade is this low because every one of them is either reactive (waits for a complaint), automatic-but-toothless (a renewal deadline), or the same party reviewing itself. Nothing in this structure catches a problem before it becomes public — every finding on this page came from an outside person reading the documents, not from any of these mechanisms working as designed.
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