The second-quarter numbers are in and people who pay attention are paying attention. It’s not the haul that’s so impressive — $866,000 is a robust figure but Romney’s PAC did more than a million in April and May alone and SarahPAC itself did better in the last half of last year than the first half of this year — but rather what she’s doing with the money. What kind of ex-governor-turned-commentator spends several hundred thousand dollars developing a direct mailing list?

One who’s keeping her options open.

The committee, SarahPAC, also spent nearly twice as much – $742,000 – as it had in any previous quarter, the lion’s share of which went to the type of list-building and fundraising (including its first major direct-mail campaign) that typically undergird top-tier political committees. It also reported its biggest-ever round of donations to candidates – $87,500 – and its highest outlays for travel costs, including $17,000 on private jet fare to crisscross the country for high-profile political speaking gigs, and speechwriting. It also showed continued payments for that speechwriting as well as foreign and domestic policy consulting, and its first ever payments to a scheduler…

But perhaps most indicative of a more traditional, robust political operation were the $330,000 in fundraising costs reflected in the report, including $154,000 to HSP Direct, a direct-mail vendor that put together SarahPAC’s first direct-mail campaign. Palin had previously used primarily online fundraising techniques, which tend to have lower overhead but cannot necessarily equal the return rate of a well-targeted but more expensive traditional direct-mail campaign. HSP’s campaign for SarahPAC, which started in earnest in April, sent glossy fundraising solicitations to more than 500,000 conservative households, asking them to help the PAC support conservative candidates in 2010, according to SarahPAC treasurer Tim Crawford.

She’s got more than a cool mil of cash on hand, inspiring GOP consultant Ron Bonjean to say, “All signs point to her running for president in 2012 with that kind of money.” She also spread a lot more money around among Republican candidates this quarter than last — a nine-fold increase, in fact, with hefty $5,000 contributions going to Terry Branstad and Chuck Grassley. Say, why’s she dumping that kind of money on a guy like Grassley who’s reviled as a RINO in many quarters? Oh, right — because he’s from Iowa, silly. More from Hotline:

What’s most notable is the number of small contributors Palin has attracted. More than 3/4 of her donations are listed as unitemized, meaning the individuals who wrote checks sent in less than $200. Much of Pres. Obama’s fundraising success in ’08 came from these small-dollar donors, meaning Palin has a grassroots folllowing — one she’s started to build significantly earlier than Obama did.

Big bucks from small donors will be more important to Palin than it was to Obama since she’ll be cold-shouldered by plenty of establishment Republicans in the primary and she knows it. Presumably that’s what the direct-mail operation is about — building a huge base of grassroots contributors as quickly as possible to convince wealthy conservatives not to be too hasty in backing Romney or Gingrich or whoever. If she can put together a huge list by the end of the year, it’ll prove not only that she has the resources to make a sustained run but that there’s enough rank-and-file support to make her the early favorite in Iowa and South Carolina. The idea of Palin as grassroots hero also plays perfectly into the media’s narrative of her as some sort of populist Bircher siren, so if she comes up with a gigantic small-donor number in the next quarter, they’ll be only too happy to broadcast it for her.

The only question: Is she running? Marc Ambinder‘s not so sure:

1. She hasn’t been recruiting fundraisers, or staff members, or activists. Her inner circle could fit in a Federation runabout. A successful presidential candidate needs fundraisers, staffers, and activists. Then again, Barack Obama had almost no one manning his presidential aspirations at this point in 2006 even as his opponents prepared conventional campaigns. While Mitt Romney makes strategic endorsements in every state and Tim Pawlenty has created PACs to help candidates in Iowa and New Hampshire, Palin is not establishing the relationships she would need to establish in order to build political campaigns in these early states. That means that she might be attempting a different type of campaign, or that she has been given bad advice, or that she won’t run at all.

2. She hasn’t been extending her brand. Republicans believe that Palin lacks the substantive chops to be president. This is not a creation of the lamestream media, even though the media’s 2008 coverage may have amplified those doubts. Palin’s friends who regularly Tweet about her doings seem to dismiss these complaints (that she isn’t smart enough, isn’t ready, isn’t developing policy chops) as stupid and uninformed. That said, given that independents’ central issue with Obama will be his failure to fix the economy, it is significant that other Republican presidential aspirants are preparing to run on competence — and Palin is not.

I think she’s still undecided and keeping her options open, but clearly a “different type of campaign” is what’s in store if she does run. Her staff will probably remain as small as possible in order to cultivate the whole anti-establishment “one of us” common touch that the grassroots admires. As for point two, here’s John Ellis, a.k.a. Jeb Bush’s cousin:

“She’s too stupid” is what the Establishment GOP really thinks about Sarah Palin. “Good-looking,” but a “ditz.” This is unfertile ground, since Palin can turn the argument on a dime and say: “They drive the country into bankruptcy, they underwrite Fannie and Freddie, they bail out Goldman Sachs, they fight wars they don’t want to win, they say enforcing the immigration laws is silly and they call me stupid! I’ll give you a choice: you can have their smarts or my stupidity, which one do you want?” A large number of GOP presidential primary voters will take Palin’s “stupidity” in a heartbeat.

Ellis’s prediction? The growing threat from Palin will lead establishment Republicans to turn to, er, Jeb Bush. Which isn’t that crazy: It might not ultimately be Jeb, but as a wise man once said, if she runs it will ultimately be a Palin vs. anti-Palin race. Exit question: Is this happening?