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This file contains:
From Higby to Strachan RE: attached information for Magruder. 1 pg. [Subject: Campaign] [Memo], no date
From Strachan to Haldeman RE: information from Chotiner on Louie Nunn and the Kentucky Senate race. 1 pg. [Subject: Campaign] [Memo], 3/29/1972
From Chotiner to Haldeman RE: the filing deadline for the Kentucky Senate race. 1 pg. [Subject: Campaign] [Memo], 3/27/1972
From Chotiner to Haldeman RE: Nunn's disappointment that RN had not endorsed him for the position of Kentucky Senator by early 1972. 1 pg. [Subject: Campaign] [Memo], 3/24/1972
From Magruder to Mitchell RE: the use of telephone operations in the 1972 elections. 4 pgs. [Subject: Campaign] [Memo], 3/15/1972
From Patricia Hutar to the Attorney General RE: a Steering Committee to direct volunteers in the campaign. 2 pgs. [Subject: Campaign] [Memo], 2/17/1972
Press release from the California Committee to Re-Elect the President naming Governor Ronald Reagan as its chair. 2 pgs. [Subject: Campaign] [Other Document], 2/4/1972
Governor Reagan's remarks at a press conference wherein he revealed his role as California CRP chairman. 2 pgs. [Subject: Campaign] [Other Document], 2/4/1972
Committee for the Re-election of the President news release on its advertising task force, the November Group. 2 pgs. [Subject: Campaign] [Other Document], no date
From Hugh W. Sloan, Jr. to Strachan RE: attached information on David K. Wilson. 1 pg. [Subject: Campaign] [Memo], 3/27/1972
From Hugh W. Sloan, Jr. to Strachan RE: a large campaign contribution from Wilson and his family. 1 pg. [Subject: Campaign] [Letter], 11/16/1971
Article titled "Republicans Woo Youth for Nixon" written by Ann Blackman. 1 pg. [Subject: Campaign] [Newsletter], no date
From Haldeman to Magruder RE: the role of youth workers in the New Hampshire primary. 1 pg. [Subject: Campaign] [Memo], 3/10/1972
Sixteenth page of a memo discussing campaign contributions, RN's poll numbers in the midwest, and youth organizations in the campaign. 1 pg. [Subject: Campaign] [Memo], no date
From Magruder to Haldeman RE: attached information on Florida campaign topics. 1 pg. [Subject: Campaign] [Memo], 3/24/1972
From Morgan to Marik RE: political mass mailings and volunteers in the Florida campaign. Charts and graphs showing correlations between the two included. 25 pgs. [Subject: Campaign] [Memo], 3/20/1972
From Magruder to the Attorney General RE: the use of Arthur C. Nielson, Sr. and his television rating company to determine past voter habits. 2 pgs. [Subject: Campaign] [Memo], 2/24/1972
From Magruder to Mitchell RE: RN's domestic policies with regard to the campaign. 1 pg. [Subject: Campaign] [Memo], 3/13/1972
From "Van" to Gordon RE: an attached statement authored by Bob Dole. 1 pg. [Subject: Campaign] [Memo], no date
News release of a statement made by Dole RE: the results of the New Hampshire presidential primary. 1 pg. [Subject: Campaign] [Report], 3/8/1972
Handwritten notes relating to a meeting on the campaign. 1 pg. [Subject: Campaign] [Other Document], 3/1/1972
Handwritten notes detailing a policy issues meeting. 4 pgs. [Subject: Campaign] [Other Document], 2/23/1972
Handwritten notes documenting the death of the son of John Rollins. 1 pg. [Subject: Campaign] [Other Document], no date
From Magruder to Colson RE: veterans in the New Hampshire primary and the 1972 campaign as a whole. 1 pg. [Subject: Campaign] [Memo], 3/23/1972
From Clayton Yeutter, through Magruder, to Mitchell RE: support for RN from Ohio Congressmen. 1 pg. [Subject: Campaign] [Memo], 3/10/1972
Handwritten notes covering various campaign topics, including a Democratic telethon and a Wisconsin telephone study. 1 pg. [Subject: Campaign] [Other Document], 3/20/1972
From Magruder to Mitchell RE: the use of Jimmy Hoffa, Jr. in the Michigan campaign.1 pg. [Subject: Campaign] [Memo], 3/24/1972
From Stans to the Vice President RE: committing to various campaign speaking engagements. Handwritten notes added by unknown. 1 pg. [Subject: Campaign] [Memo], 3/20/1972
Handwritten notes detailing information from Malek with regard to topics such as relations between the White House and the CRP, contact with state chairmen, and campaign advertising. 1 pg. [Subject: Campaign] [Other Document], no date
From Magruder to the Attorney General RE: notes from a meeting with W. Ernst Minor on campaign spokesmen. 2 pgs. [Subject: Campaign] [Memo], 2/16/1972
From Herbert L. Porter to Magruder RE: surrogate candidates. 1 pg. [Subject: Campaign] [Memo], 3/24/1972
From Magruder to Mitchell RE: Theadore White's request for a meeting. 1 pg. [Subject: Campaign] [Memo], 3/23/1972
From Magruder to Mitchell RE: the results of a mock primary at the University of Wisconsin at Whitewater 1 pg. [Subject: Campaign] [Memo], 3/23/1972
From Rietz to Magruder and Malek RE: RN's victory in a mock primary at the University of Wisconsin at Whitewater. 1 pg. [Subject: Campaign] [Memo], 3/22/1972
From Magruder to Mitchell RE: the Sheraton Corporation's desire to run an ad in the Republican National Convention program book. 1 pg. [Subject: Campaign] [Memo], 3/22/1972
From Magurder to Haldeman RE: an attached memo from Bill Novelli. 1 pg. [Subject: Campaign] [Memo], 3/24/1972
From Bill Novelli to Alex Armendaris, Paul Jones, Rietz, Dan Todd, and Clayton Yeutter RE: developing campaign advertising targeted to specific voter demographics. 4 pgs. [Subject: Campaign] [Memo], 3/16/1972
From Magruder to Mitchell RE: a new campaign spending law. Material from the House of Representatives and the Federal Communications Commission on the law attached. 38 pgs. [Subject: Campaign] [Memo], 3/24/1972
Scholar Source Context
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26145956
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WHSF: Contested, 30-5
core
doc
dtoType
document
citationUrl
pageCount
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Source metadata
id
26145956
sourceUrl
contentType
document
title
WHSF: Contested, 30-5
description
This file contains:
From Higby to Strachan RE: attached information for Magruder. 1 pg. [Subject: Campaign] [Memo], no date
From Strachan to Haldeman RE: information from Chotiner on Louie Nunn and the Kentucky Senate race. 1 pg. [Subject: Campaign] [Memo], 3/29/1972
From Chotiner to Haldeman RE: the filing deadline for the Kentucky Senate race. 1 pg. [Subject: Campaign] [Memo], 3/27/1972
From Chotiner to Haldeman RE: Nunn's disappointment that RN had not endorsed him for the position of Kentucky Senator by early 1972. 1 pg. [Subject: Campaign] [Memo], 3/24/1972
From Magruder to Mitchell RE: the use of telephone operations in the 1972 elections. 4 pgs. [Subject: Campaign] [Memo], 3/15/1972
From Patricia Hutar to the Attorney General RE: a Steering Committee to direct volunteers in the campaign. 2 pgs. [Subject: Campaign] [Memo], 2/17/1972
Press release from the California Committee to Re-Elect the President naming Governor Ronald Reagan as its chair. 2 pgs. [Subject: Campaign] [Other Document], 2/4/1972
Governor Reagan's remarks at a press conference wherein he revealed his role as California CRP chairman. 2 pgs. [Subject: Campaign] [Other Document], 2/4/1972
Committee for the Re-election of the President news release on its advertising task force, the November Group. 2 pgs. [Subject: Campaign] [Other Document], no date
From Hugh W. Sloan, Jr. to Strachan RE: attached information on David K. Wilson. 1 pg. [Subject: Campaign] [Memo], 3/27/1972
From Hugh W. Sloan, Jr. to Strachan RE: a large campaign contribution from Wilson and his family. 1 pg. [Subject: Campaign] [Letter], 11/16/1971
Article titled "Republicans Woo Youth for Nixon" written by Ann Blackman. 1 pg. [Subject: Campaign] [Newsletter], no date
From Haldeman to Magruder RE: the role of youth workers in the New Hampshire primary. 1 pg. [Subject: Campaign] [Memo], 3/10/1972
Sixteenth page of a memo discussing campaign contributions, RN's poll numbers in the midwest, and youth organizations in the campaign. 1 pg. [Subject: Campaign] [Memo], no date
From Magruder to Haldeman RE: attached information on Florida campaign topics. 1 pg. [Subject: Campaign] [Memo], 3/24/1972
From Morgan to Marik RE: political mass mailings and volunteers in the Florida campaign. Charts and graphs showing correlations between the two included. 25 pgs. [Subject: Campaign] [Memo], 3/20/1972
From Magruder to the Attorney General RE: the use of Arthur C. Nielson, Sr. and his television rating company to determine past voter habits. 2 pgs. [Subject: Campaign] [Memo], 2/24/1972
From Magruder to Mitchell RE: RN's domestic policies with regard to the campaign. 1 pg. [Subject: Campaign] [Memo], 3/13/1972
From "Van" to Gordon RE: an attached statement authored by Bob Dole. 1 pg. [Subject: Campaign] [Memo], no date
News release of a statement made by Dole RE: the results of the New Hampshire presidential primary. 1 pg. [Subject: Campaign] [Report], 3/8/1972
Handwritten notes relating to a meeting on the campaign. 1 pg. [Subject: Campaign] [Other Document], 3/1/1972
Handwritten notes detailing a policy issues meeting. 4 pgs. [Subject: Campaign] [Other Document], 2/23/1972
Handwritten notes documenting the death of the son of John Rollins. 1 pg. [Subject: Campaign] [Other Document], no date
From Magruder to Colson RE: veterans in the New Hampshire primary and the 1972 campaign as a whole. 1 pg. [Subject: Campaign] [Memo], 3/23/1972
From Clayton Yeutter, through Magruder, to Mitchell RE: support for RN from Ohio Congressmen. 1 pg. [Subject: Campaign] [Memo], 3/10/1972
Handwritten notes covering various campaign topics, including a Democratic telethon and a Wisconsin telephone study. 1 pg. [Subject: Campaign] [Other Document], 3/20/1972
From Magruder to Mitchell RE: the use of Jimmy Hoffa, Jr. in the Michigan campaign.1 pg. [Subject: Campaign] [Memo], 3/24/1972
From Stans to the Vice President RE: committing to various campaign speaking engagements. Handwritten notes added by unknown. 1 pg. [Subject: Campaign] [Memo], 3/20/1972
Handwritten notes detailing information from Malek with regard to topics such as relations between the White House and the CRP, contact with state chairmen, and campaign advertising. 1 pg. [Subject: Campaign] [Other Document], no date
From Magruder to the Attorney General RE: notes from a meeting with W. Ernst Minor on campaign spokesmen. 2 pgs. [Subject: Campaign] [Memo], 2/16/1972
From Herbert L. Porter to Magruder RE: surrogate candidates. 1 pg. [Subject: Campaign] [Memo], 3/24/1972
From Magruder to Mitchell RE: Theadore White's request for a meeting. 1 pg. [Subject: Campaign] [Memo], 3/23/1972
From Magruder to Mitchell RE: the results of a mock primary at the University of Wisconsin at Whitewater 1 pg. [Subject: Campaign] [Memo], 3/23/1972
From Rietz to Magruder and Malek RE: RN's victory in a mock primary at the University of Wisconsin at Whitewater. 1 pg. [Subject: Campaign] [Memo], 3/22/1972
From Magruder to Mitchell RE: the Sheraton Corporation's desire to run an ad in the Republican National Convention program book. 1 pg. [Subject: Campaign] [Memo], 3/22/1972
From Magurder to Haldeman RE: an attached memo from Bill Novelli. 1 pg. [Subject: Campaign] [Memo], 3/24/1972
From Bill Novelli to Alex Armendaris, Paul Jones, Rietz, Dan Todd, and Clayton Yeutter RE: developing campaign advertising targeted to specific voter demographics. 4 pgs. [Subject: Campaign] [Memo], 3/16/1972
From Magruder to Mitchell RE: a new campaign spending law. Material from the House of Representatives and the Federal Communications Commission on the law attached. 38 pgs. [Subject: Campaign] [Memo], 3/24/1972
citationUrl
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Richard M. Nixon's Returned Materials Collection
Contested Materials Files
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Richard Nixon Presidential Library
Contested Materials Collection
Folder List
Box Number
Folder Number
Document Date
No Date
Subject
Document Type
Document Description
30
5
>
Campaign
Memo
From Higby to Strachan RE: attached
information for Magruder. 1 pg.
30
5
3/29/1972
Campaign
Memo
From Strachan to Haldeman RE: information
from Chotiner on Louie Nunn and the
Kentucky Senate race. 1 pg.
30
5
3/27/1972
Campaign
Memo
From Chotiner to Haldeman RE: the filing
deadline for the Kentucky Senate race. 1 pg.
30
5
3/24/1972
Campaign
Memo
From Chotiner to Haldeman RE: Nunn's
disappointment that RN had not endorsed
him for the position of Kentucky Senator by
early 1972. 1 pg.
Tuesday, August 30, 2011
Page 1 of 8
Box Number
Folder Number
Document Date
No Date
Subject
Document Type
Document Description
30
5
3/15/1972
Campaign
Memo
From Magruder to Mitchell RE: the use of
telephone operations in the 1972 elections. 4
pgs.
30
5
2/17/1972
Campaign
Memo
From Patricia Hutar to the Attorney General
RE: a Steering Committee to direct
volunteers in the campaign. 2 pgs.
30
5
2/4/1972
Campaign
Other Document
Press release from the California Committee
to Re-Elect the President naming Governor
Ronald Reagan as its chair. 2 pgs.
30
5
2/4/1972
Campaign
Other Document
Governor Reagan's remarks at a press
conference wherein he revealed his role as
California CRP chairman. 2 pgs.
30
5
Campaign
Other Document
Committee for the Re-election of the
President news release on its advertising task
force, the November Group. 2 pgs.
Tuesday, August 30, 2011
Page 2 of 8
Box Number
Folder Number
Document Date
No Date
Subject
Document Type
Document Description
30
5
3/27/1972
Campaign
Memo
From Hugh W. Sloan, Jr. to Strachan RE:
attached information on David K. Wilson. 1
pg.
30
5
11/16/1971
Campaign
Letter
From Hugh W. Sloan, Jr. to Strachan RE: a
large campaign contribution from Wilson
and his family. 1 pg.
30
5
>
Campaign
Newsletter
Article titled "Republicans Woo Youth for
Nixon" written by Ann Blackman. 1 pg.
30
5
3/10/1972
Campaign
Memo
From Haldeman to Magruder RE: the role of
youth workers in the New Hampshire
primary. 1 pg.
30
5
Campaign
Memo
Sixteenth page of a memo discussing
campaign contributions, RN's poll numbers
in the midwest, and youth organizations in
the campaign. 1 pg.
Tuesday, August 30, 2011
Page 3 of 8
Box Number
Folder Number
Document Date
No Date
Subject
Document Type
Document Description
30
5
3/24/1972
Campaign
Memo
From Magruder to Haldeman RE: attached
information on Florida campaign topics. 1 pg.
30
5
3/20/1972
Campaign
Memo
From Morgan to Marik RE: political mass
mailings and volunteers in the Florida
campaign. Charts and graphs showing
correlations between the two included. 25
pgs.
30
5
2/24/1972
Campaign
Memo
From Magruder to the Attorney General RE:
the use of Arthur C. Nielson, Sr. and his
television rating company to determine past
voter habits. 2 pgs.
30
5
3/13/1972
Campaign
Memo
From Magruder to Mitchell RE: RN's
domestic policies with regard to the
campaign. 1 pg.
30
5
Campaign
Memo
From "Van" to Gordon RE: an attached
statement authored by Bob Dole. 1 pg.
Tuesday, August 30, 2011
Page 4 of 8
Box Number
Folder Number
Document Date
No Date
Subject
Document Type
Document Description
30
5
3/8/1972
Campaign
Report
News release of a statement made by Dole
RE: the results of the New Hampshire
presidential primary. 1 pg.
30
5
3/1/1972
Campaign
Other Document
Handwritten notes relating to a meeting on
the campaign. 1 pg.
30
5
2/23/1972
Campaign
Other Document
Handwritten notes detailing a policy issues
meeting. 4 pgs.
30
5
Campaign
Other Document
Handwritten notes documenting the death of
the son of John Rollins. 1 pg.
30
5
3/23/1972
Campaign
Memo
From Magruder to Colson RE: veterans in
the New Hampshire primary and the 1972
campaign as a whole. 1 pg.
Tuesday, August 30, 2011
Page 5 of 8
Box Number
Folder Number
Document Date
No Date
Subject
Document Type
Document Description
30
5
3/10/1972
Campaign
Memo
From Clayton Yeutter, through Magruder, to
Mitchell RE: support for RN from Ohio
Congressmen. 1 pg.
30
5
3/20/1972
Campaign
Other Document
Handwritten notes covering various
campaign topics, including a Democratic
telethon and a Wisconsin telephone study. 1
pg.
30
5
3/24/1972
Campaign
Memo
From Magruder to Mitchell RE: the use of
Jimmy Hoffa, Jr. in the Michigan
campaign. 1 pg.
30
5
3/20/1972
Campaign
Memo
From Stans to the Vice President RE:
committing to various campaign speaking
engagements. Handwritten notes added by
unknown. 1 pg.
30
5
Campaign
Other Document
Handwritten notes detailing information
from Malek with regard to topics such as
relations between the White House and the
CRP, contact with state chairmen, and
campaign advertising. 1 pg.
Tuesday, August 30, 2011
Page 6 of 8
Box Number
Folder Number
Document Date
No Date
Subject
Document Type
Document Description
30
5
2/16/1972
Campaign
Memo
From Magruder to the Attorney General RE:
notes from a meeting with W. Ernst Minor on
campaign spokesmen. 2 pgs.
30
5
3/24/1972
Campaign
Memo
From Herbert L. Porter to Magruder RE:
surrogate candidates. 1 pg.
30
5
3/23/1972
Campaign
Memo
From Magruder to Mitchell RE: Theadore
White's request for a meeting. 1 pg.
30
5
3/23/1972
Campaign
Memo
From Magruder to Mitchell RE: the results of
a mock primary at the University of
Wisconsin at Whitewater 1 pg.
30
5
3/22/1972
Campaign
Memo
From Rietz to Magruder and Malek RE: RN's
victory in a mock primary at the University
of Wisconsin at Whitewater. 1 pg.
Tuesday, August 30, 2011
Page 7 of 8
Box Number
Folder Number
Document Date
No Date
Subject
Document Type
Document Description
30
5
3/22/1972
Campaign
Memo
From Magruder to Mitchell RE: the Sheraton
Corporation's desire to run an ad in the
Republican National Convention program
book. 1 pg.
30
5
3/24/1972
Campaign
Memo
From Magurder to Haldeman RE: an
attached memo from Bill Novelli. 1 pg.
30
5
3/16/1972
Campaign
Memo
From Bill Novelli to Alex Armendaris, Paul
Jones, Rietz, Dan Todd, and Clayton Yeutter
RE: developing campaign advertising
targeted to specific voter demographics. 4
pgs.
30
5
3/24/1972
Campaign
Memo
From Magruder to Mitchell RE: a new
campaign spending law. Material from the
House of Representatives and the Federal
Communications Commission on the law
attached. 38 pgs.
Tuesday, August 30, 2011
Page 8 of 8
THE WHITE HOUSE
WASHINGTON
Date:
To : its
From :
L. Higby
Check theifort
of Mac Jayen
in telligen
G macGofqro
Rede
THE WHITE HOUSE
WASHINGTON
March 1, 1972
MEMORANDUM FOR:
H. R. HALDEMAN
FROM:
GORDON STRACHAN
G
SUBJECT:
Kentucky Senate Race
Murray Chotiner is reminding you that
date for filing in the Kentucky Senate today race Louie Nunn
is the last
could win if he received White House support and money
according to Dent. However, Dent believes Mitchell is
probably planning on not intervening to get Nunn in the race
because Lee Nunn has "poisoned" Mitchell against his
brother by calling him a "crook."
Cooper will not run according to Dent.
Dent has not been able to reach John Mitchell in Florida to
confirm their previous discussion.
If you want to confirm Dent's impression of Mitchell's thinking
you would have to place the call personally to Mitchell.
Attachment
From the desk of
MURRAY M. CHOTINER
March 27, 1972
FOR:
H. R. HALDEMAN
For your information. The filing dead-
line for the U.S. Senate in Kentucky
is Wednesday, March 29.
If Louie Nunn is to run, he will need
a bit of White House encouragement.
timmay
SUITE 500
1701 PENNSYLVANIA AVENUE. N.W.
WASHINGTON. D.C. 20006
TELEPHONE 202 298.9030
LAW OFFICES
REEVES & HARRISON
SUITE 500
1701 PENNSYLVANIA AVENUE, N.W.
MARION EDWYN HARRISON
WASHINGTON, D. C. 20006
OF COUNSEL
ERNEST GENE REEVES
MURRAY M. CHOTINER
ROBERT F. SAGLE
TELEPHONE 202 298-9030
MYRON SOLTER
TELEX 440376 CRDK
CHARLES EMMET LUCEY
CABLE "REEVLAW"
March 24, 1972
Hon. H. R. Haldeman
Assistant to the President
The White House
Washington, D.C. 20500
Dear Bob:
I am reliably informed that Louie Nunn is disappointed
he has not received oral encouragement from the President
to run for the Senate seat in Kentucky this year.
Apparently, the only two who can win the seat are Cooper
and Nunn.
I am advised that Senator Brooke has stated that Cooper
will run in spite of his statement that he will not run
if there is a draft for him to do SO. This is the situ-
ation in spite of his illness and age.
However, if Cooper or Nunn do not run, we lose the seat.
Cordially,
Murray M. Chotiner
MMC bh
COMMITTEE FOR THE RE-ELECTION OF THE PRESIDENT
1701 PENNSYLVANIA AVENUE. N.W.
WASHINGTON. D. C. 20006
March 15, 1972
(202) 333-0920
CONFIDENTIAL
MEMORANDUM FOR:
THE HONORABLE JOHN N. MITCHELL
FROM:
JEB S. MAGRUDER
SUBJECT:
Plans for the Telephone Operation
The first application of the telephone operation in the 1972
campaign was done in New Hampshire. It proved to be quite
successful. Nine telephone centers were operated, nearly
60,000 Republican households were contacted and over 105,000
completed calls were made. In addition, several thousand
volunteers were involved in the program.
Activities in the Primary States
This memorandum discusses briefly some recommendations relating
to the plans for telephone activity in the remaining primary
states and the type of organization we feel Nancy Brataas should
have in order to perform in those primary states. It is pro-
posed that the telephone operation be carried out in two more
primary states, Maryland and California.
Maryland
The Maryland primary is on May 16. Maryland is a state which
the President has a good chance to carry, but, in order to do
so, a great deal of organizational effort will have to be done
between now and November. The telephone campaign provides the
opportunity to involve many volunteers early in the year as a
format for the later campaign organization and to train key
people to operate a number of telephone centers in the fall. It
is proposed that one telephone center be established in Mont-
gomery County, made up of 10 telephones. From that center, toll-
free calls can be made to Prince Georges County as well as to
Montgomery County. Over a four-week period, the center would
have the capability of calling approximately 50,000 Republican
CONFIDENTIAL
-2-
households. One of the advantages of conducting a telephone
operation in Montgomery is that several volunteers in the D.C.
area could be trained who would be helpful to Nancy Brataas at
1701 Pennsylvania throughout the campaign. In particular, it
would be a great training location for people on her staff who
have not had prior campaign experience in this type of operation.
California
The most comprehensive remaining telephone operation would be
planned for the state of California, whose primary is on June
6. Once again, the primary purpose of the operation would be
to identify and train key leaders at the state level for the
fall campaign and to recruit a large number of volunteers to be
available in the fall. A secondary objective would be to contact
the Republican households and to increase the vote for the
President on Election Day.
The proposed plan has been discussed with Lyn Nofziger, and he
is very anxious to begin preparing for the operation in Cali-
fornia as soon as possible. Centers would be located in each
of the four regions into which the state has been divided for
the campaign. There would be one center in Stockton, one in
Santa Clara, one in Orange County, one in San Diego County and
2 to 4 in Los Angeles County, for a total of 6 to 8 centers.
Each center would have a maximum capability of about 50,000
completed calls, so that a total of 300,000 to 500,000 voters
could be contacted. More detailed plans and specific recommenda-
tions on the proposed telephone operations for each of these
primary states will be presented as a part of the overall state
plans.
Plans for the General Campaign
There are two types of telephone operations contemplated for
the General Campaign. One is the type used in New Hampshire.
Several variations are possible in terms of the timing of the
calls and the content of the conversation. However, in all
cases, the centers would be manned by volunteers. The purpose
would be to contact Republicans to reaffirm their support of
the President and to ask them to volunteer for the campaign.
CONFIDENTIAL
-3-
Independents and enlightened Democrats would be canvassed in
selected areas to identify those favorable to the President
for get-out-the-vote operations near Election Day. The un-
decided voters in this category would receive follow-up
communications as was done in New Hampshire.
The second broad type of telephone activity would be similar
to the "Neighbors for Nixon" program in 1968. In that case,
calls would be made into areas where the recruitment of
volunteers is impractical. Among those areas would be the
Black community, Spanish surname communities and ethnic com-
munities within large cities. Therefore, these centers
would be staffed by paid personnel. We would probably. imple-
ment a program similar to the 1968 operation where a person
is located in each neighborhood to call on his neighbors,
leave literature and ask them to vote for the President. We
would envision substantially better controls than in 1968 and
a much less expensive overall operation.
I feel that Nancy Brataas has demonstrated by her performance
in New Hampshire that she would be the appropriate person to
direct both telephone programs. In that capacity, she would
report directly to Bob Marik. A detailed organization plan
and budget for both types of telephone programs will be sub-
mitted for your approval within a few weeks.
Staffing Requirements
At the present time, the staff of the telephone division con-
sists of Nancy Brataas as Director and one secretary. The
following additional staff members are recommended to be hired
immediately:
1. An Assistant Director for volunteer telephone operations
with a salary at approximately $15,000. A woman by the name
of Carmen Hoeppner of Minnesota, who helped as a volunteer
in New Hampshire, has been recommended for that position.
2, An Administration Coordinator who would be responsible for
the management of the Washington office while Nancy Brataas
CONFIDENTIAL
-4-
and the Assistant Director are spending considerable time
traveling to important states to implement the telephone
programs in the field. Salary would be approximately
$15,000. Gail Belt, who has been active in local California
politics and has recently moved to Washington, is under
consideration for this position.
3. An Assistant Director for "Neighbors for Nixon". Most
probably, a man would be appropriate for this position.
Salary range would be $15,000 to $20,000. No candidates
have as yet been identified. After receiving negative
reports from many sources on Alan Peterson, we have decided
that it would be inappropriate to ask him to perform this
function in 1972.
4. One more Secretary, to assist the managers described above,
at a salary of $7,000 to $8,000.
Recommendation
That you approve of the staffing plan outlined above and
authorize Nancy Brataas to recruit people for those positions.
Approve
Disapprove
Comment
CONFIDENTIAL
COMMITTEE FOR THE RE-ELECTION OF THE PRESIDENT
1701 PENNSYLVANIA AVENUE N W
WASHINGTON 0 C 20006
(202) 333-0920
February 17, 1972
CONFIDENTIAL
MEMORANDUM FOR THE ATTORNEY GENERAL
SUBJECT:
Steering Committee
In working with the development of State Committees for the
Re-election of the President, it became apparent to the staff
that certain individuals within a state might better serve at
the national level. To utilize the experience and talents of
these persons, we are recommending that a Steering Committee
be formed to work in an advisory capacity with the Director of
Volunteers.
Therefore, we recommend that a Steering Committee be formed to
utilize the expertise and experience of the Committee members
to focus on effective use of volunteers in the campaign. The
Steering Committee will include representation from the Repub-
lican National Committee, National Federation of Republican
Women, non-partisan leaders and a public relations consultant.
The Public Relations Consultant would be on a retainer and would
counsel on a number of projects.
The Steering Committee will concentrate on the development of:
1. Ideas to recruit, motivate and utilize volunteers
effectively.
2. Special recognition programs for outstanding volunteers
to build enthusiasm and motivation.
3. Ideas to gain the support of members in non-partisan
organizations. Use the 1968 National Advisory Committee,
Women for Nixon-Agnew as the format.
4. Public relations, publicity and promotion ideas.
The first meeting of the Steering Committee could be held during
the Republican National Leadership Conference to be held March
1-4. Most of the proposed Committee members will be attending
the Conference.
CONFIDENTIAL
- 2 -
Membership possibilities include:
Mrs. Dorothy Stanislaus -- National Committeewoman from
Oklahoma
Mrs. Gladys O'Donnell -- Immediate Past President, NFRW,
California
Miss Martha Moore -- National Committeewoman from Ohio
Mrs. Mary Ellen Miller -- Congressional Campaign Committee,
Oklahoma, formerly President, Alabama Federation of
Republican Women
Miss Virginia Allan -- former national President, Business
and Professional Women, from Michigan (pending job
situation)
Mr. Bernard M. Shanley -- National Committeeman from New
Jersey
Mr. William McLaughlin -- State Chairman from Michigan
Mrs. Adelaide Brady -- Public Relations Consultant
Mrs. Mary Louise Smith -- National Committeewomen from Iowa
Mr. Clarke Reed -- State Chairman from Mississippi
Mrs. Paula Hawkins -- National Committeewoman from Florida
With your concurrence we would like to proceed with the develop-
ment of the Steering Committee as described above.
Approve
Disapprove
Comment
PATRICIA HUTAR
CALIFORNIA COMMITTEE TO RE-ELECT THE PRESIDENT
FOR RELEASE, 11:00 AM, PST, FRIDAY, FEBRUARY 4:
CONTACT: Lyn Nofziger
(213) 670-8111
LOS ANGELES, February 4 -- Ronald Reagan disclosed today that he will head
the campaign in California to re-elect President Nixon.
Reagan also announced that industrialist Leonard Firestone will be
Mr. Nixon's Finance Chairman for the state.
The Governor made the announcements in a press conference at the
Century Plaza Hotel, flanked by other of the state's leading Republican
figures.
Reagan said the presence of the group reflected the fact that the
Republican Party in California is unified behind the President.
On the platform with Reagan -- or sending messages of support --
were Firestone, Lt. Governor Ed Reinecke, State Treasurer Ivy Baker Priest,
State Comptroller Houston Flournoy, Attorney General Evelle Younger, Putnam
Livermore, State Chairman; Gordon Luce, State Vice Chairman; Mrs. Eleanor
Ring, National Committeewoman; Thomas C. Reed, National Committeeman; Ralph
Rosedale, President of the County Chairmen's Association; Bob Monagan, GOP
leader in the State Assembly; John Stull, GOP Caucus Chairman in the Assembly;
Fred Marler, Senate GOP leader and John Harmer, Senate GOP Caucus leader.
Reagan said that Luce will also serve as his special assistant in the
campaign working with the campaign leadership at all levels. He said the
Nixon campaign committee, to be known as the California Committee to Re-Elect
the President, will work closely with the Central Committee in the areas of
registration and getting-out-the-vote. He said the Committee will begin to
function immediately.
(more)
"This is not just another election," the Governor said. "This is an
election that will match a solid and consistent performer against a group
of politicians who have been on every side of almost every issue.
"This will match the man who has wound down the war, reformed the
draft, balanced the Supreme Court and come to grips with the hard, knotty
problems of inflation and unemployment against those who are known more
for their destructive criticisms than for any worthwhile accomplishments."
Reagan also disclosed that Lyn Nofziger, Deputy Chairman of the Republican
National Committee, will leave the Committee to serve as Executive Director
of the California campaign.
(30)
REMARKS BY GOVERNOR RONALD REAGAN
February 4, 1972
I'm sure that none of you is really surprised as to why we are here
today. There has been a lot of talk in recent months about the upcoming
Presidential campaign, and about the roles various people will play in it.
From the very first I have felt that the Republican governor of California
should head the re-election campaign of the Republican President. Therefore,
I am announcing today that I have accepted the chairmanship of the campaign
in California to re-elect the President.
We have met here today -- my friends here on the platform and I --
to discuss the campaign for the re-election of President Nixon and its
proposed leadership.
I am pleased that they also are in this campaign and have pledged
themselves to an all-out effort for the President's re-election. I think
you can judge by those present just how broad the President's support is
in California.
Beyond those here I have receive literally thousands of pledges of
support for the President from all over the state and from a few persons
who could not be here today.
One person in particular I am sorry cannot be here. That is my good
friend, Leonard Firestone, who has agreed to serve as State Finance Chairman
for the campaign.
As most of you know, Len has been one of the outstanding leaders of the
Republican Party in California for many years.
In order to put a campaign together it is obvious that we need more than
(more)
just a chairman and a finance chairman. Therefore I am asking Gordon
Luce to directly assist me in this campaign.
Gordon, of course, is a former member of my cabinet and now is the
President of San Diego Federal Savings & Loan. He will be helping in
his capacity as a private citizen and will work with the campaign leadership
at all levels.
Finally, I want to announce that Lyn Nofziger, who has been working at
the Republican National Committee, will serve as Executive Director of
the campaign.
The Committee will be known as the California Committee to Re-Elect
the President and as such it will seek the vote not only of Republicans
but also Democrats and Independents. Nevertheless, we hope to work
closely with the State and County Republican organizations especially
in the areas of registration and getting-out-the-vote.
Finally, we hope to have a full fledged headquarters opened by March
lst. We will let you know when that opens.
Now before I open this up to questions I want to predict that Richard
Nixon can carry California and can be re-elected. One thing about this
election -- it is not just another election --- it is an election that will
match a solid and consistent performer --- Richard Nixon -- against a group
of politicians who have been on every side of almost every issue in the
last few years. This will match the man who has wound down the war, reformed
the draft, balanced the Supreme Court and come to grips with the hard, knotty
problems of inflation and unemployment against those who are known more for
their destructive criticisms than for any worthwhile accomplishments. I
think the American people know that, and that is why I think Richard Nixon
will be re-elected.
(30)
News
from
the Committee
for the Re-election
of the President
1701 PENNSYLVANIA AVENUE, N.W., WASHINGTON, D.C. 20006 (202) 333-0920
FOR IMMEDIATE RELEASE
CONTACT: DeVan L. Shumway
(202) 333-7060
#2-7
NOVEMBER GROUP
WASHINGTON --- The Nixon campaign's advertising task force for the
72 elections has begun its work at 909 Third Avenue, New York City.
Called the November Group, the task force is headed by Peter H.
Dailey, 41, President of Dailey and Associates, Los Angeles and suppor-
ted by a team of professionals on leaves of absence from agencies
around the country.
Dailey said recently that the Task Force's mission will be
"development of strategy as well as creation and placement of all adver-
tising and consumer promotion for the President's 1972 re-election
campaign.
"
Phillip Joanou, Vice President of Doyle Dane Bernbach, Inc., is
Executive Vice President of the November Group. He is careful to
draw the distinction between the Task Force concept and a standard
advertising agency.
"It's not really correct to call us an agency," Joanou says. "We
have a very narrowly defined mission: to assist in the re-election of
the President. When that mission has been accomplished, the November
Group goes out of business."
Joining Dailey and Joanou are:
(more)
Bill Taylor, Creative Director - Senior Vice President and
member of the Board at Ogilvy and Mather, New York.
Paul Muller, Senior Vice President, Finance - Formerly Vice President,
Treasurer of Young and Rubicam, New York.
Fred Becker - Treasurer, Rumrill-Hoyt where he was Vice President
and Assistant Treasurer.
Mike Lesser, Account Manager - Senior Vice President at Marschalk
and Company.
George Karalekas, Media Director - former Director of Advertising
Services at Canada Dry Corporation and Associate Media Director at
Grey Advertising.
Bill Novelli, Account Supervisor - Formerly responsible for
advertising, films, research and creative services with the Peace
Corps/ACTION in Washington and Wells, Rich and Greene in New York.
Mike Heinrich, Promotion Director - For the last four years in
promotion at RCA Records, New York.
- 30 --
FINANCE COMMITTEE FOR THE RE-ELECTION OF THE PRESIDENT
MEMORANDUM
March 27, 1972
MEMORANDUM FOR GORDON STRACHAN
FROM:
HUGH W. SLOAN, JR. HWL
SUBJECT:
DAVID K. "PAT" WILSON
Per our conversation, for your action.
WHITE HOUSE
POSSIBLE INVITEES
HS chrono
November 16, 1971
Mr. Gordon Strachan
The White House Office
Washington, D.C.
Dear Gordon:
A short time ago, David K. "Pat" Wilson, Co-chairman of the
Republican National Finance Committee, put together a six-
figure contribution from members of his immediate family.
The major portion of this contribution came from Mrs.
Valere Blair Potter (Mrs. Justin), P. O. Box 50238, Nashville,
Tennessee 37205, and Pat Wilson has asked if she could be
invited to a major social event such as a state dinner in
recognition. He has indicated that this would be purely a
gesture on the part of the White House wsince her age and
state of her health would make it impossible to accept.
I would strongly recommend that we do this at the earliest
opportunity and that Mr. and Mrs. David K. Wilson be included
as well, since their gifts make up the balance of the con-
tribution. In the latter case, I am sure they would attend.
Sincerely,
Hugh W. Sloan, Jr.
DES in feed.
Republicans
Woo Youth
For Nixon
By Ann Blackman
Associated Press
In a small, windowless of-
fice across the street from the
White House, a 30-year-old ad-
vertising man named Ken
Rietz is organizing a nation-
wide campaign to capture the
youth vote for President
1
Nixon
Rietz, a native of Oshkosh,
Wis., and now a partner in a
Washington advertising firm,
Up
is director of the Youth Divi-
Hc
sion of the Committee to Re-
lbs.
elect the President.
His goal is to get the Re-
publican message across to as
many of the nation's 25 mil-
lion new voters as possible. To
do the job he has a paid staff
of 14 assistants, all under 30.
"We're putting together a
Young Voters for the Presi-
dent group in every state,"
Rietz said in an interview.
"The first thing we have to
do is get them registered."
For the moment, the Youth
Division is concentrating on
key primary states, and al-
ready has set up offices in
New Hampshire, Florida, Wis-
consin, California and Illinois,
If Rietz's office is small his
budget isn't. "It's more than
any Republican has put into
this kind of campaign," said
Rietz. He refused to disclose
BIG
any figures except staff sal-
alies, which run from $5,000 to
HOI
$11,000.
With registration among vot-
Thinw
ers currently running 2 to 1
maxim
Democratic, Rietz and his as-
divide
sistants are working 12- to 15-
hour days to organize a na-
tionwide network of volunteers
for the precinct-level jobs of
ringing doorbells and setting
up registration drives.
The plan works this way: In
each state, volunteers will
contact potential voters, first
by phone, then with follow-up
letters. The information gath-
ered is sent to the Washing-
ton headquarters where it is
kept on file in computers with
other statistical data on young
voters.
s
"Also, we plan to set up
RE
training centers for speakers
and volunteers in each state,"
said Ken Smith, 22, of Harbe-
son, Del. "We want to give
them briefings and supply
Frostles
holds 1:
them with facts and figures."
EXTRA.
Smith, who has charge of
recruiting Republican speak-
ers for young audiences, and
his colleagues are well aware
that-only one-fifth of the new
voters are on college cam-
puses. Although they are
scheduling Cabinet officers
and White House officials to
speak on key campuses, the
emphasis of their campaign
is on non-college youth.
3/15 H 13/13 fu
March 10, 1972
MEMORANDUM FOR :
MR. MAGRUDER
3/20
FROM :
H.R. HALDEMAN
Have we given adequate public credit and recognition to the great
work the youth in New Hampshire in the primary campaign?
HRH:pm
for
each.
16
OTHER GOP
mally
U. S. News reports an active Kansas GOP member says RN is
mistaken in taking a midwest-western sweep for granted as Admin.
farm programs are blamed for widespread resentment
Hartford
Times poll reported 52% give the Admin an "only fair " rating on
credibility; 24% rated it "good;" 17% said "poor, 11 while 7% had no
opinion.
Van Shumway said at the Comm. for the Re-election that "we
have no plans to make a side show of listing donors. 11 Ziegler indicated
he didn't believe RN had even considered the matter "I think he'll
leave that to the citizens committee. " AP says the WH hedged on the
issue. It was made clear that the RN contributions would be filed as
the laws require.
AP with a special on the RN youth campaign headed by Ken Rietz.
"If Rietz's office is small, his budget isn't, says AP. With young
voters currently running 2-1 dems, Rietz's group of under-30s is
working 12-15 hour days to organize a nationawide network of precinct
level volunteers. AP notes that altho WH and Cabinet people are being
scheduled for campuses, the emphasis is on non-college youth difficult
to reach because they aren't conveniently situated on campuses.
Noting they aren't writing-off campus youth, one staff member is quoted
as saying that, after his travels around the country, "I get the feeling
that the Pres. isn't the dirty word in colleges that he was a year ago. "
The 20 year old organizer of the "nixonettes" and "nixonaires, 11 said
she'd like to change the names to "Young Women for the President, 11
because "I don't want Gloria Steinem calling me and saying we're
exploiting the cause
but, they won't let me. 11
COMMITTEE FOR THE RE-ELECTION OF THE PRESIDENT
March 24, 1972
1701 PENNSYLVANIA AVENUE. N.W
WASHINGTON. D. C. 20006
(202) 333.0920
CONFIDENTIAL
MEMORANDUM FOR H. R. HALDEMAN
FROM:
JEB S. MAGRUDER In
Attached for your information is a copy of the report
on the Florida mailing responses, volunteers and contributors.
CONFIDENTIAL
Committee for the Re-election of the President
MEMORANDUM
March 20, 1972
MEMORANDUM FOR:
DR. ROBERT MARIK
FROM:
ROBERT MORGAN AA
SUBJECT:
Florida Mailing Responses
Volunteers and Contributors
This is the second and final report on the volunteer and
contributor responses for the Florida mailing. The report
is for the week ending March 17, 1972.
The objectives of the mailing were accomplished with some
very substantial side effects --
- 5,106 new volunteers were seeded down
to the precinct level in the top 10
counties, and
- 3,601 contributors donated $31,308
for an average of $8.70/contribution.
This paid for 48% of the mailing cost.
The Republican party in Florida was left with a very good
nucleus for the General Election while people working on
the program were given the opportunity to test their
mettle and be judged.
A detailed table showing the total responses for volunteers
and contributors on a daily basis is attached as Tab A.
A chart showing cumulative response is attached as Tab B.
Tab C shows daily response.
Please note that the response curves between New Hampshire
and Florida were similarly shaped. By the fourth day of
response in New Hampshire 35.4% of the total was in versus
39% in Florida. The fifth day showed 40% for New Hampshire
versus 47% for Florida. Florida's mail delivery was very
slow and then not processed smoothly by the post office
when it was returned. If it had run smoothly in Florida,
I strongly believe the response curves would have been the
same as New Hampshire.
-2-
We are in a position now to predict final response four days
after the first response is received. This hypothesis will
be tested in Wisconsin and California.
Cumulative and daily response charts for the counties
mailed are attached as follows:
% Voting for
County
Tab
President Nixon
Brevard
D
87
Broward
E
87.9
Dade
F
84.7
Duval
G
88.2
Hillsborough
H
88.8
Orange
I
89.1
Palm Beach
J
86.7
Pinellas
K
85.9
Sarasota
L
88.0
Volusia
M
88.6
Attachments
cc: Mr. Harry Flemming
Mr. Jeb S. Magruder
Mr. Hugh Sloan
FLORIDA MAILING RESPONSE
Average
Date
Responses
Volunteers
Contributors
Contributions
Contribution
Td.
Cum.
Td.
Cum.
Td.
Cum.
Td.
Cum.
Td.
Cum.
2-25
218
218
207
207
11
11
73
73
6.60
6.60
2-26
907
1,125
478
685
429
440
2,558
2,631
6.00
6.00
2-28
951
2,076
574
1,259
377
817
3,028
5,659
8.00
6.90
2-29
1,374
3,450
983
2,242
391
1,208
5,724
11,383
14.60
9.40
3-1
640
4,090
391
2,633
249
1,457
2,534
13,917
10.20
9.60
3-2
831
4,921
514
3,147
317
1,774
2,591
16,508
8.20
9.30
3-3
1,436
6,357
821
3,968
615
2,389
5,536
22,044
9.00
9.20
3-4
304
6,661
134
4,102
170
2,559
1,094
23,138
6.40
9.00
3-6
96
6,757
71
4,173
25
2,584
214
23,352
8.60
9.00
3-7
651
7,408
379
4,552
272
2,856
1,735
25,087
6.40
8.80
3-8
269
7,677
110
4,662
159
3,015
1,395
26,482
8.80
8.80
3-9
337
8,014
108
4,770
229
3,244
1,687
28,169
7.40
8.70
3-10
168
8,182
68
4,838
100
3,344
771
28,940
7.70
8.70
3-11
28
8,210
23
4,861
5
3,349
55
28,995
11.00
8.70
3-13
221
8,431
107
4,968
114
3,463
1,038
30,033
9.10
8.70
3-14
70
8,501
32
5,000
38
3,501
428
30,461
11.30
8.70
3-15
99
8,600
49
5,049
50
3,551
488
30,949
9.80
8.70
3-16
78
8,678
40
5,089
38
3,589
284
31,233
7.50
8.70
3-17
29
8,707
17
5,106
12
3,601
75
31,308
6.30
8.70
No. of
Florida Mailing
Tab B
Responses
Cumulative Number of Responses
10,000
9,000
8,000
7,000
Total Number of Responses
Primary Date
6,000
5,000
Total Number of Volunteers
10 X 10 X 10 TO THE INCH 46 0780
MA CINUSA,
4,000
7 X 10 7 X 10 INCRES
REWIFEL & ESSER CO.
000
2,000
Total Number of Contributors
1,000
25 26 28 29 I 2 3 4 6 7 8 9 10 11 13 14 15 16 17 18
February
March
No. of
Tab C
Florida Mailing
Responses
Daily Responses
Total Daily Responses
Total Daily Contributors
1,800
Total Daily Volunteers
1,600
1,400
1,200
Primary Date
1,000
800
K.E 10 X 10 X 10 TO THE INCH 46 0780
MADE
7 X 1 ) INCOME
KRUFFEL & ESSER CO.
600
400
200
2
in
7
X
,
11
i
February
March
No. of Volunteer
Florida Mailing
Tab D
Responses
Cumulative Number of Volunteer Responses
200
180
Brevard County
Count: 21,191
160
140
120
100
10 X 10 10 X 10 TO THE INCH 46 0780
80
M.F 112 INCHES MADE 11. IN U S.A.
7 X 7X 10 NO Hrs
KCUFFEL & ESSLR CO.
60
Primary Date
40
20
26 28 29 I 2 3 of 0 / 8 9 10 11 13 14
February
March
No. of Volunteer
Florida Mailing
Tab D
Responses
Daily Volunteer Responses
50
45
Brevard County
Count: 21,191
40
35
30
25
MADE 11. ..A.
20
Las K&E 10 X 10 X INCH 0780
10 TO THE 46
INCHES
KLUFFEL & CSSLR CO.
X10 ,NO
15
Primary Date
10
5
25 26 is 29 , 2 3 of 6 7 I 9 10 11 13 4
February
March
No. of Volunteer
Florida Mailing
Tab E
Responses
Cumulative Number of Volunteer Responses
2,000
1,800
Broward County
Count: 72,775
1,600
1,400
1,200
1,000
10 X 10 X 10 TO THE INCH 46 0780
MADE IN U S.A.
800
KLUFFEL & ESSER CO.
K-E X 7 X to 7 X 10 INCHES
600
Primary Date
400
200
,
2
8
9
February
March
No. of Volunteer
Florida Mailing
Tab E
Responses
Daily Volunteer Responses
250
Broward County
225
Count: 72,775
200
175
150
125
100
U.S 10 X 10 TO THE INCH 40 0780
X 7 X 19 INCITE MADE
KEUFFEL & ESSER CO.
Primary Date
75
50
25
it 79 29 / 2 3 of 6 .' a , 10 " 15 14
February
March
No. of Volunteer
Florida Mailing
Tab F
Responses
Cumulative Number of Volunteer Responses
1,000
900
Dade County
Count: 49,292
800
700
600
500
400
2 10 x 10 X 10 TO THE INCH 46 0780
MADE IN U S A.
7 X 7 X 10 7 X 10 INCHES
KCUFFEL & ESSLR CO.
300
Primary Date
K-E
200
100
26 , / 2 3 4 6 7 8 7 10 11 13 114
February
March
No. of Volunteer
Florida Mailing
Tab F
Responses
Daily Volunteer Responses
100
Dade County
90
Count: 49,292
80
70
60
50
MADE IN U.S.A.
40
K&E 10 x 10 X 10 TO THE INCH 46 0780
7 X 7 X X 10 10 INCHES
KEUFFEL & ESSER CO.
30
Primary Date
20
10
is
26
29
7.
29
I
2
3
4
6
I
8
/
10
"
13
February
March
No. of Volunteer
Florida Mailing
Tab G
Responses
Cumulative Number of Volunteer Responses
500
450
Duval County
Count: 18,377
400
350
300
250
THE 10.X.10.TO.THE INCH 46 0780
200
****
K2 INCHES
150
Primary Date
100
50
,
3
7
6
8
of
13
of
February
March
No. of Volunteer
Florida Mailing
Tab G
Responses
Daily Volunteer Responses
100
90
Duval County
Count: 18,377
80
70
60
50
10 X 10 TO THE INCH 46 0780
MADE IN U S A.
40
KCUFFEL & ESSER CO
Primary Date
K-E X 7 X 10 INC its INCRES
30
20
10
26
7
Y
/
&
of
&
a
7
"
13
IX
February
March
No. of Volunteer
Tab H
Florida Mailing
Responses
Cumulative Number of Volunteer Responses
500
450
Hillsborough County
Count: 17,824
400
350
300
250
200
K*E 10 X 10X 10 TO THE INCH 46 0780
no 7 X 10 7 X 10 INI MES MADE IN U S.A.
KEUFFEL & ESSER CO.
Primary Date
150
100
50
-6 29 / i 3 if G 7 $ 9 10 " 13 14
February
March
No. of Volunteer
Florida Mailing
Tab H
Responses
Daily Volunteer Responses
100
90
Hillsborough County
Count: 17,824
80
70
60
50
MADE
40
KE 10 X 10 X 10 TO THE INCH 46 0780
7 X TO INCHES
KEUP EL KEUFFELS & ESSE ESSERICO. CO.
30
Primary Date
20
10
24
21
vi
21
3
?
&
,
3
14
February
March
No. of Volunteer
Florida Mailing
Tab I
Responses
Cumulative Number of Volunteer Responses
1,000
900
Orange County
Count: 32,130
800
700
600
500
MADE IND S A.
400
M K+E 10 x 10X 10 TO THE INCH 46 0780
X 7 X 10 7 X 10 INCHES
KEUFFEL & EGSFR CO
300
Primary Date
-
200
100
, 3 of 6 7 $ 9 10 " 13 14
February
March
No. of Volunteer
Florida Mailing
Tab I
Responses
Daily Volunteer Responses
200
180
Orange County
Count: 32,130
160
140
120
100
10 X 10 X 10 TO THE INCH 46 0780
MADE 5
80
7 X 10 7 X 10 INCRES
KEUFFEL & ESSCR CO.
60
Primary Date
K&E
40
20
25 26 23 ( 2 3 of c 2 x 7 " 13 14
February
March
No. of Volunteer
Florida Mailing
Tab J
Responses
Cumulative Number of Volunteer Responses
500
Palm Beach County
450
Count: 43,958
400
350
300
250
10 x 10 TO THE INCH 46 0780
200
E 7 X 7 X 7 X 10 INI INCHES MADE IN U V A.
KEUFTEL a FSSER CO.
Primary Date
150
1/1
K&E
100
50
5
26
=1
/
3
of
6
/
8
9
10
"
3
14
February
March
L
No. of Volunteer
Florida Mailing
Tab J
Responses
Daily Volunteer Responses
100
Palm Beach County
90
Count: 43,958
80
70
60
50
MAIL " U S A,
40
LLC 10 X 10 X 10 TO THE INCH 46 0780
Primary Date
30
: K-Z 1X IN'
20
10
it
2
3
of
6
8
9
1314
February
March
No. of Volunteer
Florida Mailing
Tab K
Responses
Cumulative Number of Volunteer Responses
1,000
Pinellas County
Count: 90,083
900
800
700
600
500
10 X 10 X 10 TO THE INCH 46 0780
400
K+E 7 X 10 INCHS MADE MUSA
KEUFFEL & ESSER CO.
300
Primary Date
200
100
= 26 -8 29 I 2 3 & 6 / 8 of 13 it '.3 in
February
March
No. of Volunteer
Florida Mailing
Tab K
Responses
Daily Volunteer Responses
250
225
Pinellas County
Count: 90,083
200
175
150
125
10 x 10 X TO TO THE INCH 46 0780
MADE 11.
100
KEUFIEL a ESSER CO.
75
Primary Date
KE 7 X 10 *N*
50
25
= 26 2 , = , 3 of to / If , a 11 13 14
February
March
No. of Volunteer
Florida Mailing
Tab L
Responses
Cumulative Number of Volunteer Responses
500
450
Sarasota County
Count: 21,631
400
350
300
250
10 X 10 TO X 10 TO THE INCH 46 0780
MADE U IN U A.
200
KEUP CL a LSSLR CO.
KE 7 X X yes INCORE
150
Primary Date
100
50
% :s Z , to 0 7 , 3 14
February
March
No. of Volunteer
Florida Mailing
Tab L
Responses
100
Daily Volunteer Responses
90
Sarasota County
Count: 21,631
80
70
60
50
10 X 10 X 10 TO THE INCH 46 0780
1
40
KLUFFEL & ESSER CO.
10 X 10 TO
7 INCLE
30
Primary Date
KE
20
10
Y
29
3
6
8
13
February
March
No. of Volunteer
Florida Mailing
Tab M
Responses
Cumulative Number of Volunteer Responses
500
Volusia County
450
Count: 14,516
400
350
300
250
10 X 10 X 10 TO THE INCH 46 0780
MADE U.S.A.
200
X 10 7 X 10 INCHES
KEUFFEL & ESSI R CO.
150
Primary Date
K&E
100
50
is :/ / 3 if 6 7 8 , 10 11 13 14
February
March
No. of Volunteer
Florida Mailing
Таb M
Responses
Daily Volunteer Responses
100
Volusia County
90
Count: 14,516
80
70
60
50
10 X 10 TO THE INCH 46 0780
40
E K.E 10 7 X 10 INCRES MADE
KEUFFEL & ESSLR CO.
Primary Date
30
20
10
/
2
3
of
s
7
/
February
March
COMMITTEE FOR THE RE-ELECTION OF THE PRESIDENT
1701 PENNSYLVANIA AVENUE N.W
WASHINGTON D. C. 20006
(202) 333-0920
February 24, 1972
CONFIDENTIAL
MEMORANDUM FOR THE ATTORNEY GENERAL
SUBJECT: Nielson Survey
We have been in contact with Arthur C. Nielson, Sr., Chairman of
the company which performs the rating service for television pro-
grams. As you know, they have a large sample of viewers who main-
tain detailed diaries of their viewing habits over many weeks.
Nielson would be able, for us, to call each of these people in a
given media market and ask about their past voting habits. With
that information, we would be able to determine whether the "ticket
splitter" has a different type of viewing pattern from the straight
Republican or straight Democratic voter. If so, it could be very
useful in placing our television advertising so as to have the
greatest impact on the uncommitted voter.
At the present time, it is not known whether there is any correlation
between voting behavior and viewing habits. Therefore, it is proposed
that a pilot survey be undertaken in one market (Chicago) to see if
any pattern exists. That would cost $5,000 and involve a sample
of about 1400. If a useful pattern emerged, we would then submit
a follow-up proposal for additional tests in important regional media
centers such as Los Angeles, Atlanta, etc.
Bob Teeter would coordinate the project, from the point of working
with A. C. Nielson on the content of the survey questions and analy-
sis of the data. Peter Dailey would evaluate the usefulness of the
results and develop recommendations for additional work, if he felt
it would be helpful in implementing media strategy.
The people who would be coordinating the project from A. C. Nielson
Company are senior executives who firmly support the President for
re-election.
CONFIDENTIAL
- 2 -
Recommendation
That you approve the expenditure of $5,000 for the pilot project
described above, to determine if our target voters have viewing
patterns different from the population as a whole.
Approve
Disapprove
Comment
JEB S. MAGRUDER
CONFIDENTIAL
COMMITTEE FOR THE RE-ELECTION OF THE PRESIDENT
1701 PENNSYLVANIA AVENUE. N.W.
WASHINGTON D. C. 20006
March 13, 1972
(202) 333-0920
CONFIDENTIAL
MEMORANDUM FOR THE HONORABLE JOHN N. MITCHELL
FROM:
JEB S. MAGRUDER
SUBJECT:
Actions by the President on Domestic Issues
The Campaign Strategy Group has considered the question of what
actions .the President should take on domestic issues between now
and the Moscow trip.
It was their strong feeling that Presidential travels to various
states or cities to dramatize his domestic programs and accomplish-
ments should be limited in number, if done at all. Primary states
should particularly be avoided so that he does not fall to the level
of the crowd of primary election candidates.
The President's declared position of non-involvement in the early
political campaign has remained credible up to this point. As long
as it does, his stature as a national leader and world statesman
can grow. Any attempt, however, to make political gain out of "non-
political" trips could undermine that credibility and restore the
image of a partisan campaign.
The group felt that the most effective technique the President has
employed has been his direct announcement of personal action on an
important problem. That technique has great impact and capitalizes
on the asset of incumbency. The most obvious cases have been China
and the New Economic Policy. The same type of announcement, if
possible, would be the most effective vehicle to reinforce the Presi-
dent's concern and activism on domestic issues. Some important issues,
in the minds of the voters, on which the President is not perceived
positively are: crime, drugs and unemployment.
The most opportune time to increase the President's stature in these
areas will be before the Democratic nominee is selected and the parti-
san guns are turned on the incumbent.
CONFIDENTIAL
COMMITTEE FOR THE RE-ELECTION OF THE PRESIDENT
Gordon:
For your information, I obviously
lost my argument with Neil Koch
because here is the statement issued
by Bob Dole Wednesday afternoon.
Van
Encls.
FOR IMMEDIATE RELEASE
(3/8 at 2:00 PM)
Does N. H. need a recount?
Washington, D. C. -Senator Bob Dole, Chrmn of the RNC, issued
the following statement today.
While I am gratified by the results of the Republican primary
race in N.H. , the vote in the primary of the oppposition party
deitrubs disturbs me graaely. I am reuluctant to see Vance Hartke
subjected to still another recount, but I do think that the totals
suggest a need for a recount in that race.
The tally for the leading candidate is so slow unless there is
some sound political reason for what amounts to a very substantial
rejection of that candidacy, one would have to assume the possi-
bility that the votes were just not counted properly. The leading
candidate got 1% point lower than the New Hampshire total in 1968
beeause-P- that caused Pres. Johnson to withdraw.
Of course, I have called on the front-runner to withdraw a number
of times but he has not and I conclude from this that he anticipated
overwhelming vindication of his positions.
Either this judgement
is in error, or the count is.
0
3/1
1
JSM-
Dave Backley Jones - AA to James
AG
- sincerely concerned
thinks P "lied" to Baelley
?
Teeter + cw c/58m -mty
evellent; tall to Teeter
cover material + ideas
0
2/23
Pol Issues Mty
Fundr- nH - Dartmouth events go
Dent - J8m column nte Jackandersen
attendees: Finch, Dominick, Dent,
Evans, Goodearle, Price,
Timmons, Millspargh, Lehman,
J8m
oushbrook not moving
strongly - under
5% - both public +
private (our poles)
me cooskey - to be expt
below 2090
Rn to get 60-70%
2
compaign a) telephone poll- 70%
positive - only Rep being
called -hi undeuded
b) - undecided get soues
c) all Reps - one telecont
meg - P position
all Repis - mlg 3 times;
190 response but some &
- lists old - 20-25%
d) Get out vote mly of exact
ballot the rotated alphabetically
Deernell + Waller - only joe
get out coters - cards
Radio + punt but no TV
on every
bec/TUToo much of an
escalation
- Radee ads all maninaleetf.INH
active Sunogate comp
minchester armory - Mar 3
Reocefeller / hish lletter w/
20 sens. + ove's
- Inds can vote for 1st time
in n. H - polls Endicate 3 to z
for Dems so we areavoiding
beel could go for mcClosley who
- Endicott Peabody -vp actuities
Irasnt been able to get the Ind's
no more polling in nH,
but telephone checks on effect of Chena
- Evans - turnout, can't rely on
Celephone beel unlisted Rep's
Fla -
ashbook
Timmons friend Mile Thompson, Dade
County am defect
8090 Reps in 10 counties
2 mlgs - 1st to identify Thiontypest
then to 2dd getout vote
Polling Inpo:
ashbrook - 4-5%,
McClosdey - 4-5% a/no
Proe in ag Fla - if ashbrook
got $ in last 2 weeks
could blets us.
Cubans- -
ashhoolc has Wallace pubs
beel Rep nots re-regis
to help Wallace
Dem $:
NOTV in Fla. the ads in can
hindray beggest TU in Fla
ashbrool being uen by manhattan
12 but no real org
except it wing
Run radio - man in street +
punt, no TU, 2 directmail
Sunis - mar 9- Reagan alleynoter
w/ Jackie Gleaton etc in miami
Very low key
Wesconsin - a major effort to
recapture genl election moraenton
but use TV.
3 premaries not entered
see, W. Ua + Pa.
but in the other 15
Del's not relatedte Preferential Rimoy
End of mar series of mtgs W/AG
nisen St Ormn + Rep St Omn
JSM-Good showing - -65-75% but
win line of 50%
ashhwood + Mcl- - pushed te 25%each
E
John Rollins son deil
nate Journal cn Price
Oriel of Prot
Audley, Humes,
COMMITTEE FOR THE RE-ELECTION OF THE PRESIDENT
MEMORANDUM
March 23, 1972
MEMORANDUM FOR:
MR. CHARLES W. COLSON
FROM:
JEB S. MAGRUDER
With reference to your memorandum on the VFW and New
Hampshire, the only message we had from your office on
this subject was a memo from Dick Howard to me on the
use of one Daley Whipple. Rob Odle called Dick to get
Whipple's address and phone number, Dick called back
to give it to Rob, and Rob then called Allan Walker,
our executive director in New Hampshire and asked
Allan to make contact with him.
Whipple was contacted and asked to organize his troops
to participate in the March 3 Appreciation Day Rally,
but he said he had to be out of the state for a time,
and would rather not participate in the campaign in
New Hampshire until after the primary.
Chuck, this is the only contact we ever had from your
office on this subject. We followed through as did
our man in New Hampsnire, but the fellow who was sup-
pose to help didn't.
Naturally, in the campaign, we are going to organize
a maximum effort with veterans. The Veterans Committee
for the Re-election of the President will be one of
Fred Malek's functional groups which will shortly be
formally structured. We have already recommended a
candidate to John Mitchell as executive director of
this group and expect to have approval on him shortly.
Of course he and the entire Veterans Committee will
work closely with your office and Fred Malek will be of
great assistance in coordinating this.
bcc: Mr. Gordon C. Strachan
COMMITTEE FOR THE RE-ELECTION OF THE PRESIDENT
MEMORANDUM
March 10, 1972
MEMORANDUM FOR:
THE HONORABLE JOHN N. MITCHELL
THROUGH:
JEB S. MAGRUDE
FROM:
CLAYTON YEUTTER P
Congressman Latta of Ohio made a comment to me a couple
of days ago that may have merit as we plan strategy for
Ohio. He said that if he were running a state-wide cam-
paign in Ohio, his first move would be to enlist the per-
sonal support of the state's Republican Congressmen. His
rationale for this is that a large number of the Congress-
men typically run far ahead of state-wide candidates (in-
cluding Mr. Nixon in 1968) on election day. If they will
work hard for the President while conducting their own
campaigns, they may be able to significantly boost his
vote total.
I am impressed with his argument. Excluding Ashbrook, the
following Republican Congressmen garnered more than 60% of
the vote in both 1968 and 1970: Clarence Brown; Clarence
Miller; William Keating; Charles Whalen, Jr.; Del Latta;
William Harsha; Jackson Betts; William McCulloch; J. William
Stanton; Charles Mosher and Chalmers Wylie. In addition,
William Minshall was in this category in 1970.
There are some very talented politicians in this group. (Latta
himself received more than 70% in both 1968 and 1970.) We
ought to try to capitalize on this in the Presidential campaign
if we can.
CC: Mr. Harry Flemming
Mr. John C. Foltz
0
3/20
E. - P. Est Plan + inject
yes, G deaft note , Dean
Dems- telephone - A BC - Sat seen by 8-9
19 his - 610,000 - cost + cable
etc. = 1 millin in cost
Celebrities loaded fundraising appeal
Comm name change
advertising etc. Re- Elect P. Nex
Cemm confer name - change after
Wise telephone Derns study -Then/Fre
Pu/P Reven ?
Out - attack onpol purpose leb/
e as Sm stery held per pol motur
Ken Dam - copyot The Re - Electer - Fronk,
COMMITTEE FOR THE RE-ELECTION OF THE PRESIDENT
1701 PENNSYLVANIA AVENUE. N W.
March 24, 1972
WASHINGTON D C. 20006
(202) 333-0920
CONFIDENTIAL
MEMORANDUM FOR THE HONORABLE JOHN N. MITCHELL
FROM:
JEB S. MAGRUDER M
SUBJECT:
Jimmy Hoffa,
Jr.
During the course of our Strategy Planning meeting which
focused on the plans for the Michigan Primary, Jack Gibbs,
our Michigan Executive Director, raised the question of whether
Jimmy Hoffa, Jr., should be appointed to the Michigan Committee.
Gibbs feels, as does Bob Teeter (who is from Michigan) that
the addition of Hoffa to the large group of prominent Michigan
citizens who are being asked to join the Committee, would be
a real boost to the Committee in.that state. However, others
(such as Peter Dailey) feel that the addition of Hoffa to a
state committee would be a net detriment nationally. Therefore,
the question is whether you feel the national reasons for not
putting Hoffa on the Michigan Committee would outweigh the gain
in Michigan from putting him on.
Your guidance would be appreciated on whether Jack Gibbs should
be asked to put Jimmy Hoffa, Jr., on the Committee.
Ask Gibbs to put Hoffa on the Committee
Ask Gibbs not to put Hoffa on the Committee
Jeep we
March 20,
MEMORANDUM FOR THE VICE PRESIDENT
I have discussed the whole matter of speaking engagements
with John Mitchell, and we both feel it is important that
you limit future acceptance of fund-raising events to those
sponsored by state Committees for the Re-election of the
will soll
President. The only exception would be for events which
are promoted jointly by the State Republican Committee and
the State Committee for the Re-election of the President,
received
with the two splitting the net proceeds equally.
That being the case, I recommend that you do not accept
the following invitations:
Indiana State GOP Fund Raiser
June 15
North Carolina State Fund Raiser
June 10 or 17
Arkansas GOP Fund Raiser
May 6
Fort Worth, Texas Fund Raiser
Month of May
Montana Fund Raiser
Date Open
State of Washington
You also noted three events to which you are already committed,
as follows:
Nebraska Fund Raiser
June 9, 16, or 17
Ohio (Colmmbus)
May 9
New Jersey (Westfield)
April 22
If 1t is not reasonably possible for you to withdraw from
them, you will undoubtedly have to keep the commitments.
I hope that this is clear and that it will present no
problems for you.
Maurice H. Stans
cc: Walter Jones
P.S. I understand that Tom Pappas would like you to
80 to Massachusetts to speak at a joint dinner in which our
State Committee would share 50-50. This would meet the
guideline above.
0
Malek
1
E. prob.
2
Job Description
Ttles Dep.
Citizens groups
Comp Monay
3
WH Staff contact w/ Comm
GS+ 58m.
4
State Chairman contact
5
advertising
6
Relationship at 1701
- 75% time at 1701
- only mtys in WH
u/ WH S not 1701
I
7
J8m - finesse
Fla w/ JMT Flemming !
FM meet ul Teeter on polls
x
apparently not results.
COMMITTEE FOR THE RE-ELECTION OF THE PRESIDENT
February 16, 1972
MEMORANDUM
MEMORANDUM FOR THE ATTORNEY GENERAL
SUBJECT:
Mr. W. Ernst Minor
As you know, we agreed to invite Ernie Minor to join our Spokesmen
Resources Division staff for the purpose of scheduling the
Surrogate Spokesmen he has been handling at the Republican
National Committee. I appreciated your hesitancy in agreeing to
that proposal, however, and I postponed discussing the subject
with Ernie in the hope that an alternative agreement might be
reached. As a consequence, we met with Ernie on February 10,
1972, and discussed the following proposal:
1. We will employ an additional individual to
work in our Spokesmen Resources Division. That individual
will schedule those Governors, Senators and Congressmen
who have been, or will be, asked to act as surrogate
spokesmen. We propose to employ an individual for this
position who has had some experience on the Hill and,
perhaps, has served as an administrative assistant.
2. Ernie will schedule, from the Republican
National Committee, all other Governors, Senators and
Congressmen. Ernie assured me that there will be full
cooperation and communication with our operation.
3. The one exception to the foregoing division
of responsibility is that Ernie will be our scheduling
contact with Governor Reagan. I agreed to that because
of Ernie's close established relationship with the
Governor. Ernie will, of course, continue to schedule
Senator Dole.
Memorandum for the Attorney General
February 16, 1972
Page Two
Ernie agreed to this proposal and has, in fact, confirmed it
to me in a subsequent memorandum. I believe this arrangement
will satisfy our requirements and be acceptable to all concerned.
JEB S. MAGRUDER
Committee for the Re-election of the President
MEMORANDUM
March 24, 1972
MEMORANDUM FOR:
THE HONORABLE JOHN N. MITCHELL
THROUGH:
JEB S. MAGRUDER
FROM:
HERBERT L. PORTER
SUBJECT:
Surrogate Candidates
It is my understanding that Secretary Morton recently spoke
to you complaining about being scheduled into certain events
in conjunction with "Appreciation Day" in Florida on March
9th. Also, Jeb Magruder has shown me the letter you received
from Secretary Morton outlining his "strategy" for scheduling
his future appearances.
In discussing this situation with Bob Hitt of Morton's
office, I reviewed carefully the reasoning for having
Secretary Morton accompany us to Florida. In Florida, the
Secretary was the only member of the Administration present,
was introduced as "representing the President", and was
given top billing at our airport arrival that afternoon.
In addition, an impromptu plane-side press conference (shown
on all three Miami T.V. stations that evening) was held
upon arrival.
I disagree with Hitt's claim that the Secretary was "shunted
to a lower level" with Governor Reagan being in attendance.
Hitt also said that the Secretary considered it a "waste
of time" for him to be on the same program as Ronald
Reagan and Red Skelton. This attitude on the part of our
surrogates will only hurt the President. It certainly is
not what the President had in mind last October when he asked
the Cabinet to hit the campaign trail.
It is my hope that the proposed letter from you to our
surrogates will help to alleviate some of the complaints.
In my opinion, the Secretary's plans for publicizing the
national resource problems and talking about the environmental
activities are good. However, on these special "Appreciation
Day" events, nothing beats getting out among crowds, shaking
hands, and doing some old-style political campaigning. That
is where the T.V. cameras are.
CC: H.R. Haldeman
COMMITTEE FOR THE RE-ELECTION OF THE PRESIDENT
1701 PENNSYLVANIA AVENUE. N.W
March 23, 1972
WASHINGTON D C 20006
(202) 333-0920
MEMORANDUM FOR THE HONORABLE JOHN N. MITCHELL
FROM:
JEB S. MAGRUYER
SUBJECT:
Interview with Theadore White
Following your departure for Key Biscayne your office was
contacted by Theadore White, who will be in Washington next
week and wanted to set up an interview to discuss the campaign.
Since you were away this call was referred to my office.
White is interested in speaking with someone who has an over-
view of the campaign during the first part of next week. With
your approval I will meet with White to discuss the campaign.
Approve
Disapprove
Comment
COMMITTEE FOR THE RE-ELECTION OF THE PRESIDENT
1701 PENNSYLVANIA AVENUE. NW
March 23, 1972
WASHINGTON D C. 20006
(202) 333-0920
MEMORANDUM FOR THE HONORABLE JOHN N. MITCHELL
FROM:
JEB S. MAGRUDER
SUBJECT:
Results of the Mock Primary at the University
of Wisconsin at Whitewater, March 22, 1972
Attached for your information are the results of another
mock election where the President won on a college campus.
COMMITTEE FOR THE RE-ELECTION OF THE PRESIDENT
1701 PENNSYLVANIA AVENUE N.W
March 22, 1972
WASHINGTON D C. 20006
(202) 333.0920
MEMORANDUM FOR:
JEB MAGRUDER
FRED MALEK
FROM:
KEN RIETZ
SUBJECT:
Mock Primary - University of
Wisconsin at Whitewater, March 22, 1972
Following are the results of a mock primary which washeld
at the University of Wisconsin at Whitewater on Wednesday,
March 22, 1972.
Nixon
318
McGovern
302
Jackson
45
Muskie
36
Chisholm
31
Lindsay
25
McCarthy
24
Wallace
22
HHH
15
Ashbrook
.8
Patsy Mink
3
Wilbur Mills
1
Write-ins
15
The mock primary was sponsored by the student government,
conducted by the student elections committee and held in conjunction
with the student senate elections. The candidates were listed
according to party on the ballot.
cc: Van Shumway
Angela Harris
801
DETERMINED TO BE AN
ADMINISTRATIVE MARKING
March 22, 1972
E.O. 12085, Section 6-102
By
Ep NARS, Date 3-30-82
CONFIDENTIAL
MEMORANDUM FOR THE HONORABLE JOHN N. MITCHELL
FROM:
JEB S. MAGRUDER
The Sheraton Corporation has offered to purchase the inside
cover space for an ad in the convention program book. The
cost of this ad to Sheraton would be $25,000. It is our
understanding that Sheraton has also offered to purchase a
similar ad in the Democratic National Committee's program
book.
With your approval, I will advise Dick Herman that we should
accept the Sheraton offer and will run their ad on the in-
side cover of our convention program book
Approve
Disapprove
Comment
Or, should we advise Dick only to accept the Sheraton offer
if the DNC also accepts/
Approve
Disapprove
Comment
CONFIDENTIAL
COMMITTEE FOR THE RE-ELECTION OF THE PRESIDENT
1701 PENNSYLVANIA AVENUE N.W
March 24, 1972
WASHINGTON D. C 20006
(202) 333.0920
CONFIDENTIAL
MEMORANDUM FOR H. R. HALDEMAN
FROM:
JEB S. MAGRUDER
Attached for your information is a copy of a memorandum I
received from Bill Novelli on the development of advertising
directed to voter subgroups.
CONFIDENTIAL
Committee for the Re-election of the President
March 16, 1972
MEMORANDUM
TO:
ALEX ARMENDARIS
PAUL JONES
KEN RIETZ
DAN TODD
CLAYTON YEUTTER
FROM:
BILL NOVELLI
WDH
SUBJECT:
Development of Advertising, Directed to
Voter Subgroups.
1. Where Advertising Fits.
Advertising is one of several major tools in the overall
re-election campaign effort to maximize the President's
votes among specific voter groups.
Obviously, each part of the total effort must be coordinated
with the others in terms of objectives, strategy, and timing.
This overall coordination is best handled by the manager
responsible for each voter group.
Advertising
Government
Agency
Communications
MANAGER
Direct
Mail
OF
VOTER
Press/
GROUP
Public Relations
Field
Organization
ETC.
-2-
Advertising probably has more trouble breaking through to the
voter than messages that are not recognized as partisan, such
as a government agency announcement which reflects well on
the President. However, advertising's strength is its ability
to direct a specific, controlled message to a precise audience
with heavy repitition --- with the clear objective of voter
attitude change.
2. How Advertising Media Plans Will be Developed For Voter Groups
A. Where to Advertise - the first step is to determine where
advertising should be run, and at what media levels. This
will be done by determining which specific areas within key
states will be necessary to win that key state and its
electoral votes. Each state, each county and each ADI (Area
of Dominent Influence - a measurement of media coverage) will
be indexed in importance and potential using such criteria
as:
1 previous voting
ii current poll data indicating voting intentions
iii overall importance of the area in terms of electoral
votes.
iv any political considerations that are considered
significant by the Committee
Based on these indexes, the approximate media weight each area
will receive can be calculated.
B. Which Audiences In Each Area Will Receive Advertising.
Each area that is considered important enough to receive
substantial advertising weight will actually be subject to two
advertising campaigns. The first of these will be a mass
effort that will appeal to the great majority of voters.
The media strategy will be broad reach and coverage.
The second advertising campaign will be harmonious with the
mass audience effort, but will be specifically aimed at the
significant voter groups in the area. Each of these voter
groups will be evaluated in terms of:
i previous voting
ii size of group and its estimated percentage of
the total area's vote
iii potential to vote for the President.
A media program will then be designed for each voter group,
using the media that will reach these groups most efficiently
and effectively.
-3-
KEY STATE
MASS ADVERTISING CAMPAIGN
Young
Black
Older
Young
Spanish
Farm
Older
ETC.
Voter
Adver-
Voter
Voter
Adver-
Adver-
Voter
Adver-
tising
Adver-
Adver-
tising
tising
Adver-
tising
tising
tising
tising
(area 1)
(area 2)
(area 3)
(area 4)
3. How Advertising Messages Will Be Developed for Voter Groups
The next step is to determine what to say to each voter group to
whom advertising will be directed. This will be done as follows:
a. Analysis of voter group attitudes - how the people of a
specific group feel about various issues; how they feel
about the President, and his potential opponents, and
what special concerns they may have as a group.
b. Qualitative Concept Testing - using the information from
the analysis of group attitudes, focus group sessions will
be held to provide additional direction. This will lead
to the development of one or more possible creative concepts,
and perhaps some preliminary copy development.
C. Quantitative Concept Testing - now the concepts will be
checked through research using individual interviews and
a larger sample to be sure the copy strategy and concepts
have broad appeal and relevance.
d. Message Testing - Advertising (TV and radio commercials,
print advertisements) will be developed on the basis of
the concept research. Representative examples of this
advertising will then be tested to determine whether
they:
i communicate the creative strategy
ii are believable
iii contain issues/concerns that are still important
to the voter
iv contain any serious dislikes
V can provide additional direction for future copy.
e. At key stages in the development of both media plans and adver-
tising copy, the manager of the voter group will be asked for
-4-
comment and suggestions. Specifically, the advertising
group will want to know:
i based on his knowledge of his voter group and
his campaign organization, how does the voter
group manager assess the advertising?
ii How does the advertising fit in with the other
parts of the voter group campaign?
Also, the advertising group will periodically issue a status
report to each voter group manager which will outline the
timing and progress of copy and media development.
If you have any questions or comments regarding this program for adver-
tising to voter groups, please call.
CC:
Pete Dailey
Phil Joanou
Jeb Magruder
Mike Lesser
COMMITTEE FOR THE RE-ELECTION OF THE PRESIDENT
March 24, 1972
1701 PENNSYLVANIA AVENUE. N.W
WASHINGTON. D. C. 20006
(202) 333-0920
CONFIDENTIAL
MEMORANDUM FOR THE HONORABLE JOHN N. MICTHELL
FROM:
JEB S. MAGRUDER
SUBJECT:
Campaign Spending Law
The enclosed material on the new campaign spending law
was released today. I thought that you would be interested
in examing the documents.
Gordon Liddy has been given bese materials and others which
contain additional fine print. He will provide an analysis
on Monday. One of Liddy's reports will be for internal use
and the other for external use by people such as our state
chairmen.
CONFIDENTIAL
CLERK, U.S. HOUSE OF REPRESENTATIVES
WASHINGTON, D.C. 20515
MANUAL
of
REGULATIONS
and
ACCOUNTING INSTRUCTIONS
RELATING TO DISCLOSURE OF FEDERAL CAMPAIGN FUNDS FOR CANDI-
DATES FOR THE U.S. HOUSE OF REPRESENTATIVES AND POLITICAL
COMMITTEES SUPPORTING SUCH CANDIDATES
MARCH 1972
(This is an interim publication only. A revised edition containing the Comptroller Gen-
eral's Title I regulations, the Federal Communication Commission's guidelines, and the
Interstate Commerce Commission's, the Federal Communication Commission's, and the
Civil Aeronautic Board's credit regulations will be published when all such guidelines
and regulations become available.)
CLERK, U.S. HOUSE OF REPRESENTATIVES
WASHINGTON, D.C. 20515
MANUAL OF REGULATIONS AND ACCOUNTING INSTRUCTIONS RELATING
TO DISCLOSURE OF FEDERAL CAMPAIGN FUNDS FOR CANDIDATES
FOR THE U.S. HOUSE OF REPRESENTATIVES AND POLITICAL COM-
MITTEES SUPPORTING SUCH CANDIDATES
CONTENTS
A. Prescribed forms:
Page
Registration and statement of organization (committees only)
1
Reports of receipts and expenditures (committees, candidates, and
other persons)
1
B. Definitions:
Affiliated and connected organization
1
Calendar year
1
Clerk
2
File, filed, filing
2
Full name and name
2
Mailing address and address
2
Occupation and principal place of business, if any
2
Periodic reports
2
Preelection reports
2
C. Special instructions regarding registration statements and reports:
Personal responsibility
2
Committee officers
2
Special reports after closing of last preelection report
2
Waiver of filings
2
Waiver of reporting requirements
2
Identification number for committees
3
Changes and corrections
3
Notification of suspension, dissolution or termination
3
D. Accounting instructions:
Dates for closing books
3
Canceled check as receipt
3
Cash on hand
3
Contributed services
3
Disclosure of receipt and consumption of contributions in kind
4
Uniform identity of contributors
4
Allocation of expenditures among candidates
4
Manner of reporting debts, and contracts, agreements and promises to
make contributions or expenditures
4
Record of proceeds of events
4
Retained copies and records
4
Audits
5
E. Public inspection and copying of reports
5
F. Complaints of violations
5
(III)
REGULATIONS AND INSTRUCTIONS
The following regulations and instructions are issued by the Clerk of the U.S. House of Representatives
pursuant to Section 308 of the Federal Election Campaign Act.
A. PRESCRIBED FORMS
All statements and reports required to be filed to disclose receipts and expenditures made for the purpose
of influencing nominations or elections to the U.S. House of Representatives shall be filed on forms prescribed
by the Clerk. If statements or reports are required to be filed in connection with other Federal elections, they
shall be filed with each appropriate supervisory officer on the forms prescribed by that supervisory officer.
Such statements and reports and any changes or corrections thereto shall be typewritten or printed legibly
in ink. Use only black, blue or blue-black ribbon or ink.
Registration and Statement of Organization (Committees Only)
Each political committee which anticipates receiving contributions or making expenditures during a
calendar year in an aggregate amount exceeding $1,000, any portion of which will be expended for the purpose
of influencing the nomination or election of any candidate or candidates for the U.S. House of Representatives,
shall file a Statement of Organization with the Clerk within 10 days after the effective date of the Act, or
within 10 days after the organization of the committee, or within 10 days after the committee has information
which causes it to anticipate receiving such contributions or making such expenditures exceeding $1,000. No
political committee which is included within the scope of the Act shall be exempted from filing a Statement of
Organization with the Clerk by reason of being required to file also with another supervisory officer.
Reports of Receipts and Expenditures (Candidates, Committees and Other Persons)
Reports of Receipts and Expenditures required by the Act shall be filed with the Clerk by all candidates
for the U.S. House of Representatives and by those political committees which are required to file a Statement
of Organization with the Clerk and have not been granted a waiver of such reports.
Persons who make contributions or expenditures in support of a candidate for the U.S. House of
Representatives other than by contribution to a political committee or candidate, in an aggregate amount in
excess of $100 during a calendar year, shall report such contributions in the same manner as do committees,
as provided by Section 305 of the Act. Persons complying with this regulation may use the prescribed reporting
forms which have been issued for committees, substituting the person's name wherever the identification of a
committee is required by the form. Reports filed in compliance with this regulation need not be cumulative.
They shall be due on the same dates as are reports from candidates and committees except that persons com-
plying with Section 305 of the Act need file reports only for those reporting periods within which such direct
contributions or expenditures have been made.
B. DEFINITIONS
(See Section 301 of the Act for definitions of "election," "candidate," "Federal office," "political committee,"
"contribution," "expenditure," "supervisory officer," "person" and "State." See also Section 102 of the Act
for additional definitions under Title I.)
"Affiliated or Connected Organization" includes but is not limited to (a) an organization which organized
the reporting committee primarily for the purpose of influencing the nomination or election of candidates for
Federal office; or (b) an organization whose primary purpose is to support the reporting committee; or (c) an
organization whose membership is generally similar to that of the reporting committee.
"Calendar Year" for 1972, the first year during which the Act will be effective, means the period from
April 7, 1972, to and including December 31, 1972. No report is required to show any expenditure or contribution
which occurred before April 7, 1972, the effective date of the Act, except that any expenditure for communica-
tions media (as defined in Title I of the Federal Election Campaign Act) used on or after April 7, 1972, shall
(1)
2
be charged against the candidate's expenditure limitation applicable to the election for which it was used, re-
gardless of when the use is paid for or contracted for. For further information concerning communications
media spending, refer to the Comptroller General's Regulations on Title I of the Act.
"Clerk" means Clerk of the U.S. House of Representatives.
"File," "Filed," and "Filing" mean delivery to the Clerk of the U.S. House of Representatives, Wash-
ington, D.C., by midnight of the prescribed filing date, or deposit as certified air mail, in an established U.S.
Post Office, postage prepaid, no later than midnight of the second day next preceding the filing date. Certified
mail receipt shall be retained as evidence of mailing. Documents deposited within 500 miles of Washington,
D.C., need not be sent by air mail but shall be certified. In the event the mailing deadline falls on a day in which
no mail is certified, the next preceding day on which mail is certified shall be deemed the mailing date. All reports
may be deposited in preprinted return envelopes supplied by the Clerk, bearing a declaration of contents and
requesting priority handling. In the event a report is too large to be inserted in the preprinted envelope, it
should be packaged separately but the whole face of the preprinted envelope may be used as a mailing label.
(See separate requirement for filing under "Complaints of Violations.")
"Full Name" and "Name" mean identification of the person usually given for business purposes.
"Mailing Address" and "Address" mean building number, street, city, State, and ZIP code.
"Occupation and Principal Place of Business, if any" means, if self-employed, type of work or profession
and city where self-employed; or, if employed, type of work or title, name of employer or employing organiza-
tion and city of employment.
"Periodic Reports" mean those reports of receipts and expenditures which shall be filed on the tenth
day of March, June and September and no later than the thirty-first day of January.
"Preelection Reports" mean those reports of receipts and expenditures which shall be filed on the fifteenth
and fifth days next preceding an election.
C. SPECIAL INSTRUCTIONS REGARDING REGISTRATION STATEMENTS AND REPORTS
Personal Responsibility
Any person required to file a statement, report or other document with the Clerk under the Act shall be
personally responsible for the timely filing of a complete and accurate statement, report, or document.
Committee Officers
Every political committee shall have a chairman and a treasurer, who shall be separate individuals. No
contributions and no expenditure shall be accepted or made by or on behalf of a political committee at a time
when there is a vacancy in the office of chairman or treasurer thereof. No expenditure shall be made for or on
behalf of a political committee without the authorization of its chairman or treasurer or the designated agents.
Special Reports After Closing of Last Preelection Report
Any contribution of $5,000 or more (including a transfer of funds from a candidate or committee) which
is received after the closing date prescribed for books for the last report prior to an election shall be separately
reported within 48 hours after its receipt. Such contribution shall be reported to the Clerk by telegraph or
hand delivered letter giving the date and amount of contribution and the full name and mailing address (occupa-
tion and principal place of business, if any) of the contributor. All such contributions shall also be declared in the
next periodic or preelection report due under the Act.
Waiver of Filings
If a periodic report is due on or within 10 days of the filing date for a preelection report, the filing of the
preelection report shall fulfill both requirements and shall be so indicated on the report form.
Waiver of Reporting Requirements
Any political committee required to file reports with the Clerk may be relieved of the duty to comply
with such requirements if all of the following conditions are satisfied-
(1) the committee is a local, city, or county committee and does not conduct its activities through-
out the State or in any other State; and
3
(2) the committee primarily supports persons seeking State or local office; and
(3) the committee does not make contributions or expenditures in support of a candidate for election
to the U.S. House of Representatives in an aggregate amount exceeding $1,000 in a calendar year.
Upon receipt of such Statement of Organization from a committee that meets all of the above three require-
ments, the Clerk will grant a waiver and SO advise the reporting committee. Such waiver shall continue only
for such time as all of the three above conditions are satisfied.
Identification Number for Committees
Upon receipt of a Statement of Organization, the Clerk shall assign an identification number to the register-
ing committee, acknowledge receipt thereof and notify the political committee of the number assigned. This
identification number shall be entered by the political committee on all subsequent statements or reports filed
with the Clerk under the Act, as well as on all communications concerning such statements or reports.
Changes and Corrections
Any change in information previously submitted in a Statement of Organization, and any correction
to a statement or report shall be reported to the Clerk within 10 days following the date of the event prompt-
ing such change or correction. The change or correction shall be reported by letter in the same manner as was
the information previously submitted, shall identify the form and the paragraph or schedule containing the
information to be changed or corrected, and shall be verified by oath or affirmation by the person required by
law to submit such information at the time the change or correction is reported.
Notification of Suspension, Dissolution or Termination
Any committee which, after having filed one or more Statements of Organization with the Clerk, disbands
or determines that it will no longer receive contributions or make expenditures during the calendar year in an
aggregate amount exceeding $1,000, shall so notify the Clerk. Such notification shall include a termination
report and a statement as to the disposition of residual funds if the committee is disbanding and shall be verified
by oath or affirmation and filed in the same manner as the Statement of Organization. Candidates for the
U.S. House of Representatives shall continue to file Reports of Receipts and Expenditures for as long as they
continue to be a candidate and receive contributions or make expenditures following an election. When they
cease to be a candidate or when they cease to receive contributions or make expenditures after an election they
shall file a termination report that covers the period from the closing date of the last previous report filed
through the date of termination.
D. ACCOUNTING INSTRUCTIONS
Dates for Closing Books
Reports of receipts and expenditures due on the 15th day next preceding an election shall be complete as
of midnight of the 22nd day next preceding such election. Reports of receipts and expenditures due on the 5th day
next preceding an election shall be complete as of midnight of the 12th day next preceding such election. Re-
ports of receipts and expenditures due on the 10th day of the months of March, June and September and by the
31st day of January shall be complete as of midnight of the last day of the preceding month. All such reports
shall be cumulative and shall cover the period from the closing date of the last previous report filed.
Cancelled Check as Receipt
A cancelled check showing payment of a bill, together with the bill or invoice stating the purpose of the
expenditure, shall be deemed to be a receipted bill.
Cash on Hand
Cash includes but is not limited to money, balances on deposit in banks and savings and loan institutions,
checks, negotiable money orders and other paper commonly accepted by a bank in a deposit of cash, and cash
funds in other repositories.
Contributed Services
Services which a person is paid to perform or which are performed in lieu of regular duties for such person's
employer, are not deemed to be voluntary services and should be reported and identified as a contribution in
kind.
4
Disclosure of Receipt and Consumption of Contributions in Kind
Each contribution in kind shall be declared at fair market value and reported on the appropriate schedule
of receipts, identified as to its nature and li-ted as "contribution in kind." The total amount of goods and
services contributed in kind shall be deemed to have been consumed in the reporting period in which received.
Each such contribution shall be declared as an expenditure at the same fair market value and reported on the
appropriate expenditure schedule, identified as "contribution in kind." (For exceptions concerning broadcast
time donated to a candidate under the provisions of the Communications Act of 1934, see the guidelines of the
Federal Communications Commission.)
Uniform Identity of Contributors
In determining the aggregate of a person's contributions, the treasurer or candidate shall list contributions
from the same donor under the same name. In each instance when a contribution received from a person in a
reporting period is added to previously reported unitemized contributions from the same contributor and the
aggregate exceeds $100 within the calendar year, the name and address (occupation and principal place of
business, if any) of that contributor shall then be listed on the prescribed reporting forms. In addition, any
subsequent contribution(s) received from a contributor who has previously been reported within the calendar
year shall be listed on the prescribed reporting forms using the same name as previously reported.
Allocation of Expenditures Among Candidates
A political committee making an expenditure for or on behalf of more than one candidate for Federal,
State or local office shall allocate the expenditures among such candidates on a reasonable basis and report this
allocation for each Federal candidate on the prescribed form to each appropriate supervisory officer. The
treasurer shall retain for audit any documents supporting the allocation.
Allocations of expenditures for the use of communications media shall ,comply with the provisions of the
Comptroller General's Regulations on Title I of the Act.
Manner of Reporting Debts and Contracts, Agreements, and Promises to Make Contributions or Expenditures
Every contribution and expenditure in the nature of a debt incurred, or a contract, agreement, or promise
to make a contribution or expenditure entered into on or after April 7, 1972, which is in writing and exceeds the
amount of $100, shall be reported in separate schedules on the reporting forms prescribed by the Clerk until such
debts, contracts, agreements, or promises are paid, liquidated, cancelled, forgiven or otherwise extinguished.
Such debts, contracts, agreements and promises shall not be considered as part of the totals of receipts or ex-
penditures until actual payment is made.
Records of Proceeds of Events
The treasurer of each political committee and each candidate shall keep full and complete records of
proceeds from the sale of tickets and mass collections at each dinner, luncheon, rally, and other fundraising event,
and such records shall include the date, amount of proceeds, location and nature of each event, and an itemized
list of individuals who purchased tickets within the calendar year in an amount (aggregate) in excess of $100.
They shall also keep full and complete records of the proceeds from the sale of items such as political campaign
pins, buttons, badges, flags, emblems, hats, banners, literature and similar materials.
Retained Copies and Records
Every candidate, political committee, or other person filing a statement or report with the Clerk under
the Act shall preserve a copy of each statement or report for a period of not less than two years from the
date of filing.
Every person required to file any report or statement with the Clerk shall maintain records on the matters
required to be reported including vouchers, cancelled checks, bills, invoices, worksheets, and receipts, which will
provide in sufficient detail the necessary information and data from which the filed statements and reports may
be verified, explained or clarified, and checked for accuracy and completeness, and he shall keep such records
available for audit, inspection or examination by the Clerk, or his authorized representatives, for a period of not
less than two years from the date of filing of the statements or reports or changes or corrections thereto.
5
Audits
Audits and field investigations may be made as directed by the Clerk. All candidates, political committees
and other persons required to file reports under these Regulations shall keep adequate books and records. Such
books and records shall be maintained on a current basis and shall be made available for inspection and audit
by the Clerk or his authorized representatives.
E. PUBLIC INSPECTION AND COPYING OF REPORTS
Statements and reports filed with the Clerk under the Act will be made available in the Office of Records
and Registration, Room 1036, Longworth House Office Building, Washington, D.C., for inspection and
copying by any person, commencing as soon as practicable after receipt but, in any case, not later than the end
of the second day following the day of receipt.
A list of general rules with respect to the inspection and copying of documents, and a schedule of charges
for copies as authorized by the Act shall be posted in the Office of Records and Registration of the Clerk.
Any information copied or obtained from statements and reports shall not be sold or used by any person
for the purpose of soliciting contributions or for any commercial purpose. For purposes of this regulation, "any
commercial purpose" means any sale, trade, or barter of any list of names or addresses taken from such state-
ments and reports and any use of any such lists for any surveys or sales promotion activity. For purposes of
this regulation, "soliciting contributions" means requesting gifts or donations of money, or anything of value
for any cause or organization-political, social, charitable, religious, or otherwise. Violations of this sub-
section are subject to the criminal penalties provided in section 311 of the Act.
F. COMPLAINTS OF VIOLATIONS
Any person who believes a violation of Title III of the Act or of these Regulations has occurred which is
within the jurisdiction of the Clerk, may file a written complaint in person or by registered or certified mail
with the Clerk. When a complaint is received, it shall be stamped to show the date and time of receipt, and
acknowledged by registered or certified mail.
There is no prescribed form for a complaint, but all complaints shall be typewritten or handwritten legibly
in ink. The name and address of the person making the complaint shall be typewritten or hand printed on the
complaint, and it shall be signed by such person and verified by the oath or affirmation of such person, taken
before any officer authorized to administer oaths. A complaint shall name the alleged violator, describe in detail
the alleged violation and shall be submitted together with any evidentiary material. Complaints will not be
available for public inspection or copying.
No investigation shall be required if a complaint is frivolous on its face, illegible, too indefinite, does not
identify any violator, is unsigned or is not notarized.
TUESDAY, MARCH 21, 1972
WASHINGTON, D.C.
Volume 37 . Number 55
PART II
NATIONAL ARCHIVES OF THE UNITED
THE * 1934 SHIPS
FEDERAL
COMMUNICATIONS
COMMISSION
Use of Broadcast and Cable-
cast Facilities by Candidates
for Public Office
(Public Notice of March 16, 1972)
No. 55-,Pt. II--1
5796
NOTICES
FEDERAL COMMUNICATIONS
The guidelines are being issued in re-
valid for and should be followed in cases
sponse to a host of inquiries raised by
involving disputes about other matters
COMMISSION
members of the broadcast and cable in-
such as whether a candidate was charged
dustries, and others, as to the implica-
the proper rates, or whether he was al-
tions of the amended sections 312 and
[FCC 72-231]
lowed reasonable access to a station or
315. Their preparation has involved the
whether he was permitted to purchase
USE OF BROADCAST AND CABLECAST
Commission in some extremely difficult
reasonable amounts of time. In such
FACILITIES
decisions as to congressional intent con-
cases, of course, the detailed statement of
cerning various aspects of the amend-
the complainant called for in (iii) of the
Candidates for Public Office
ments. Their release is viewed as being
penultimate paragraph of the complaint
MARCH 16, 1972.
in the public interest and consistent with
procedures in the 1970 primer should be
On August 7, 1970, the Commission
the position taken in the 1970 primer
modified to fit the particular complaint.
issued a Public Notice entitled "Use of
where we said (24 F.C.C. 2d 832, 885):
To make use of the guidelines easier,
Broadcast Facilities by Candidates for
In response to general inquiries the Com-
they are preceded by title I of the Fed-
Public Office" (24 F.C.C. 2d 832). That
mission limits Itself to giving general guide-
eral Election Campaign Act of 1971
notice, the so-called "Political Broadcast
lines to help an individual or station de-
which amends sections 312 and 315 of the
Primer," consisted of a compilation of
termine their rights and obligations under
Communications Act; sections 312 and
section 315.
the Commission's interpretive rulings
315 as they presently read and as
under section 315 of the Communications
Broadly speaking, the guidelines deal
amended; and the Commission's rules
Act of 1934, as amended, and the Com-
with four areas: (1) Definition of "legally
governing political broadcasts and cable-
mission's rules implementing that sec-
qualified candidate," (2) rates to be
casts. Insofar as the Commission's spon-
tion of the Act. It superseded all similar
charged for use of a station by candi-
sorship identification rules are pertinent
primers that had been previously issued.
dates, (3) certifications stations are re-
to this subject the reader is referred to
Since then, additional interpretive rul-
quired to obtain from candidates, and
the 1970 primer (24 F.C.C. 2d 832, 837-8).
ings have been issued from time to time
(4) allowing reasonable access to or per-
The immediately following section con-
and published in the FCC Reports. The
mitting purchase of reasonable amounts
tains title I of the Federal Election Cam-
rulings in the 1970 primer and thereafter
of time by candidates for Federal elec-
paign Act of 1971.
apply both to political programs over
tive office.
I-THE NEW LAW
broadcast stations and those originated
In some cases, the guidelines supple-
by cable television systems (CATV
ment present Commission rules governing
TITLE I-CAMPAIGN COMMUNICATIONS
systems).
political broadcasts and the interpretive
SHORT TITLE
On February 7. 1972. the Federal Elec-
rulings of the 1970 primer and there-
tion Campaign Act of 1971 was enacted
after. In other cases they are inconsistent
SEC. 101. This. title may be cited as the
"Campaign Communications Reform Act."
(Public Law 92-225) It amends sections
with them. Effective April 7, 1972, any
312 and 315 of the Communications Act,
inconsistencies between the rules, the
DEFINITIONS
effective April 7. 1972.
that
1970 primer, and rulings since 1970 on the
SEC. 102. For purposes of this title:
the amended sections applicable to
one hand. and these guidelines on the
(1) The term "communications media"
all political broadcasts or CATV cable-
other, will be resolved in favor of the
means broadcasting stations, newspapers,
guidelines. Generally the guidelines high-
magazines, outdoor advertising facilities, and
casts mations) made on or
light any inconsistencies by referring to
telephones; but, with respect to telephones,
after April 7, whether free or purchased,
the appropriate section of the rules, perti-
spending or an expenditure shall be deemed
and whether contracted for prior to that
to be spending or an expenditure for the use
date or not. The purpose of the present
nent questions in the 1970 primer, or
of communications media only if such spend-
Public Notice is to furnish guidelines
rulings made since the issuance of the
ing or expenditure is for the costs of tele-
apprising broadcast station licensees,
primer. It is our intent to amend the rules
phones, paid telephonists, and automatic
CATV operators, candidates, and other
in the future to accommodate the
telephone equipment, used by a candidate for
interested persons of their respective re-
changes in sections 312 and 315. We do
Federal elective office to communicate with
sponsibilities and rights under the
not presently envisage the issuance in the
potential voters (excluding any costs of tele-
amended sections. These guidelines are
near future of a new primer to replace
phones incurred by a volunteer for use of
that of 1970. However, as experience ac-
telephones by him).
being issued by the Commission after
(2) The term "broadcasting station" has
careful study of the legislative history
crues, we may find it necessary to modify
the same meaning as such term has under
underlying the amendments, and, like
the present guidelines, or to issue new
section 315(f) of the Communications Act of
ones as new problems arise. Some ques-
1934.
the 1970 primer, are issued in question
tions are intentionally not raised in the
(3) The term "Federal elective office"
and-answer format.¹
guidelines since they would best be
means the office of President of the United
handled on a case-by-case basis.
States, or of Senator or Representative in,
1 The Federal Election Campaign Act of
The recommended complaint proce-
or Resident Commissioner or Delegate to,
the Congress of the United States (and for
1971 consists of four titles. The amendments
dures set forth in the 1970 primer (24
purposes of section 103(b) such term includes
to the Communications Act are in title I.
F.C.C. 2d 832, 834-5) were written largely
the office of Vice President).
Other provisions in the new law include limi-
for the purpose of dealing with requests
(4) The term "legally qualified candidate"
tations on the amount that a candidate for
for "equal opportunity" under the pro-
means any person who (A) meets the quali-
Federal elective office may spend for the use
visions of section 315. However, they are
fications prescribed by the applicable laws to
of communications media on behalf of his
hold the Federal elective office for which he is
candidacy, limitations on the expenditures
a candidate, and (B) is eligible under appli-
that such candidates may make from their
rules on the subject, which must be done
cable State law to be voted for by the elec-
personal funds or the funds of their Imme-
by May 7, 1972. The Commission will soon
torate directly or by means of delegates or
diate families in connection with their cam-
issue a Notice of Proposed Rule Making in
electors.
paigns, and requirements of detailed report-
regard to this.
ing by political committees and candidates
The amended sections 312 and 315 apply
(5) The term "voting age population"
of the sources and uses of campaign funds.
to both broadcast stations and cable televi-
means resident population, eighteen years of
Regulations issued by the Comptroller Gen-
sion systems, except that, as the "reasonable
age and older.
eral under titles I and III, by the Secre-
access" guidelines indicate, cable systems
(b) The term "State" includes the District
tary of the Senate under title III, and by
that lack cablecasting facilities and are not
of Columbia and the Commonwealth of
the Clerk of the House of Representatives
required by the Commission's rules to have
Puerto Rico.
under title III, implement those provisions
them need not provide such facilities pur-
MEDIA RATE AND RELATED REQUIREMENTS
and also serve to supplement these guidelines.
suant to section 312(a) (7). Therefore, as was
Title IV pertains to extension of credit to
the case with the 1970 primer, the guidelines
SEC. 103. (a) (1) Section 315(b) of the Com-
candidates for Federal elective office, without
are applicable to both broadcast stations and
munications Act of 1934 is amended to read
security, by the communications and trans-
cable television systems References to "sta-
as follows:
portation industries. That title does not be-
tions" and "licensees" include "cable televi-
"(b) The charges made for the use of any
come effective with regard to the communica-
sion systems" and "cable television system
broadcasting station by any person who is
tions industry until the FCC promulgates
operators."
a legally qualified candidate for any public
FEDERAL REGISTER, VOL. 37, NO. 55-TUESDAY, MARCH 21, 1972
NOTICES
5797
office in connection with his campaign for
office of Delegate or Resident Commissioner
(B) Any expenditure for the use of any
nomination for election, or election, to such
in the case of the District of Columbia or
communications medium by or on behalf of
office shall not exceed-
the Comunon wealth of Puerto Rico).
the candidacy of a candidate for Federal
"(1) During the forty-five days preceding
(B) For purposes of this paragraph (3), a
elective office (or nomination thereto) shall
the date or a primary or primary rubert eles-
person is & candidate for presidential nomi-
be charged against the expenditure limita-
tion and during the sixty days preceding
nation if be Inakes (or any other person
tion under this subsection applicable to the
the date of a general or special election in
makes on his behalf) an expenditure for the
election in which such medium is used.
which such person is 8 cand.date, the lowest
use of any commrunications medium on be-
(b) No person may make any charge for
unit charge of the station for the same
half of his candidacy for any political party's
the use by or on behalf of any legally
class and amount of time for the same pe-
nomination for election to the office of Pres-
qualified candidate for Federal elective office
riod: and
ident. He shall be considered to be such a
(or for nomination to such office) of any
"(2) At any other time, the charges made
candidate during the period-
newspaper, magazine, or outdoor advertising
for compa able use of such station by other
(1) B sinning on the date on which he (or
facility. unless such candidate (or PL person
users thereof."
such other person) first makes such an ex-
specifically authorized by such condidate in
(2) (A) Section 312(a) of such Act is
penditure (or, if later, January 1 of the year
writing to do so) certifies in writing to the
amended by striking "or" at the end of clause
in which the election for the office of Presi-
person making such charge that the pay-
(5), striking the period at the end of clause
dent is held). and
ment of such charge will not violate para-
(6) and inserting in lieu thereof a semicolon
(ii) Ending on the date on which such
graph (1), (2), or (3) of subsection (a),
and "or", and adding at the end of such
political party nominates a candidate for the
whichever is applicable.
section 312(a) the following new paragraph:
office of President.
(c) Section 315 of the Communications
"(7) For wilful or repeated failure to allow
For purposes of this title and of section 315
Act of 1934 is amended by redesignating
reasonable C. is or to permit purchase
of the Communications Act of 1934, a candi-
subsection (c) as subsection (g) and by in-
of recemable amounts of time for the use
date for presidential nomination shall be
serting after subsection (b) the following
of a broadcasting station by 3 legally quali-
new subsections:
fied condiders for Federal elective office on
considered a legally qualified candidate for
public office.
"(c) No station licensee may make any
behalf of his candidacy.".
(R) The record sentence of section 315(a)
(C) The Comptroller General shall pre-
charge for the use of such station by or on
seribe regulations under which any expendi-
behalf of any legally qualified candidate for
of such Act 18- amended by inserving "under
Federal elective office (or for nomination to
this subsection" after "No obligation is
ture by is candidate for presidential nomina-
tion for the use in two or more States of &
such office) unless such candidate (or a
imposse".
communications medium shall be attributed
person specifically authorized by such candi-
(b) To the extent that any person sells
to such candidate's expenditure limitation
date in writing to do 50) certifies to such
space in any newspaper or magazine to a
in each such State, besed on the number of
licensee in writing that the payment of
legally qualified candidate for Federal elec-
tive office, or nomination thereto. in connec-
persons to such State who can reasonably
such charge will not violate any limitation
tion with such candidate's campaign for
be expensed to be reached by such communi-
specified in paragraph (1), (2), or (3) of
casions medium.
section 104(a) of the Campaign Communi-
nomination for, or election to, such office,
(4) (A) For purposes of subparagraph (B)
cations Reform Act, whichever paragraph is
the charges made for the use of such space
(1) The term "price index" means the
applicable.
in connection with bis campaign shall not
average over a calendar year of the Con-
(d) If a State by law and expressly-
exceed the charges made for comparable
summer Price Indes (all items-U.S. city
"N) Has provided that a primary or other
use of such space for other purposes.
average) published monthly by the Bureau
election for any office ef such State or of a
LIMITATIONS OF EXPENDITCHES FOR USE CF
of Labor Statistics.
political subdivision thereof is subject to
this subsection.
COMMUNICATIONS MEDIA
(11) The term "base period" means the
calendar year 1970.
"(2) Has specified a limitation upon total
Enc. 101. (a) (1) Subject to parseraph (4),
(2) At the beginning of each calender year
expenditures for the use of broadcasting
no legally qualified candidate in an election
(commencing in 1972), as there becomes
stations on behalf of the candidecy of each
(other than a primary or primary runoff
election) for D Faderal elentive office may-
available necessary data from the Bureau of
legally qualified candidate in such election,
Labor Stesistics of the Department of Labor,
(3) Has provided in any such law an
(A) spend for the USE of covemunications
media on behalf of his candidacy in such
the Secretary of Labor chall certify to the
unequivocal expression of intent to be bound
Compuroller General and publish in the FED-
by the provisions of this subsection, and
election D. total amount in excess of the
greater of-
ERAL RECISTER the per centum difference be-
"(4) Has stipulated that the amount of
such limitation shall not exceed the amount
(1) 10 cents multiplied by the voting age
tween the price index for the 12 months pre-
which would be determined for such elec-
population (as certified under paragraph (5))
ceding the beginning of such calendar year
and the price index for the base period. Each
tion under section 104(a) (1) (B) or 104(a)
of the geographical area in which the elec-
amount determined under paragraph (1)
(2) (B) (whichever is applicable) of the Cam-
tion for such office is held, or
(A) (1) and (ii) shall be increased by such
paign Communications Reform Act had such
(ii) $50,000, OF
election been an election for a Federal elec-
(B) Spend for the use of broadcast sta-
per centum difference. Each amount SO in-
tions on bahalf of his candidacy in such elec-
creased shall be the amount in effect for
tive office or nomination thereto;
tion a total amount in excess of GO per
such calender year.
Then no station licensee may make any
centure a the amount determined under
(5) Within 60 days after the date of
charge for the use of such station by or on
subparagraph (A) with respect to such
enactment of this Act, and during the first
behalf of any legally qualified candidate in
election.
week of January in 1973 and every subse-
such election unless such candidate (or a
(2) No legally qualified candidate in a
quent year, the Secretary of Commerce shall
person specifically authorized by such candi-
primary election for nomination to a Federal
certify to the Comptroller General and pub-
date in writing to do so) certifies to such
elective office, other than President, may
11sh in the FEDERAL REGISTER an estimate of
licensee in writing that the payment of such
spend-
the voting age population of each State and
charge will not violate such State limitation.
(A) For the use of communications media,
congressional district for the last calendar
"(e) Whoever willfully and knowingly
or
year ending before the date of certification.
violates the provisions of subsection (c) or
(B) For the use of broadcast stations,
(6) Amounts spent for the use of com-
(d) of this section shall be punished by a
munications media on behalf of any legally
fine not to exceed $5,000 or imprisonment
on behalf of his candidacy in such election
qualified candidate for Federal elective office
for a period not to exceed 6 years, or both.
a total amount in excess of the amounts de-
(or for nomination to such office) shall, for
The provisions of sections 501 through 503
termined under paragraph (1) (A) or (B),
the purposes of this subsection, be deemed
of this Act shall not apply to violations of
respectively, with respect to the general elec-
to have been spent by such candidate.
either such subsection.
tion for such office. For purposes of this
Amounts spent for the use of communications
subsection & primary runoff election shall
"(f) (1) For the purposes of this section:
media by or on behalf of any legally qualified
be treated as a separate primary election.
candidate for the office of Vice President
"(A) The term 'broadcasting station' in-
(3) (A) No person who 19 a candidate for
of the United States shall, for the purposes
cludes a community antenna television
presidential nomination may spend-
of this section, be deemed to have been spent
system.
(1) For the use in a State of communica-
by the candidate for the office of President
"(B) The terms 'licensee' and 'station
tions media, or
of the United States with whom he is
licensee' when used with respect to a com-
(ii) For the use in a State of broadcast
running.
munity antenna television system, means the
stations,
(7) For purposes of this section and sec-
operator of such system.
tion 315(c) of the Communications Act of
"(C) The term 'Federal elective office'
on behalf of his candidacy for presidential
1934-
means the office of the President of the
nomination a total amount in excess of the
(A) spending and charges for the use of
United States, or of Senator or Representa-
amounts which would have been determined
communications media include not only the
tive in, or Resident Commissioner or Dele-
under graph (2) (A) OF (5), respectively,
direct charges of the media but also agents
gate to, the Congress of the United States.
had he been a candidate for election for the
commissions allowed the agent by the media,
"(2) For purposes of subsections (c) and
office of Senstor from such State (or for the
and
(d), the term legally qualified candidate"
FEDERAL REGISTER, VOL 37, NO. 55-TUESDAY, MARCH 21, 1972
5798
NOTICES
means any person who (A) meets the qualifi-
matter added by Act is that printed in
(3) Has provided in any such law an un-
cations prescribed by the applicable laws to
italic):
equivocal expression of intent to be bound
hold the office for which he 13 a candidate
Sec. 315, (a) If any licensee shall permit
by the provisions of this subscction, and
and (B) Is eligible under applicable State
any person who is a legally qualified candi-
(4) Has stipulated that the amount of
law to be voted for by the electorate directly
or by nicans of delegates or electors."
date for any public office to use a broadcast-
such limitation shall not erceed the amount
ing station, he shall afford equal opportuni-
which would be determined for such elec-
REGULATIONS
ties to all other such candidates for that
tion under section 104(a) (1) (B) or 104(a)
office in the use of such broadcasting sta-
(2) (B) (whichever is applicable) of the Cani-
SEC. 105. The Comptroller General shall
tion: Provided," That such licensee shall have
paign Communications Reform Act had such
prescribe such regulations as may be neces-
election been an election for a Federal elec-
sary or appropriate to carry out sections 102,
no power of censorship over the material
tive office or nomination thereto,
103(b), 104(a). and 104(b) of this Act.
broadcast under the provisions of this sec-
tion. No obligation is hereby imposed under
then no station licensee may take any charge
FENALTIES
this subsection upon any licensee to allow
for the use of such station by or on behalf
SEC. 106. Whoever willfully and knowingly
the use of its station by any such candidate.
of any legally qualified candidate in such
violates any provision of section 103(b).
Appearance by a legally qualified candidate
election unless such candidate (or a person
104(a), or 104(b) or any regulation under
on any-
specifically authorized by such candidate in
section 105 shall be punished by a fine of
(1) Bona fide newscast,
writing to do so) certifies to such licensee
not more than $5,000 or by imprisonment
(2) Bona fide news interview,
in writing that the payment of such charge
of not more than 5 years, or both.
(3) Bona fide news documentary (if the
will not violate such State limitation.
appearance of the candidate is incidental to
(e) Whoever willfully and knowingly vio-
For purposes of clarification, sections
the presentation of the subject or subjects
lates the provisions of subsection (c) or (d)
II and III of this public notice set forth
covered by the news documentary), or
of this section shall be punished by a fine
the new language of sections 312(a) and
(4) On-the-spot coverage of bona fide
not to exceed $5,000 or imprisonment for a
315 of the Communications Act as
news events (included but not limited to
period not to exceed five years, or both. The
amended in accordance with Title I of
political conventions and activities incidental
provisions of sections 501 through 503 of this
thereto),
the Federal Election Campaign Act of
Act shall not apply to violations of either
such subsection
1971. Section IV sets forth the language
shall not be deemed to be use of a broad-
(f) (1) For the purposes of this section:
of the Commission's present rules gov-
casting station within the meaning of this
erning political broadcasting.
subsection. Nothing in the foregoing sen-
(A) The term 'broadeasting station' in-
tence shall be construed as relieving broad-
cludes a community antenna television
system.
II-SECTION 312(a) OF THE
casters, in connection with the presentation
(B) The terms 'licensee' and 'station li-
COMMUNICATIONS ACT (AS AMENDED)
of newscasts, news interviews, news docu-
censee' when used with respect to a com-
mentaries, and on-the-spot coverage of news
Effective April 7. 1972, section 312(a)
events, from the obligation imposed upon
munity antenna television system, means the
of the Communications Act of 1934 will
operator of such system.
them under this Act to operate in the public
read as follows (previously existing law
interest and to afford reasonable opportunity
(C) The term 'Federal elective office'
means the office of President of the United
which will remain unchanged is shown in
for the discussion of confiicting views on
issues of public importance.
States, or of Senator or Representative in.
roman: previously existing matter de-
leted by the Campaign Communications
[(b) The charges made for the use of any
or Resident Commissioner or Delegate to, the
Congress of the United States.
broadcasting station for any of the purposes
Reform Act is enclosed in brackets: new
set forth in this section shall not exceed the
(2) For purposes of subsections (c) and
matter added by the Campaign Commu-
(d), the term "legally qualified candidate'
charges made for comparable use of such sta-
nications Reform Act is, printed in
tion for other purposes.]
means any person who (A) meets the quali-
(b) The charges made for the use of any
fications prescribed by the applicable laws
italic):
to hold the office for which he is a candidate
broadcast station by any person who is
a
SEC. 312. (a) The Commission may revoke
legally qualified candidate for any public
and (B) is eligible under applicable State
any station license or construction permit-
office in connection with his campaign for
law to be voted for by the electorate directly
(1) For false statements knowingly made
nomination for election, or election, to such
or by means of delegates or electors.
either in the application or in any statement
office shall not exceed-
((c) The Commission shall prescribe
of fact which may be required pursuant to
(1) During the 45 days preceding the date
appropriate rules and regulations to carry
section 308;
out the provisions of this section.
of a primary or primary runoff election and
(2) Because of conditions coming to the
during the 60 days preceding the date of a
IV-THE COMMISSION'S RULES AND REGU-
attention of the Commission which would
general or special election in which such per-
LATIONS WITH RESPECT TO POLITICAL
warrant it in refusing to grant a license
son is a candidate, the lowest unit charge
BROADCASTS AND CABLECASTS
of permit on an original application;
of the station for the same class and amount
(3) For willful or repeated failure to oper-
of time for the same period; and
The Commission's present rules and
ate substantially as set forth in the license:
(2) At any other time, the charges made
regulations with respect to political
(4) For willful or repeated violation of,
for comparable use of such station by other
broadcasts coming within section 315 of
users thereof.
or willful or repeated failure to observe any
the Communications Act are set forth in
provision of this Act or any rule or regula-
(c) No station licensee may make any
tion of the Commission authorized by this
charge for the use of such station by or on
$8 73.120 (AM), 73.290 (FM), 73.590
behalf of any legally qualified candidate for
(noncommercial educational FM), and
Act or by a treaty ratified by the United
Federal elective office (or for nomination to
73.657 (TV), respectively. These provi-
States;
such office) unless such candidate (or a per-
sions are identical (except for elimina-
(5) For violation of or failure to observe
son specifically authorized by such candidate
tion of any discussion of charges in
any final cease and desist order issued by the
in writing to do so) certifies to such licensee
§ 73.590 relating to noncommercial edu-
Commission under this section; [or]
in writing that the payment of such charge
cational FM stations) and read as
(6) For violation of section 1304, 1343, or
will not violate any limitation specified in
follows:
1464 of title 18 of the United States Code [.];
paragraph (1), (2), or (3) of section 104(a)
or
of the Campaign Communications Reform
Broadcasts by.candidates for public office-
(7) For willful or repeated failure to allow
Act, whichever paragraph is applicable.
(a) Definitions. A "legally qualified candl-
reasonable access to or to permit purchase
(d) If a State by law and expressly-
date" means any person who has publicly
of reasonable amounts of time for the use
(1) Has provided that a primary or other
announced that he is R candidate for nomi-
of a broadcasting station by a legally quali-
election for any office of such State or of a
nation by a convention of a political party
fied candidate for Federal elective office on
political subdivision thereof is subject to this
or for nomination or election in a primary.
behalf of his candidacy.
subsection,
special, or general election, municipal,
(2) Has specified a limitation upon total
county, State or national, and who meets the
III-SECTION 315 OF THE
expenditures for the use of broadcasting sta-
qualifications prescribed by the applicable
COMMUNICATIONS ACT (AS AMENDED)
laws to hold the office for which he is a can-
tions on behalf of the candidacy of each
Effective April 7, 1972, section 315 of
legally qualified candidate in such election,
didate, so that he may be voted for by the
electorate directly or by means of delegates
the Communications Act of 1934 will read
or electors, and who:
as follows (previously existing law which
This word, although italicized, is not new
(1) Has qualified for a place on the ballot
will remain unchanged is shown in
matter. It appears in italic in the present
or
roman; previously existing law deleted
law and remains in italic in the new law.
(2) Is eligible under the applicable law to
*The word hereby is not included in the
be voted for by sticker, by writing in his
by the Campaign Communications Re-
United States Code (47 U.S.C. 315) but ap-
name on the ballot, or other method. and
form Act is enclosed in brackets; new
pears in the Statutes at Large (66 Stat. 717).
(1) has been duly nominated by a political
FEDERAL REGISTER, VOL. 37, NO. 55-TUESDAY, MARCH 21, 1972
NOTICES
5799
party which is commonly known and re-
applicable laws to hold the office for which
television system, or complaining of noncom-
garded as such, or (ii) makes a substantial
he is a candidate, 80 that he may be voted
pliance to the Commission, shall have the
showing that he is & bona fide candidate for
for by the electorate directly or by means
burden of proving that he and his opponent
nomination or office, as the case may be.
of delegates or electors, and who:
are legally qualified candidates for the same
(b) General requirements. No station 11-
(1) Has qualified for B. place on the ballot,
public office.
censee is required to permit the use of its
or
facilities by any legally qualified candidate
(2) Is eligible under the applicable law to
The Commission guidelines for inter-
for public office, but if any licensee shall
be voted for by sticker, by writing his name
preting the Federal Election Campaign
permit any such candidate to use its facil-
on the ballot. or other method. and (1) has
Act of 1971 appear in the following sec-
ities, it shall afford equal opportunities to
been duly nominated by & political party
tions V through VIII.5
all such other candidates for that office to
which is commonly known and regarded as
use such facilities: Provided, That such 11-
such, or (II) makes a substantial showing
V-SECTION 315-LEGALLY QUALIFIED
censee shall have no power of censorship
that he is a bona fide candidate for nom-
CANDIDATES
over the material broadcast by any such
ination or office.
V. 1. Q. Who is a "legally qualified
candidate.
Section 76.205 Origination cablecasts by
(c) Rates and practices. (1) The rates,
candidates for public office. (a) General re-
candidate" for purposes of section
if any, charged all such candidates for the
quirements. If a cable television system shall
315(a)?
same office shall be uniform and shall not
permit any legally qualified candidate for
A. The definition of paragraph (a) [y]
be rebated by any means direct or indirect.
public office to use its origination channel
of the Commission rules applies for the
A candidate shall, in each case, be charged
(8) and facilities therefor, it shall afford
purposes of administering section 315(a).
no more than the rate the station would
equal opportunities to all other such candi-
(See IV above and IV in the 1970 primer.)
charge if the candidate were a commercial
dates for that office: Provided, however, That
advertiser whose advertising was directed to
such system shall have no power of censor-
However, section 104(a) (3) (B) of the
promoting its business within the same area
ship over the material cablecast by any such
Campaign Communications Reform Act
as that encompassed by the particular office
candidate: And provided, further, That an
requires some explanatory remarks con-
for which such person 16 a candidate. All
appearance by a legally qualified candidate
cerning candidates for presidential nom-
discount privileges otherwise offered by &
on any:
ination. Broadly speaking. clause (1) of
station to commercial advertisers shall be
(1) Bona fide newscast,
that section provides that n person is a
available upon equal terms to all candidates
(2) Bona fide news interview,
candidate for presidential nomination if,
for public office.
(3) Bona fide news documentary (if the
(2) In making time available to candi-
appearance of the candidate is incidental to
on or after a specified date, he makes
dates for public office no licensee shall make
the presentation of the subject or subjects
(or any other person makes on his be-
any discrimination between candidates in
covered by the news documentary), or
half) an expenditure for the use of a
charges, practices, regulations, facilities, or
(4) On-the-spot coverage of bona fide
communications medium on behalf of
services for or in connection with the serv-
news events (including but not limited to
his candidacy for nomination. (This pro-
ice rendered pursuant to this part, or make
political conventions and activities inciden-
vision is subject to interpretation by
or give any preference to any candidate for
tal thereto),
regulations to be issued by the Comp-
public office or subject any such candidate
shall not be deemed to be use of the facil-
troller General of the United States.)
to any prejudice or disadvantage: nor shall
any licensee make any contract or other
ities of the system within the meaning of
The section also states that a person
agreement which shall have the effect of
this paragraph.
who is a candidate for presidential
permitting any legally qualified candidate
NOTE: The fairness doctrine is applicable
nomination is, for purposes of section
for any public office to broadcast to the
to these exempt categories. See 76.209.
(b) Rates and practices. (1) The rates, if
315 of the Communications Act, con-
exclusion of other legally qualified candi-
any, charged all such candidates for the same
sidered to be a legally qualified candi-
dates for the same public office.
(d) Records; inspection. Every licensee
office shall be uniform. shall not be rebated
date for public office.
shall keep and permit public inspection of
by any means direct or indirect, and shall
Paragraph (a) [y] of the Commission
a complete record of all requests for broad-
not exceed the charges made for comparable
rules provides that a person is not a le-
cast time made by or on behalf of candi-
origination use of such facilities for other
gally qualified candidate within the
dates for public office, together with an ap-
purposes.
(2) In making facilities available to can-
meaning of the statute unless he has
propriate notation showing the disposition
made by the licensee of such requests, and
didates for public office no cable television
publicly announced his intention to be
the charges made, if any, if request is
system shall make any discrimination be-
granted. Such records shall be retained for
tween candidates in charges, practices, regu-
a candidate. (See Q. and A. IV.18. of
& period of 2 years.
lations, facilities, or services for or in con-
the 1970 primer.) New section 104(a)
NOTE: See $ 1.526 of this chapter.
nection with the service rendered. or make or
(3) (B) means that a person who had
(e) Time of request. A request for equal
give any preference to any candidate for pub-
opportunities must be submitted to the
lic office or subject any such candidate to
made an expenditure as described in
licensee within 1 week of the day on which
any prejudice or disadvantage; nor shall any
that section is a legally qualified candi-
the first prior use, giving rise to the right
cable television system make any contract
date for presidential nomination, even
of equal opportunities, occurred: Provided,
or other agreement which shall have the
however, That where the person was not &
effect of permitting any legally qualified
candidate at the time of such first prior use,
candidate for any public office to cablecast to
For convenience. in the remainder of this
he shall submit his request within 1 week
the exclusion of other legally qualified can-
public notice, references to any paragraph of
of the first subsequent use after he has
didates for the same public office.
the political broadcast or cablecast rules will
become a legally qualified candidate for the
(c) Records; inspections. Every cable tele-
be by paragraph only. For example, "para-
office in question.
vision system shall keep and permit public
graph (a) (y)" of the Commission rules will
(f) Burden of proof. A candidate request-
inspection of a complete record of all re-
mean "§§ 73.120(a). 73.290(a), 73.590(a). and
ing such equal opportunities of the licensee,
quests for origination cablecasting time
73.657(a) of the political broadcast rules and
or complaining of noncompliance to the
made by or on behalf of candidates for public
the corresponding 76.5(y) of the political
Commission shall have the burden of prov-
office, together with an appropriate notation
cablecast rules."
ing that he and his opponent are legally
showing the disposition made by the system
Attention is invited to the fact that some
qualified candidates for the same public
of such requests, the charges made, If any,
paragraphs of the present political broadcast
office.
and the length and time of cablecast, if the
and cablecast rules are inconsistent with the
request is granted. Such records shall be
The Commission's present rules and
guidelines herein. For example, paragraphs
retained for a period of two years.
(b) and (c) (1) of the political broadcast
regulations with respect to political
(d) Time of request. A request for equal
rules are inconsistent with the guidelines
cablecasts coming within section 315 of
opportunities for use of the origination
which implement the new sections 312(a) (7)
the Communications Act are set forth in
channel(s) must be submitted to the cable
and 315(b) (1) of the Communications Act
§§ 76.5(y) and 76.205, which read as
television system within one (1) week of the
(which respectively require broadcast sta-
follows:
day on which the first prior use, giving rise
tions to give reasonable access to candidates
to the right of equal opportunities, occurred:
for Federal elective office, and to charge all
Section 76.5 Definitions.
(y) Legally
Provided, however, That where a person was
candidates not more than "lowest unit
qualified candidate. Any person who has
not a candidate at the time of such first
charges" during specified periods before elec-
publicly announced that he is a candidate
prior use, he shall submit his request within
tions.) As stated in the fifth paragraph of
for nomination by a convention of a political
one (1) week of the first subsequent use
this public notice, such inconsistencies are
party or for nomination or election in 6
after he has become a legally qualified candi-
to be resolved in favor of the guidelines. In
primary. special, or general election, munici-
date for the office in question.
the future, the Commission will amend the
pal, county, State, or National, and who
(e) Burden of proof. A candidate request-
present political broadcast and cablecast
meets the qualifications prescribed by the
ing such equal opportunities of the cable
rules to conform with tbe guidelines.
FEDERAL REGISTER, VOL. 37, NO. 55-TUESDAY, MARCH 21, 1972
5800
NOTICES
though no public announcement of can-
3. Q. To whom do the "comparable
most favored commercial advertiser for
didacy has been made, and hence is en-
use" provisions of section 315(b) (2)
the same class and amount of time for
titled to equal opportunity under section
apply?
the same period, without regard to the
315(a) of the Communications Act. How-
A. Unlike section 315(b) (1), section
frequency of use by the candidate. This
ever, section 104.0) of the Campaign
315(b) (2) has no restrictive provisions,
includes discount rates not published in
Communications Reform Act amends
and applies to all persons who are legally
a rate card but provided to commercial
section 315(c) of the Communications
qualified candidates for the purposes of
advertisers. Some examples follow:
Act to provide that no communications
section 315(a) as discussed in Q. and A.
(a) A licensee sells one fixed-position.
medium may make any charge for the
V. 1. above: whether running in an elec-
1-minute spot in prime time to commer-
use of its facilities by or on behalf of
tion or seeking nomination by a party
cial advertisers for $15. It sells 500 such
any legally qualified candidate for Fed-
convention.
spots for $5,000. It must sell one such
eral elective office (or for nomination
4. Q. To what "legally qualified can-
spot to a candidate for not more than
to-such office) unless such candidate (or
didates" do the certification provisions
$10.
a person specifically authorized by such
of section 315(c) apply?
(b) A licensee sells one immediately
candidate in writing to do so) submits a
A. They apply to "legally qualified
preemptible 30-second spot in drive time
certification to the licensee that the pay-
candidates" as the term is defined in
to commercial advertisers for $10. It sells
ment of the charge will not exceed the
section 315(f) (2). who are seeking to
100 such spots for $750. It must sell one
spending limitation set forth in the new
hold "Federal elective office" as the term
such spot to a candidate for not more
law. In cases where a person has made
is defined in section 102(3) of the Cam-
than $7.50.
the expenditure mentioned in section
paign Communications Reform Act. This
(c) A licensee's best rate per spot for
104(a) (3) (B) but has not publicly an-
definition of "legally qualified candidate"
run-of-schedule, 1-minute spots is 1,000
nounced his candidacy, we shall con-
is intended to be used only with regard
for $1,000. Its rate for one such run-of-
strue the submission of the aforemen-
to the certification required by the pro-
schedule spot is $4. It must sell one such
tioned certificate and the expenditure
visions of section 315(c) and the spend-
spot to a candidate for not more than
as constituting a public announcement
ing limitation provisions of section
$1.
as of the date of the broadcast or publi-
104(a) (1) and (2) of the Campaign
2. Q. May the lowest unit charge vary
cation in other communications media
Communications Reform Act referred to
with the day of the week on which a
of the matter for which the expenditure
in section 315(c). The Commission is of
candidate uses a station?
is made.
the view that the definition of section
A. Yes. For example, a television sta-
Moreover, we interpret the intent of
315(f) (2) (B) dues not include situations
tion might charge commercial advertisers
Congress to be that the, mere making
where a person is seeking nomination for
more for 1-minute, fixed-position spots
of minimal expenditures under the pro-
U.S. Senator or Representative by a con-
between 7:00-7:30 p.m. on Sunday than
visions of section 104(a) (3) (B) does not
vention or caucus held to nominate such
it does for such spots on Monday through
entitle a person to equal opportunity
candidates and that the provisions of
Friday; and the charges on Monday
under section 315(a). Thus, for example,
section 315(c) do not apply to such per-
through Friday might exceed the charges
a person who has taken out a $5 adver-
sons. The Commission believes that the
for such spots on Saturday. In computing
tisement in a newspaper, and submitted
provisions of section 315(c) do apply to
the lowest unit charge which must not be
a certification in connection therewith,
persons qualifying as candidates for
exceeded in selling time to candidates,
would not. in the absence of other facts
presidential nomination under the
stations. in addition to taking into ac-
to demonstrate the bona fides of his
spending provisions of section 104(a)
count the class and amount of time for
candidacy, be entitled to equal oppor-
(3) (A) (1) whether they are running
the same period of the day. may take into
tunity under section 315(a).
in a primary election or are seeking to
account the day of the week. if rates of
2. Q. To whom do the "lowest unit
influence the action of a State conven-
the station vary with the day of the week.
charge" provisions of section 315(b) (1)
tion of a political party that will select
In the example given above, the station
apply?
delegates to its national nominating
would not be required to sell time to a
A. With one exception, section 315
convention.
candidate for use on Sunday between
(b) (1) applies to all persons who meet
5. Q. To what "legally qualified can-
7:00-7:30 p.m. at rates not exceeding the
the requirements of a "legally qualified
didates" do the provisions of section
lowest unit charge for Saturday night.
candidate" for purposes of section 315(a)
315(d) apply?
If a station does not vary its charges to
as discussed in Q. and A. V. 1. above.
A. They apply to all "legally quali-
commercial advertisers with the day of
The exception is that it does not apply
fied candidates" for any office of a State
the week, it may not do so with candi-
to candidates for nomination by a con-
or political subdivision thereof who meet
dates for public office.
vention or a caucus of a political party
the definition of "legally qualified can-
3. Q. A general election is to be held
held to nominate a candidate since the
didate" set forth in section 315(f) (2) if
on November 2. As required by section
special rate provision of section 315
the State has taken the steps mentioned
315(b), the lowest unit charge must be
(b) (1) by its express terms applies only
in section 315(d). The definition of sec-
made to candidates during the preceding
during the 45 days preceding the date of
tion 315(f) (2) (B) does not apply to situ-
60 days, commencing September 3. Pur-
a primary or a primary runoff election
ations where a person is seeking nomina-
suant to normal practices, a station on
and during the 00 days preceding the
tion for State office by a caucus or
September 20 changes from its summer
date of a general or special election in
convention, and the provisions of section
rates to its higher fall rates. Is the lowest
which a person is a candidate. Thus, for
315(d) do not apply to such candidates.
unit charge during the entire 60-day
example, a person campaigning in a
period preceding the election based on
VI-SECTION 315-LOWEST UNIT CHARGE
State in an effort to have the State con-
summer rates?
vention of a political party select dele-
VI. 1. Q. What is the meaning of "low-
A. No. From September 3 to Septem-
gates to a national nominating conven-
est unit charge of the station for the
ber 20, the lowest unit charge is based on
tion who are favorable to him would not
same class and amount of time for the
the summer rates. On and after Septem-
be entitled to the lowest unit charge.
same period" in section 315(b)
ber 20, the fall rates are used as the basis
Similarly, a person campaigning to have
A. The term "class" refers to rate cat-
for computation of the lowest unit
a State convention nominate him for
egories such as fixed-position spots,
charge. Compare Q. and A. VI. 8. through
State office, or for U.S. Senator or Rep-
preemptible spots, run-of-schedule and
12. below.
resentative. would not be entitled to the
special-rate packages. The term "amount
4. Q. For a particular community,
lowest unit charge. In a situation where
of time" refers to the unit of time pur-
ARB and Nielsen television market re-
a person is campaigning in a primary
chased, such as 30 seconds, 60 seconds,
ports are issued six times a year. Upon
election in which delegates will be se-
5 minutes or 1 hour. The term "same
receipt of these reports it is the normal
lected to go to a State convention which
period" refers to the period of the broad-
cast day such as prime time, drive time,
in turn will select delegates to a national
class A. class B or other classifications
8 At the present time, of course, such
convention, the lowest unit charge pro-
established by the station.
changes in rates are subject to any state-
ments of policy, guidelines, or regulations
vision would apply to that person during
Candidates are entitled to discounts,
issued by the Price Commission under the
the 45 days preceding the primary.
frequency and otherwise, offered to the
Economic Stabilization Program.
FEDERAL REGISTER, VOL. 37, NO. 55-TUESDAY, MARCH 21, 1972
NOTICES
5801
business practice of a television station
theless pay the higher price for which he
A. The extremely low rate should be
in the community to reexamine its rates
contracted. Such will not be the case for
viewed as the lowest unit charge, Le-
and revise some of them. During the 60-
a candidate under the provisions of sec-
cause it is the lowest charge available
day period preceding a general election.
tion 315(b) (1). If the price of a spot
to commercial advertisers and it was
such a rate revision occurs which results
on the date of use is lower than the price
possible for it to have been afforded on
in increased rates for adjacencies to pro-
for which he contracted in advance, he
any day of the 60-day period. In view
gram A shown in prime time, and a de-
will be entitled to the lower price and
of this consideration and the possibility
crease in rates for adjacencies to program
is to be given a rebate (if the spot has
of abuse (by favoring commercial ad-
B in prime time. What is the basis for
been previously paid for) or an adjust-
vertisers or one candidate over another),
calculation of the lowest unit charge for
ment (if the spot has not yet been paid
the giving of such an extremely low rate
adjacencies to the two programs during
for). Moreover. if the lower price (on the
on any date will not only set a new stand-
the Co-day period?
date of use) just mentioned is not as
ard for the calculation of lowest unit
A. Candidates using adjacencies to
low as the lowest unit charge made to
charge on that date and the remainder
either program A or program B prior to
advertisers who enter into the 52-week
of the period, but all candidates who
the rate change are entitled to be charged
type of contract mentioned above, the
have used the station prior to that date
not more than the lowest unit rate for
candidate is entitled to be charged the
will be entitled to refunds to bring the
such adjacencies prior to the rate change,
lowest unit rate based on the 52-week
charges to them in line with that ex-
and those using adjacencies to either
contract even though he purchases only
tremely low rate. To afford some cer-
program after the rate change are en-
one spot.
tainty in this respect, the appropriate
titled to be charged not more than the
The upshot of the foregoing is that a
period to which this holding applies is
lowest unit charge after the rate change.
candidate falling under the provisions of
the 45- or 60-day period; affording ex-
Thus, the lowest unit rate for candidates
section 315(b) (1) will be entitled to the
tremely low rates on an ad hoc basis
for adjacencies to program A prior to
lowest unit charge on the date of use
outside these periods thus is not relevant
the rate change is lower than the lowest
of the network regardless of the date on
to the issue of the lowest unit charge.
unit rate after the rate change. As to
which he places or pays for his order for
7. Q. Candidate A purchases 50 fixed-
adjacencies to program B, the lowest unit
time. We emphasize that it is the date
position, 1-minute spots in prime time to
rate prior to the rate change is higher
of network use that will govern the
be aired prior to the 45- or 60-day period
than the lowest unit rate after the rate
charge made to any candidate. Thus if
preceding an election and pays for the
change. Compare Q. and A. V1. 8. through
$40,000 is the lowest unit charge for a 1-
time on the basis of "comparable use" as
12. below."
minute spot announcement on a partic-
provided in section 315(b) (2). Pursuant
5. Q. Do the lowest unit charge pro-
ular program in prime time on Octo-
to section 315(a), candidate B is entitled
visions apply to purchase of time on the
ber 1, and $50,000 is the lowest unit
to "equal opportunity" to respond to
networks?
charge for a 1-minute spot on that pro-
candidate A, and candidate B purchases
A. Yes. The Commission is of the view
gram in prime time on October 22, can-
50 such spots for his response. which
that although the Campaign Communi-
dide*e A who purchases a 1-minute scot
spoth are to be aired during the 45- or
cations Reform Act does not specifically
broadcast on October 1 pays $40,000, and
candidate B who purchases a 1-minute
60-day period. On what basis is candidate
refer to networks, the provisions are in-
B charged?
tended to apply to purchase of network
spot broadcast on October 22 pays
$50,000. This difference in price charged
A. Candidate B may be charged not
time. A network is in a real sense selling
the two candidates is not inconsistent
more than the lowest unit charge pre-
time on behalf of station licensees and
the Commission interprets new section
with paragraph (c) [b] of the Commis-
vailing during the 45- or 60-day period.
sion rules (which provides that there
Had candidate E responded to candidate
315(b)(1) as applying to the combina-
tion of licensees in the network as well
shall be no discrimination between can-
A prior to the 45- or 60-Gay period, he
didates as to charges) for both candi-
would have been charged on a "compara-
as to the individual licensees. Thus,
charges to legally qualified candidates
dates are receiving the lowest unit rate
ble use" basis, just like candidate A.
purchasing network time may not exceed
at the time of use, that rate being based
However, since the statute provides for a
the lowest unit charge for the same class
on audience exposure and giving candi-
lowest unit charge basis for uses during
date B greater exposure than A. (See Q.
the 45- or 60-day period, caudidate B
and amount of time for the same period
and A. VI. 3. and 4. above. The difference
is charged on that basis. Paragraph
of the broadcast day on a network. Can-
in rates therein are also correlated with
(c) [b] of the Commission rules on politi-
didates are entitled to be charged not
more than the lowest unit rate regard-
audience size. See also footnote 6 above.)
cal broadcasts provides that a station
less of the number of times they use the
Attention is invited to the fact that the
shall not discriminate between candi-
network. For example, if a television
foregoing discussion of network charges
dates in charges. but this does not
network gives a discount for advertisers
to candidates is applicable to uses of a
amount to discrimination since the dif-
who contract in advance on a noncan-
network not involving "equal opportu-
ference in charges is set by statute.
cellable basis for at least one I-minute
nity" under section 315(a). For "equal
8. Q. During the S0-day period pre-
commercial announcement for broadcast
opportunity" situations, the principle set
ceding a general election, the rates of a
in one or more specified programs in
forth in Q. and A. VI. 8., below, applies.
station, pursuant to normal business
prime time at least once a fortnight on
Thus, if candidate A has 8 1-minute spot
practices, change from summer tc higher
a regular schedule over a 52-week period,
on a network on October 1 for $40,000,
fall rates. The lowest unit charges are
a candidate would be entitled to that dis-
candidate B exercising "equal opportu-
therefore less before the rate change
count even though purchasing only one
nity" rights on October 22 pays $40,000
than afterwards. (See Q. and A. VI. 3.
such spot announcement. At intervals, a
rather than $50,000.
above.) Candidate A purchases 50 fixed-
television network may change the spot
6. Q. During the 60-day period pre-
position. 1-minute spots in prime time
announcement charges for a particular
ceding a general election there are no
to be aired before the rate chauge. Pur-
program depending on the viewer ratings
changes in rates of the kind mentioned
suant to section 315(a), candidate B is
for the program. If commercial adver-
in Q. and A. VI. 3. and 4. above. A licensee
entitled to equal opportunity to respond
tiser A has contracted in advance for a
observes that on a particular date he has
to candidate A, and candidate B pur-
spot on a program to be broadcast on a
some unsold time available during prime
chases 50 such spots for his response,
certain date, and if because of low viewer
time hours. Preferring to realize some-
which spots are to be aired after the sea-
ratings the price being offered to other
thing rather than nothing for that time,
sonal rate change. Is candidate B charged
advertisers for spots on the program on
he approaches and sells to an advertiser
a higher rate?
that date is lower than the price con-
three 1-minute, fixed-position spots in
A. Although in situations not involv-
tracted for by A, advertiser A must none-
prime time at an extremely low rate. The
ing "equal opportunity" the lowest unit
unit charge for the three spots is lower
charge for candidates using the station
" At the present time. of course, such
than the lowest unit charge for such
spots based on "normal" rates prevailing
prior to the seasonal rate change is based
changes in rates are subject to any state-
ments of policy. guidelines. or regulations
during the 60-day period. What is the
on summer rates, and for those using the
issued by the Price Commission under the
effect of this in calculating lowest unit
station after the change is based on fall
Economic Stabilization Program.
charge for the 60-day period?
rates, the situation is different in cases
FEDERAL REGISTER, VOL. 37, NO. 55-TUESDAY, MARCH 21, 1972
5802
NOTICES
involving "equal opportunity." The can-
provided in section 315(b) of the Com-
titling opposing candidates to 'equal
didate in such a situation is entitled to
munications Act prior to its amendment
opportunities in the 1970 primer.) Sec-
be charged on the same basis as the
by the Campaign Communications Re-
tion 104(a) (6) of the Campairn Com-
candidate to whom he is responding.
form Act. Is the candidate entitled to a
munications Reform Act provide t.
Therefore, in this situation, the rate
refund if payment to the station has been
amounts spent for the use of communi-
charged candidate B must be the same
made prior to the time of use, or to an
cations media by or on behnif of a can-
as that charged candidate A (which rate
adjustment in the charges if payment
didate are attributable to the candidate's
cannot exceed the lowest unit charge
has not been made at or before the time
spending limit. This means that sonie
based on summer rates). (Compare Q.
of use, so that he will pay on a lowest unit
broadcast time bought to further the
and A. VIII. 71. in the 1970 primer.)
charge basis?
candidacy of a person may he on his be-
9. Q. During the 60-day period pre-
A. Yes. The lowest unit charge applies
half and will count against his spencing
ceding a general election, the rates of a
to all uses falling under the provisions
limit, but will not be entitled to the "low-
station, pursuant to normal business
of section 315(b)(1) which occur on or
est unit charge" If it does not involve a
practices, change from summer to higher
after April 7, 1972, regardless of the date
"use" by the candidate. (See Q. and A.
fall rates. The lowest unit charges are
of contract.
VIII.2. of the 1970 primer.)
therefore less before the rate change
12. Q. On or after April 7, 1972, a can-
15. Q. Does the "lowest unit charge"
than afterwards. (See Q. and A. VI. 3.
didate contracts with a station for use
provision of section 315(b) (1) apply to
above.) Cendidate A purchases 50 fixed-
of its facilities on a specified date or
both time charges and other charges by
position, 1-minute spots in prime time
dates in the future, which dates occur
a station in connection with political
to be aired before the rate change. Pur-
within a 45- or 60-day period before
broadcasts?
suant to section 315(a), candidate B re-
an election. The price for the use of the
A. No. The provision applies only to
quests "equal opportunity" to respond
facilities is stated in the contract. At
charges for purchase of time. It does not
to candidate A in fixed-position, 1-min-
the time of use of the facilities, the rates
cover additional charges made by F33-
ute spots in prime time to be aired after
of the station have changed because, for
tion for other services, which may be
the seasonal rate change. Candidate B
example, of normal seasonal rate
termed production oriented, such as
requests 100 such spots. At what rate is
changes, or because of the issuance of
charges for use of 8 television studio,
candidate B charged?
ARB or Nielsen TV market reports which
audio- or video-taping, or line charges
A. Candidate B is entitled to 50 such
resulted in rate changes by the station.
and remote technical crew charges when
spots at the rate charged candidate A
At what rate is the candidate charged for
the broadcast is to be picked up cuicide
to satisfy the "equal opportunity" re-
use of the station?
the station. Moreover, the provision Goes
quirement. For the remaining 50 spots
A. If the change in rates has resulted
not apply to additional charges that
he may be charged not more than the
in a lowest unit charge which is greater
might be incurred if a candidate sought
lowest unit rate based on the higher fall
than that provided in the contract. the
to purchase full sponsorship of an exist-
rates. Jt ould be noted that the sale
candidate is entitled to the charge speci-
ing program for which there is =
to candidate B of 50 spots at the low
fied in the contract. If the rate change
lished program charge in addition to a
summer rates to satisfy the "equal op-
of the station has resulted in & lowest
time charge.
portunity" requirement does not affect
unit charge which is less than that pro-
16. Q. Customarily. stations allow ad-
the rates to be charged him or other
vided in the contract, the candidate is
vertising agency commissions to
candidates using the station after the
entitled to be charged at the lesser rate.
out of the charges made for time. If a
change 10 the higher fall rates on other
13. Q. On or after April 7. 1972, a can-
candidate purchases time from L station
than an "equal obsortunity" basis.
didate contracts with a station for use of
through ER agency, may the station in-
10. Q. A commercial advertiser has
its facilities during a period 60 days prior
clude the agency commission in the low-
over a period of years had a contract for
to a general election. The contract speci-
est unit charge it makes to the candidate?
commercial spot announcements with a
fies no set rate to be charged, but instead,
A. Yes. However, if a candidate pur-
station and that contract has been re-
provides that the rate to be charged will
chases time directly from a station with-
newed from time to time with unchanged
not exceed the lowest unit charge being
out the use of an agency. the lowest unit
rates set at the time the contract was
made on the date(s) contracted for. May
charge must exclude tr.c amount usually
entered into although the rates of the
such contracts be entered into by
paid for agency commission. For ex-
station to other advertisers have in-
stations?
ample, if a 1-minute spot announcement
creased. Thus. the lowest unit charge of
A. Yes. There is nothing in the new law
costs $100 and an agency is allowed $15,
the station for the same class and
concerning the type of contract a station
a candidate placing a spot through an
amount of time for the same period com-
may enter into with a candidate. (How-
agency must pay $100. But if a candidate
puted by using current rates to other
ever, a contract providing that regardless
places the spot directly, without use of
advertisers is higher than the lowest unit
of the lowest unit charge being made on
an agency, he pays $85. In this connec-
charge based on the rates being given
the date of use by the candidate the
tion, however, attention is invited to Q.
to the advertiser with the "rate protec-
candidate must pay a higher rate speci-
and A. VI.13. above which states that
tion agreement." In calculating the low-
fied in the contract would be contrary to
production costs are not included in the
est unit charge for a candidate who
the public policy established by the new
lowest unit charge. Hence a candidate
qualifies for such charges under section
law.) Without additional language in
purchasing time directly, without the use
315(b) (1), is it correct to use as a basis
such a contract, however, it might be
of an agency, must furnish his advertise-
for the calculation the current rates gen-
impossible to satisfy the certification re-
ment or other program matter to the
erally held out to advertisers in the
quirement of Q. and A. VII.1.(1), below.
station, unless it is the policy of the sta-
community?
14. Q. Does the "lowest unit charge"
tion to prepare the material for commer-
A. No. The candidate is entitled to the
provision of section 315(b) (1) apply to
cial advertisers in such situations. See Q.
lowest unit charge for the same class and
political broadcasts by groups, organiza-
and A. VIII. 12. and 20. in the 1970
amount of time for the same period.
tions or persons other than candidates?
primer.
Since the lowest unit charge is that being
A. No. The provision applies only to
17. Q. May a station with both "na-
given to the advertiser with the contract
broadcasts by candidates for public office.
tional" and "local" rates charge a can-
of long standing. that charge must be
The general guideline to be followed is
didate falling within the purview of sec-
made to the candidate. Compare Q. and
that the "uses" of broadcast stations for
tion 315(b) (1) its lowest rate charge
A. VIII. 13. in the 1970 primer.
which the "lowest unit charge" provision
based on its "national" rates?
11. Q. A candidate, prior to April 7,
applies are the "uses" which would entitle
A. No. The calculation of the lowest
1972, has contracted for use of a sta-
an opposing candidate to "equal oppor-
unit charge must be based on its "local"
tion after that date. The date(s) of use
tunities" under the provisions of section
rates (if they are lower than its "na-
contracted for occurs during the 45- or
315(a), i.e., uses in which the candidate
tional" rates) regardless of whether a
60-day period before an election. The
personally participates through use of his
candidate is rulining for musicipal,
contract price was at rates not exceed-
voice or image, live or taped, or through
county, State, or national office. ("Na-
ing those made to commercial advertisers
film or picture. (See "III. B. What con-
tional" and "local" are not viewed as
for comparable use of the station, as
stitutes a 'use' of broadcast facilities en-
different "classes" of service under the
FEDERAL REGISTER, VOL. 37, NO. 55-TUESDAY, MARCH 21, 1972
NOTICES
5803
provisions of section 315(b) (1).) For
held in the State, the person is running
amount, and period of time on the
example, if a candidate were running for
in that primary, but that primary will
station.
the office of United States Senator and
occur more than 43 days after the pro-
23. Q. Where a cable television opera-
fell within the purview of section 315
posed use of the stations in State C. On
tor does not have an advertising rate
(b) (1), and if a station on which he
what stations is the candidate extitled to
schedule, how should he determine the
purchased time covered all or most of the
the lowest unit charge?
proper rate for a political message, in
State in which he was running, calcula-
A. He is entitled to the lowest unit
terms of "lowest unit charge" and "com-
tion of the lowest unit charge would have
charge only on the stations in the eastern
parable use" rate concepts?
to be baced on the station's "local"
State where he is running in the primary
A. Since it is likely that most cable
rather than it's "national" rates. This
election. In the western States he would
operators have had little experience in
guideline obscrules Q. and A. VIII. 4. and
be entitled to rates on a "comparable"
offering cablecasts on their systems. and
14. iv 1070 primer insofar as candi-
basis under the provisions of section 315
even less in charging for use of cable-
dates failing under the provisions of sec-
(b) (2). The Commission is of the view
casting facilities, it will be necessary for
tion 315(b) (1) are concerned. They are
that the intent of the lowest unit rate
operators without existing rate schedules
not overruled, however, as to candidates
provision is that it is to apply only in
to arrive at some reasonable rate struc-
falling under the provisions of section
situations where an election is being held
ture. Section 73.251 (11) (lii) of the
315(b) (2). See also Q. and A. VIII.3. in
in the service area of the St ation on
rules requires cable systems to establish
the 1970 primer.
which time is being purchased. If the
appropriate rate schedules for use of
18. Q. In computing the lowest unit
person in this case subsequently receives
their leased access channels; we expect
charge under the provisions of section
the nomination of his party at its na-
that such rates will not have the effect of
315(b) (1), is the calculation based on
tional convention. then under the pro-
discouraging political use of such
the rate card of the station or on the
visions of section 315(b) (1) he would be
channels.
rates actually charged by the station if
entitled to the lowest unit charge in sta-
24. Q. Do the "lowest unit charge" and
they differ from those on the rate card?
tions in all of the 50 States during the
"comparable use" rate concepts prevent
A. The calculation is based on what-
60-day period preceding the presidential
a cable television operator from estab-
ever will give the lowest unit rate for
election.
lishing different rate structures for origi-
the same class and amount of time dur-
20. Q. By statute a State provides that
nation and access cablecasting channels?
ing the same period of the day. If use
broadcast stations may carry legal
A. No. The Commission considers
of the actual charges gives the lowest
notices at rates fixed by the statute. This
origination and access cablecasting
unit rate, actual charges are used in
rate is quite low $0 that for a particular
channels to be very different and non-
determining rates for candidates. If use
broadcast station in that State the lowest
comparable vehicles for expression on a
of the rate card gives the lowest unit
unit charge for such notices for the same
cable system. It is for this reason, for
class and amount of time for the same
rate, the rate card is the basis used.
example, that the Commission requires
Example of actual charges forming the
period is less than the lowest unit charge
"equal time" and "fairness" obligations
basis for lowest unit charge: A licensee
based on "normal" rates. Must the lowest
arising on an origination cablecasting
is "flexible" and uses his rate card as a
unit charge for candidates be calculated
channel to be satisfied on such a channel,
point of departure for negotiations which
on the basis of the statutory rate for legal
and not on an access channel. See para-
always results in rates less than those
notices?
graph 145, Cable Television Report and
shown on the card. Example of rate card
A. No. Since the rates for legal notices
Order, 37 F.R. 3252 (1972). Thus, a cable
forming the basis for lowest unit charge:
are set by statute rather than by the
operator need not have the same rate
A rate card shows a "package" or "plan"
station, they are not used for calculation
structure for both origination and access
for fixed-position, one-minute spots in
of the lowest unit charge for candidates.
channels.
drive time which yields the lowest unit
21. Q. Are trade outs or barter trans-
25. Q. What is the meaning of "charge
charge on the card for such spots (e.g.,
actions involving commercial advertisers
made for comparable use" in section
10,000 such spots over a period of a year
to be used in computing the lowest unit
315(b) (2)?
for a very low rate). The "package" or
charge?
A. This term is identical with that in
"plan" on the rate card also yields the
A. No. Although stations engage in
section 315(b) prior to its amendment by
lowest unit charge as compared with
trade outs and barter in dealing with
the Campaign Communications Reform
actual sales that may have been made
advertisers, only transactions involving
Act, and is construed in the same man-
for such spots at rates less than card
sale of time for monetary consideration
ner. The section entitled "VIII. What
rates. However, the "package" or "plan"
are to be used as the basis for calculating
rates may be charged candidates for pro-
has not been purchased by anyone for
the lowest unit charge which must not
grams under section 315?" in the 1970
use during the 45- or 60-day period. In
be exceeded when a candidate wishes to
primer contains Commission rulings on
such a case, the rate card is used as the
purchase time. (This does not affect the
this statutory term and on paragraph
basis for calculation of the lowest unit
Commission's policy with respect to re-
(c)[b] of the Commission rules govern-
rate for such spots because although it
porting trade out and barter transactions
ing political broadcasts and cablecasts
was never taken advantage of by a pur-
on the Annual Financial Report (FCC
which implemented the old section
chaser of time, the very low unit rate of
Form 324). See Public Notice, FCC 72-
315(b). These rulings are still valid.
the "package" or "plan" was being held
139, February 17, 1972.)
VII-SECTION 315-CERTIFICATION
out to the public.
22. Q. Are stations permitted to
charge less than the lowest unit charge
VII. 1. Q. What procedure is recom-
19. Q. A person is a legally qualified
during the 45- or 60-day period before
mended by the Commission with regard
candidate for nomination for the presi-
an election?
to the certification that stations must
dency, as discussed in Q. and A. V.1.
A. Yes. To make the preceding ques-
obtain pursuant to sections 315(c) and
above. He is running in the primary elec-
tions and answers concerning the matter
315(d).
tion of a State in the eastern part of the
of "lowest unit charge" less cumbersome,
A. The Commission recommends the
United States. During the period of 45
they have sometimes been couched in
following procedure which is analogous
days before that primary election he
terms that might have conveyed the im-
to that which will be established by
wishes to purchase time on stations
pression that stations must charge the
regulations of the Comptroller General
in that State and on stations in each
lowest unit charge to candidates. It is
for certifications required by section
of three western States. The situa-
stressed here that section 315(b) (1) pro-
104(b) of the Campaign Communica-
tion with regard to each of the western
vides that charges made by stations shall
tions Reform Act in connection with
States is as follows: (1) in State A, a
not exceed the lowest unit charge for the
uses by candidates of newspapers. maga-
presidential primary election has already
same class and amount of time for the
zines, or outdoor advertising facilities:
been held in the State; (2) in State B,
same period. Stations are at liberty to
(1) The certification should contain
the delegates to the national nominating
charge less than the lowest unit charge.
the call sign and community of license of
convention have already been selected by
However, if they do. they must give the
the station (or, in the case of a cable
a State convention; (3) in State C. a
same low unit rate to other candidates
television system. the name of the sys-
presidential primary election is yet to be
for all offices purchasing the same class,
tem, each community served, and State);
FEDERAL REGISTER, VOL. 37, NO. 55-TUESDAY, MARCH 21, 1972
No. 55-Pt. П—2
5801
NOTICES
name of candidate; his political afilia-
copy of that person's authorization given
A. They only ply to legally qualified
tion: elective office sought: date of pri-
to the person making the charge must be
candidates for 1 elective (as
mary or other election in connection with
attached to the cert.fication and retained
such offices are delined (3)
which time is being purchased: dates of
with it in the file for the 2-year period.
and (4) of the Campaign Communica-
proposed use or of si: tion; duration
(3) Attention of certifying parties is
tions Reform to
to
of each broadcast and time at which each
invited to the fact that the Comptroller
access by candidates for other than Fed-
broadcast is to be made on each date;
General of the United States will, in the
eral elective office, 2. Decrease must covern
the rate to be charged and the total
near future, promulgate regulations gov-
its conduct by established interpre tions
charges for which payment by the candi-
eming communications media spending
of secuion 315 of the Communica Act
date is certified not to violate the candi-
limitations for Federal elective office as
prior to amendments. One such interpre-
date's spending limitation: signature of
required by the Campaign Communica-
tation of section 315 is the Commission's
the candidate or of the pct refically
tions Reform Act. These regulations will
histone Delicy sale o: who to
authorized by the candidate in writing to
be published in the FEDERAL REGISTER and
candidates for office: The licensee in its
do so; and date of signature. In addition
issued in a new title 11 ("Federal Elec-
own good-falth judgment in serving the
to the foregoing, the certification should
tions") of the Code of Federal Regula-
public interest may determine which po-
state that payment for the use of the
tions. Candidates should, of course, fa-
litical races are of greatest interest and
time purchased, including any agent's
miliarize themselves with the contents of
significance to its service area, and there-
commission allowed the agent by the
those regulations when issued. However,
fore may refuse to sell time to candidates
station. will not violate the candidate's
P.S an aid to stations and candidates,
for less important offices, provided it
permissible limit of campaign spending
and with the caveat that this informa-
treats all condidates for such OLICES
under the provisions of section 104(a)
tion is subject to modification by the
equally.
of the Federal Election Campaign Act
aforementioned regulations, the follow-
2. Who is a "legally qualified candl-
of 1971 (Public Law 92-225) as deter-
ing represents the substance of a perti-
date" for Federal elective office for pur-
mined by the Comptroller General of the
nent portion of what is expected to ap-
poses of section 3.2(2)(7)?
United States for the race involved. (For
pear in the regulations:
A. A "legally tushfed candidate" for
State races under section 315(d), appro-
priate language concerning spending
An expenditure for use of 2 station is
Federal elective office of
deemed to take place on the date or dates
this section is the 02016 as that spelled
limits imposed by the State law should
when the station is actually used, regardless
out in Q. and A. V.1. above, i.e., for pur-
be used.)
of when payment therefor is made and re-
poses of reasonable BOODER and permit
(2) The original certification must be
gardless of the date of any contract or prom-
purchase of reasonable amounts ct time
given to the person, making the charge
ise. Such expenditure is charged against the
the definition is the same as for section
before the order or agreement for the
amount of the expenditure lim tation ap-
315(a) concerning "equal opportunties."
particular use is accepted. One copy of
plicable to the election in connection with
the certification should be retained by
which the station is actually used, regardless
3. Q. How is a licensee to comply with
the candidate cr the authorized person.
of when payment therefor is made and re-
the requirement of section 312(s)(7)
gardless of the date of any contract or
that he give bis
If prior to the date(s) of use there is a
promise. An expenditure for the Due of a
station to, or pernit the proble J of
change in the amount of charge, an
station, when such use occurs on or after
reasonable amounts of time by, candi-
amended certification must be given to
the effective date of the Campaign Com-
dates for Federal elective cffice?
the station.
munications Reform Act (April 7, 1972), is
charged against the expenditure limitation
A. Each B, When pr. Zons
(3) Each authorization by a candidate
of sections 307 and 309 of the Communi-
to another person or persons to make
applicable to the election in which the sta-
tion is used, regardless of whether or not the
tions Act, is ..3 to cerve 125 CLD-
on behalf of the
use is paid for or constitue for prior in the
L
Inter
7.
all the name and address of the
effective date of the Act. However, the Act
In its Report and Statement 02 Policy
authorized individual, the name of the
does not apply when such use occurs en-
Re: Commission En Rame Programming
candidate, the election involved, and any
tirely before the effective date of the Act.
Inquiry (1950), the Commission stated
restrictions or limitations imposed, and
regardless of whether or not the use is paid
that political broadcasts constitute one
it should be signed and dated by the
for on or after the effective date.
of the major elements in meeting that
candidate. The authorized individual
2. Q. Under the provisions of sections
standard. (See Formers Educational and
may retain the original but a copy of
315(c) and 315(d), if a station gives free
Cooperative Union of America. North
the authorization must be given to the
time for use by or on behalf of a candi-
Dakota Division V. WDAY, Inc., 360 U.S.
person making the charge.
date must it obtain a certification from
525 (1959), and Red Lion Broadcasting
(4) Whenever a single use of a sta-
the candidate or a properly authorized
Co., Inc. V. FCC, 395 U.S. 367, 393-94
tion is by or on behalf of two or more
person?
(1969).) The foregoing broad standard
candidates for elective office, the amount
A. No. The sections only require the
has been applied over the years to the
attributable to the expenditure of each
station licensee to obtain a certification
overall programing of licensess. New sec-
candidate is the amount agreed upon by
if a charge is being made for the broad-
tion 312(a) (7) adds to that broad stand-
the candidates in advance of the use and
cast time, for if time is given free, use of
ard specific language concerning reason-
shown on the certification. In such situa-
a station by or on behalf of a candidate
able access.
tions, a joint certification, or individual
under those circumstances cannot bring
Congress clearly did not intend, to
certifications showing the allocation to
the candidate into violation of the
take the extreme case, that during the
each candidate should be furnished by
spending limitation.
closing days of a campaign stations
joint users.
3. Q. If a candidate prior to April 7,
should be required to accommodate re-
(5) Certifications should be obtained
1972, has contracted for use of a station
quests for political time to the exclusion
for each individual use or series of uses
both prior to April 7. 1972, and after that
of all or most other types of program-
of a station for which & candidate con-
date, must the station obtain the certifi-
ing or advertising. Important as an in-
tracts. (E.g., if one contract is for 100
cation required under section 315 (c) or
formed electorate is in our society, there
spots, only one certification is
(d) for the broadcasts which occur after
are other elements in the public interest
necessary.)
April 7, 1972?
standard, and the public is entitled to
(6) The certification need not be in
A. Yes. A certification must be ob-
other kinds of programing than politi-
any special form. It may, for example, be
tained in all cases where a station is
cal. It was not intended that all or most
incorporated into a standard contract
making a charge for use of the station by
time be preempted for political broad-
or start order.
or on behalf of a legally qualified candi-
casts. The foregoing appears to be the
(7) Certifications must, pursuant to
date on and after April 7, 1972. No certi-
only definite statement that may be made
paragraph (d) [c] of the Commission's
about the new section, since no all-
rules, be placed in the station file which
fication for uses of a station prior to
embracing standard can be set. The test
April 7, 1972, is necessary.
is available for public inspection, and re-
of whether & licensee has met the re-
VIII-SECTION 312-REASONABLE ACCESS
quirement of section is one of
tained for a period of 2 years. If the cer-
reasonableness. The will not
tification is made by a duly authorized
VIII. 1. Q. To what candidates do the
substitute its judgment for that of the
person as mentioned in (3) above, the
provisions of section 312(a) (7) apply?
licensee, but, rather, it will determine in
FEDERAL REGISTER, VOL 37, NO. 55-TUESDAY, MARCH 21, 1972
NOTICES
5805
any case that may arise whether the li-
to a broadcast by candidate B. paid for
A. Under the provisions of the Com-
censee can be said to have acted reason-
by candidate B. which occurred after
mission rules, noncommercial educa-
ably and in good faith in fulfilling his
candidate A had reached his spending
tional stations operating on channels
obligations under this section.
limit. must the station provide free time
reserved for noncommercial educational
We are aware of the fact that a myriad
to candidate A?
use are not permitted to levy charges for
of situations can arise that will present
A. No. Candidate A cannot furnish the
time-for political broadcasts or other-
difficult problems. One conceivable
necessary certification that purchase of
wise. Some such stations presently are
method of trying to act reasonably and
time on the station would not result in
providing political programing without
in good faith might be for licensees, prior
a violation of the spending limitation.
charge, and it appears that as a practical
to an election campaign for Federal
8. Q. Some stations have in the past
matter the new provision will not greatly
offices, to meet with candidates in an
had the policy of not selling short polit-
alter their practices. On the other hand,
effort to work out the problem of rea-
ical spot announcements (e.g., 10 sec-
those stations that do not engage in such
sonable access for them on their stations.
onds, 1 minute) on the ground that they
programing will be required under the
Such conferences might cover, among
did not contribute to an informed elec-
new law to provide reasonable access to
other things, the subjects of the amount
torate. In light of the enactment of sec-
candidates without charge. Noncommer-
of time that the station proposes to sell
tion 312(a) (7), may stations ha such
cial educational stations that are operat-
or give candidates, the amount and types
policies, or must they sell reasonable
ing on unreserved channels, and non-
of its other programing. the 7-day rule,
numbers of short spots to legally quali-
profit stations that are not educational,
and the amount of advertising it pro-
fied candidates for Federal office if
e.g., those offering religious broadcast-
poses to sell to commercial advertisers.
requested?
ing, may charge for political broadcast
4. Q. Do the provisions of section 312
A. We have, prior to the enactment of
time (if their charters or articles of in-
(a) (7) apply to persons or groups re-
section 312(a) (7), when station were
corporation permit them to make time
questing access to or purchase of time
on a station for themselves as spokesmen
(under the provisions of section 315) not
charges) although it is their policy nor-
on behalf of a candidate?
required to allow use of their facilities
mally not to charge for any time. If they
by particular candidates for nublic office.
do charge, notice must be given to the
A. No. The section applies only to TP-
ruled that licensees may have such pol-
Conumission 01 this change in operation.
quests for "use" of a station by a candi-
icies. In so ruling, we have cautioned
The lowest unit charge provisions of
date. The standard of what constitutes
a "use" of a station for purposes of ad-
that licensees have the public interest
section 315(b) cannet apply to such
ministering section 312(a) (7) is the same
consideration of making their facilities
stations since they have no rates on
as the standard concerning "equal op-
available to candidates, but have left to
which to base such a charge. However,
portunities" under section 315(a). That
the good-faith judgment of the licensee
any charges made must be reasonable
standard is elaborated in sections III.
the determination of how the facilities
when viewed in the light of charges made
were to be used to serve the public in-
hr coromorcial stations in the same
A. and E. of the 1970 primer and subsc-
terest. As complaints arose, we looked to
broadcast service licensed to serve the
quent rulings. (See also Q. and A. VI.14.
the reasonableness of that judgment in
same community. If the charges made by
above.) With regard to spokesmen for
candidates, a licensee must govern its
a particular fact pattern. (31 FCC 2d 782
nonprofit stations are unduly high, it is
(1971).) Section 312(a) (7) now imposes
conceivable that they might be construed
conduct by the "public interest, conven-
ience. or necessity" standard of sections
on the overall obligation to operate in
as an attempt to circumvent the reason-
the public interest the additional specific
able access provision of section 312
307 and 309 of the Communications Act
requirement that reasonable access and
(a) (7). Noncommercial educational sta-
discussed in Q. and A. VIII.3. above. See
also Letter to Nicholas Zapple, 23 F.C.C.
purchase of reasonable amounts of time
tions and nonprofit stations. whether
2d 707 (1970).
be afforded candidates for Federal office.
giving free time for political broadcasts
5. Q. Does the "reasonable access" pro-
We shall, under this new section, apply
or charging for such time, may make
vision of section 312(7) require com-
the same test of reasonableness of the
necessary charges for production-
mercial stations to give free time to
judgment of the licensee. Thus whether
oriented services, and for other things
legally qualified candidates for Federal
a refusal to sell short political spots
of the type mentioned in Q. and A. VI.15.
elective office?
would or would not violate the provisions
above.
A. No, but the licensee cannot refuse
of the new section would depend on the
11. Q. Does the "reasonable access"
to give free time and also to permit the
circumstances in which the refusal OC-
provision of section 312(a) (7) require
purchase of reasonable amounts of time.
curred. The same would apply to similar
a cable television system that lacks ca-
If the purchase of reasonable amounts
situations, e.g., in cases where a station
blecasting facilities to provide such fa-
of time is not permitted, then the station
has a policy of not placing political spots
cilities upon receipt of a request for
is required to give reasonable amounts
on news programs.
access to or purchase of time on a
of free time.
9. Q. Does section 312(a) (7) apply to
system?
6. Q. If a commercial station gives rea-
noncommercial educational stations, and
A. No. A cable system that lacks cable-
sonable amounts of free time to candi-
other nonprofit stations. as well as to
casting facilities, other than for auto-
dates for Federal elective office, must it
commercial stations?
mated services, and is not required by the
also permit purchase of reasonable
A. Yes. There are no provisions in the
Commission's Rules to have them, need
amounts of time?
Campaign Communications Reform Act
not provide such facilities upon receipt
A. No. A commercial station is re-
exempting such stations, nor is there
of a request for access to or purchase of
quired either to provide reasonable
anything in the legislative history of the
time on the system.
amounts of free time or permit purchase
Act that would indicate that such an
Adopted: March 15, 1972.
of reasonable amounts of time. It is not
exemption was intended. Both types of
required to do both.
stations would be required to give rea-
FEDERAL COMMUNICATIONS
7. Q. If candidate A has spent the
sonable access to legally qualified candi-
COMMISSION,"
maximum amount of funds permitted
dates for Federal elective office.
[SEAL]
BEN F. WAPLE,
him under the limitation set by section
10. Q. May noncommercial educa-
Secretary.
104(a) (1), (2), or (3) of the Campaign
tional stations and nonprofit stations
[FR Doc.72-4289 Filed 3-20-72;8:48 am]
Communications Reform Act and re-
charge for broadcast time by or on behalf
quests "equal opportunity" under the
of legally qualified candidates for Fed-
Commissioners Johnson and H. Rex Lee
provisions of section 315(a) to respond
eral elective office?
not participating.
FEDERAL REGISTER, VOL. 37, NO. 55-TUESDAY, MARCH 21, 1972
3/24/72
QUESTIONS AND ANSWERS
GENERAL INFORMATION
1. Who is responsible for administering the provisions of the
Act pertaining to statements of registration and reports of
receipts and expenditures?
The Act designates three "supervisory officers" to administer
Title III of the Act covering disclosure of campaign funds in
campaigns for Federal office. The supervisory officers are (1)
the Secretary of the Senate for reports pertaining to Senators, and
(2) the Clerk of the House of Representatives for reports pertaining
to Representatives, Delegates, and Resident Commissioners to Congress;
(3) the Comptroller General of the United States for reports pertaining
to candidates for President and Vice President, and in other cases.
2.
How will questions be resolved regarding the interpretation of
the requirements in the Act for which the Comptroller General
is responsible?
Questions regarding matters for which the Act designates the
Comptroller General as responsible supervisory officer and for other
matters should be submitted in writing. The Comptroller General will
issue interpretations, interpretive rulings, and advisory opinions
as may be required. Questions should be addressed to:
Director, Office of Federal Elections
U.S. General Accounting Office
441 G Street, NW.
Washington, D.C. 20548
Telephone: 202-386-6411
Copies of regulations, political committee registration forms,
and financial report forms may also be obtained this way.
3. During what hours will the Office of Federal Elections be open for
business?
The Office will be open from 9 a.m. to 5 p.m., Monday through
Friday, except Federal holidays. When pre-election reports for
presidential elections are being filed, the Office will also be open
on Saturdays from 9 a.m. to 5 p.m.
- 1 -
4. Will copies of financial reports filed by candidates and
political committees be available from the General Accounting
Office (GAO)?
Yes. Financial reports and registration statements filed will
be available for public inspection and copying at the Office of Federal
Elections in the GAO and also at State capitals. Requests for copies
can be made in person or in writing. Copies will be made available
at a cost per page to be posted. Persons submitting requests for copies
by mail will be billed for the cost of mailing in addition to the cost
of producing the requested copies. (NOTE: The law states that information
obtained from the reports and registration statements is not to be sold
or used for the purpose of soliciting contributions or for any commercial
purpose.)
5. Will copies of reports filed by candidates and political committees
be printed and made available to the public?
Yes. Copies of the statements of organization and all financial
reports filed by each political committee during the calendar year will
be printed by the Public Printer and sold to the public by the Superintendent
of Documents. The Comptroller General is required to compile and furnish
to the Public Printer by March 31 each year an annual report for each
political committee containing copies of all reports filed, together
with a copy of the statement of organization. The reports should be
available to the public within a reasonable time after that date.
6. Will copies of statements of organization and reports of
receipts and expenditures filed with State officers be
available for public inspection and copying?
Yes. The law requires this. A charge will be made for copies
furnished.
7. Is there a legal limit on the amount which individuals may
contribute to a candidate or political committee?
There is no legal limit on the amount that individuals may contribute
to a candidate or political committee. There are limitations, however,
on expenditures which a candidate for Federal elective office may make
from his personal funds or the personal funds of his immediate family.
The legal limits are:
(1) $50,000 for a candidate for the Office of President or
Vice President.
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(2) $35,000 for a candidate for the office of Senator.
(3) $25,000 for a candidate for the office of Representative,
or Delegate or Resident Commissioner to the Congress.
The candidate's immediate family includes the candidate's
spouse, and any child, parent, grandparent, brother or sister of
the candidate, and their spouses. These limitations are contained in
Title II of the Act as an amendment to Title 18 of the United States
Code.
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STATEMENTS OF ORGANIZATION
OF POLITICAL CONNITTEES
1. Who is required to register with the U.S. General Accounting Office
under the Federal Election Campaign Act of 1971?
Every political committee (committee, association, or organization)
which anticipates receiving contributions or making expenditures during a
calendar year of more than $1,000, any portion of which will be expended
for or on behalf of candidates for the office of President or Vice President
of the United States. The same registration requirements apply to political
committees receiving contributions and making expenditures for or on
behalf of candidates for senator and representative of the U.S. Congress.
2. When are political committees required to register?
A statement of organization is required to be filed within 10 days
after its organization or 10 days after the committee has information which
causes it to anticipate receiving contributions or spending over $1,000,
whichever is later. Since, however, many committees will have met this
criteria by April 7, 1972, the effective date of the Act, they are required
to file a registration statement by April 17, 1972. Registration forms may
be obtained from the U.S. General Accounting Office, Secretary of the Senate,
or Clerk of the House of Representatives.
3. Is there a specific form to be used by political committees supporting
candidates for President and Vice President in filing statements of
organization?
Yes. Form CG-1 is to be used in filing a statement of organization.
This form may be obtained from the Office of Federal Elections, U.S. General
Accounting Office, 441 G Street, NW., Washington, D.C. 20548.
4. If a political committee expects to receive contributions or spend
over $1,000 for candidates for Senator or Representative to the
U.S. Congress in addition to the office of President, are separate
statements of organization required to be filed?
Yes. If the political committee expects to receive contributions or
spend more than $1,000 for or on behalf of candidate(s) for senator or
representative, registration statements should be filed, as appropriate,
with the:
Secretary of the Senate
Clerk of the House of
Room S-221
and/or
Representatives
Capitol Building
Room 1036 Longworth House
Washington, D.C. 20510
Office Building
Washington, D.C. 20515
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5. How is information included in registration statements changed?
For example, how is a change in the position of chairman or treasurer
for a political committee to be reported?
If the change involves, for example, only a change in the name of the
chairman or treasurer, it may be reported by letter. The notification should
identify the name of the political committee, address, and registration
number in addition to the names of the old and new officers. If the changes
are extensive, revised registration statements should be filed.
6. The statement of organization must include the names, addresses, and
relationships of affiliated or connected organizations. What is meant
by the term "affiliated or connected organizations"?
Affiliated or connected organizations includes but is not limited to
(1) an organization which organized the reporting committee primarily for
the purpose of influencing the nomination or election of candidates for
Federal office; or (2) an organization whose primary purpose is to support
the reporting committee; or (3) an organization whose membership is generally
similar to that of the reporting committee.
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REPORTING OF RECEIPTS AND EXPENDITURES
BY
CANDIDATES, POLITICAL COMMITTEES, AND OTHER PERSONS
1.
Who is required to file reports of receipts and expenditures
of campaign funds for Federal office with the Comptroller
General of the United States?
Periodic reports are required to be filed by:
a. Every candidate for nomination or election to the
office of President or Vice President of the United
States.
b. Every political committee which supports a candidate
or candidates for nomination or election to the office
of President or Vice President and receives contributions
or spends more than $1000 in a calendar year.
C. Any person (other than a candidate or political committee)
who makes contributions or expenditures, other than by
contribution to a candidate or political committee, in excess
of $100 during a calendar year.
2. Is there a specific form to be used by candidates, political
committees, and other persons in filing reports of receipts
and expenditures of Federal campaign funds?
Yes. Form CG-3 is to be used by political committees and other
persons; Form CG-2 is to be used by candidates for the offices of
President or Vice President. The form may be obtained from the Office
of Federal Elections, U.S. General Accounting office, 441 G Street, NW.,
Washington, D.C. 20548. The form contains instructions regarding the
information and data required to be reported.
3.
How many copies of the Report of Receipts and Expenditures
(Form CG-3) should be filed by political committees with
the Office of Federal Elections and the State officer?
a. An original is required to be filed with the Office of
Federal Elections. (This may be hand delivered or sent
in preprinted return envelopes supplied by the Office
of Federal Elections. The special envelopes request
priority handling by the U.S. Postal Service.)
b. One copy is required to be filed with the State officer
(e.g., Secretary of State) of the State or other jurisdiction
where the committee has its principal office.
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4. Under what conditions can a political committee be relieved
of filing reports of receipts and expenditures with the
Comptroller General?
Political committees do not have to file financial reports if:
a. The committee is a local, city, or county committee
and does not conduct its activities throughout the State
or in any other State; and
b. The committee primarily supports persons seeking State
or local office; and
C. The committee does not make contributions or expenditures,
including transfers of funds to any other political
committee, in support of a candidate for nomination or
election to the office of President or Vice President of
the United States in an aggregate amount exceeding $1,000
in a calendar year. A contribution or expenditure in
support of a candidate for Vice President is considered to
be made on behalf of the candidate for President with whom
he is running.
5. When do reports of receipts and expenditures have to be filed
by candidates, political committees, and other persons?
Reports are required to be filed on March 10, June 10, September 10,
and January 31, for each calendar year and on the fifteenth and fifth
days next preceding each presidential primary and general election and
national nominating convention. The reports shall be cumulative and
each report will cover the period from the closing date of the previous
report filed.
6. What information is required to be reported for each
contributor in an amount in excess of $100?
a. Full name
b. Residence mailing address, including zip code
C. Occupation
d. Principal place of business, if any
The occupation should be identified by the title, if any, or
type of work. The principal place of business should be
identified by the full name of the contributor's employer
or organization if self employed, and city of employment or
self-employment.
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This information should be stated identically on each report
if the information remains unchanged. If any of the items should
change during the calendar year, the exact name and address pre-
viously used should be shown with subsequent entry, as well as
the new information.
7.
If several contributions of less than $100 are received from
a contributor which aggregate more than $100 during the
calendar year, is it necessary to report his name, address,
and other required information?
Yes. Special instructions are contained on Schedule A on how
these situations are to be accounted for and reported.
8.
Do all contracts, agreements, or promises to make contributions
need to be reported to the Office of Federal Elections?
No. They are required to be reported only if they are made in
advance of actual payment, are made in writing, and exceed the
amount of $100.
9. Is a report required to be filed when a political committee
disbands?
Yes. Any committee which previously filed a statement of
organization is required to notify the Comptroller General when it
disbands. The notification should include a statement as to the
disposition of residual funds or debts.
A committee must continue reporting its debts and obligations
until extinguished.
10. Are any expenditures made before April 7, 1972, required
to be reported?
Yes. If an expenditure is made before April 7, 1972, for the
use of communications media after that date, it must be reported and
charged against the candidate's limitation applicable to the election
in which used. Other contributions received or expenditures made
before April 7, 1972, need not be reported.
11. Who is required to file reports of receipts and expenditures
other than candidates and political committees?
Every person who makes contributions or expenditures, other than
by contribution to a political committee or candidate, in an aggregate
amount in excess of $100 within a calendar year. These reports are
required to be filed on the dates on which reports by political
committees are filed and contain the same information, except they
need not be cumulative.
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12. The law defines contributions as a gift, subscription, loan,
advance, a deposit of money, or "anything of value." How
should the dollar value of contributions in kind (anything of
value) be determined for reporting purposes?
The dollar value of contributions in kind should be determined
by the contributor. It should be the fair market value of the item
contributed; i.e., the value of the item if it were to be purchased
or sold. The candidate or political committee receiving the contri-
bution, however, should question the value placed on an item if it
appears unreasonable. Contributions in kind must be reported on
Schedule A appropriately labelled.
13. Is it acceptable to submit required reports of contributions and
expenditures on computer tapes or disks?
Since the Comptroller General is required to make reports filed
available for public inspection and copying no later than the second
day after receipt, it is necessary that printed copies of the report
be filed. The Office of Federal Elections, however, may find the
computer tapes or disks helpful in preparing the yearly compilation
reports. The use of them, therefore, should be offered to the Office
of Federal Elections. Where printed reports are made with the use of
a computer, the reports should provide the same information required
by the report forms.
14. The law requires that any contribution of $5,000 or more
received after the closing date for the last report filed by
a political committee, but prior to a primary, general, or
other election, shall be reported within 48 hours after its
receipt. Do transfers between political committees have. to
be reported under this requirement?
Yes. The definition of contribution contained in Section 301
of the law includes "a transfer of funds between political committees."
Reports of $5,000 contributions during the required period should be
filed on Form CG3 or by telegram. Other items included in the
definition of "contribution" are:
a. A gift, subscription, loan advance, or deposit
of money or anything of value.
b. A contract, promise, or agreement, whether or not
legally enforceable, to make a contribution.
C. The payment by any person other than a candidate or
political committee of compensation for the personal
services rendered to a candidate or committee without
charge to them.
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15. Who is required to file reports on national conventions?
Committees or organizations which:
a. Represent a State (or a political subdivision thereof)
or any group of persons in dealing with national party
officials with respect to a nominating convention.
b. Represent a national party in making arrangements for
a nominating convention.
The reports must be made within 60 days following the convention
but not later than 20 days prior to date of the general election, on
forms prescribed by the Office of Federal Elections.
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REPORTS BY COMPTROLLER GENERAL
1.
What types of reports will be prepared and published by
the Comptroller General on contributions and expenditures
by and on behalf of candidates for the Office of President of the
United States?
At the end of each calendar year the Comptroller General will
prepare and publish an annual report of:
a. Total reported contributions and expenditures for all
candidates, political committees, and other persons
during the year.
b. Total amounts expended according to such categories as
he shall determine and broken down into candidate, party
and nonparty expenditures on the National, State, and local
levels.
C. Total amounts expended for influencing nominations and
elections stated separately.
d. Total amounts contributed according to such categories
of amounts as he shall determine and broken down into
contributions on the national, State, and local levels
for candidates and political committees.
e. Aggregate amounts contributed by any contributor shown
to have contributed in excess of $100.
In addition, special reports will be prepared from time to time (1) com-
paring various totals and categories of contributions and expenditures
made with respect to preceding elections and (2) others as deemed
appropriate.
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MEDIA RATES
1.
Who is responsible for administering the provisions of the Act
pertaining to charges for use of communications media?
The Federal Communications Commission has this responsibility
for charges relating to the use of broadcasting stations. (See
Guidelines of the Federal Communications Commission). The Comptroller
General of the United States has this responsibility for charges
relating to the use of newspapers and magazines.
2.
How will a candidate know if he is being charged the correct
amounts for use of broadcasting facilities, newspapers, or
magazines for campaign purposes?
The broadcasting stations, newspapers, and magazines are
required to make information available which will disclose the rate
structures. The law limits charges for broadcasting to the lowest
unit charge of the station for the same class and amount of time
for the same period. The limitations on rate charges apply during
the 45-day period preceding a primary and during the 60-day period
preceding the general election.
3.
If a candidate, in connection with his campaign for nomination
or election to a Federal elective office, believes that he has
been charged an amount in excess of the lowest unit charge by
a broadcasting station, what action may he take?
The Federal Communications Commission has the responsibility
to prescribe regulations for Section 103(a) pertaining to charges
for use of broadcasting stations. The candidate therefore, may file
a complaint with the FCC alleging that the broadcasting station
has violated Section 103(a) of the Act.
4.
If a candidate for President or Vice President or for the Senate
or House believes that he has been charged for space in a newspaper
or magazine an amount exceeding the charges made for comparable
use of such space for other purposes, what action may he take?
The candidate may file a complaint with the Comptroller General
alleging that the newspaper or magazine has violated Section 103(b)
of the Act. After an investigation, if it is believed that a violation
has occurred, the matter will be referred to the Attorney General.
Before filing a complaint, however, the candidate should make reasonable
efforts to resolve the difference. If a complaint is filed, a copy
should be sent to the newspaper or magazine involved in the complaint.
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5.
If questions arise on spending for the use of communications
media by candidates or in behalf of candidates for Federal
elective office, how can the answers to them be determined?
By writing or calling:
Office of Federal Elections
U.S. General Accounting Office
441 G Street, N.W.
Washington, D.C. 20548
Telephone: 202-386-6411
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LIMITATIONS ON EXPENDITURES FOR
COMMUNICATIONS MEDIA
1.
How much can legally qualified candidates for the office of
President spend for use of communications media in political
campaigns?
Candidates can spend up to the following amounts:
Pre-Nomination
General Election
An amount equal to 10c times
An amount equal to 10c times
the voting age population of
the combined voting age population
the State, District of
in the United States, District of
Columbia or Puerto Rico.,
Columbia, and Puerto Rico.
but not less than $52,150 in
each jurisdiction during
1972.
These amounts, however, will change in future years by the percentage
that the price index increases or as voting age population estimates
change. The Comptroller General each year will determine the amount
of expenditure limitation for each State and congressional district
and for the nation, and will publish them in the Federal Register.
They will also be made available to all candidates, political
committees, and other interested persons through general distribution.
2.
How will a congressional candidate know if the amount he can spend
exceeds the $52,150 limitation if he doesn't know the voting age
population?
On or before April 7, 1972 (during the first week in January in
future years), the Secretary of Commerce will provide and certify to the
Comptroller General and publish in the Federal Register an estimate of
the voting age population of each State and congressional district.
These estimates will be the basis for determining the total amount that
can be spent for communications media. Tables showing the voting age
population by State and congressional district are available from the
General Accounting Office, as well as the limitation amounts.
3. Are there any other limitations that apply to spending for use of
communications media?
Yes. Of the total amount that candidates for President or Congress
are authorized to spend for use of communications media, they may spend up
to 60 percent for use of "broadcasting stations." Broadcasting stations are
TV and radio stations and CATV systems. Other communications media are
newspapers; magazines; outdoor advertising facilities: and telephones,
under certain conditions. Tables showing the expenditures authorized to
be made by candidates for communications media will be available from the
General Accounting Office.
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4.
Does the limitation apply separately to candidates for President
and Vice President?
Not in the general election period. For purposes of the spending
limitation for communications media, the office of President includes
both the President and Vice President.
5. Will records be kept by the supervisory officers which will disclose
whether candidates have exceeded the expenditure limitations for
communications media?
The supervisory officers will periodically receive financial reports
on all contributions and expenditures from candidates and political
committees. However, it is the responsibility of each candidate for Federal
elective office to maintain accurate and complete records of expenditures
for communications media for use in controlling expenditures and making
sure that limitations are not exceeded.
6.
If a candidate decides to spend for communications media less than
his overall limitation, will this in any way affect the candidate's
broadcasting limitation? For example, if a candidate has available
$40,000 to spend on communications media and his overall spending
limitation is $60,000 is his broadcasting spending limitation
$24,000 (60 percent of $40,000) or $36,000 (60 percent of $60,000)?
The candidate may spend for broadcasting purposes up to 60 percent
of his overall limitation for communications media. In the example above,
the candidate can spend up to $36,000 for use of broadcasting stations.
7. For purposes of determining the communications media expenditure
limitations, is each primary, general, special, and runoff election
treated separately?
Yes. A new expenditure limitation is applicable to each separate
election. No amount is carried over from one election to another.
8. Are communications media expenses charged against the candidate's
expenditure limitations at the time the medium is used or at the
time of payment?
Communications media expenses are to be charged against the limitation
in the election in connection with which the medium is used. Therefore,
commitments and expenditures made for the use of media on or after April 7,
1972, are required to be charged as appropriate against limitations
applicable to elections held after that date. No charges will be made
against the limitations if the use preceded April 7, 1972.
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9.
How will a newspaper, magazine, or outdoor advertising company
know whether a candidate is exceeding his expenditure limitation
for communications media?
The candidate or his authorized representative is required to
certify in writing that the payment for the use of the communications
media used will not violate the expenditure limitation.
10.
If a candidate for presidential nomination makes a campaign
speech on television or radio in a State where a primary is
to be held and the broadcast reaches significant portions of
nearby States, is the cost of the broadcast required to be
apportioned among all States affected? If so, how are these
costs to be apportioned and by whom?
If the candidate intends to reach persons in only one State in
which he is actively seeking primary votes or convention delegates,
then no apportionment is made and the total expenditure is attributed
to the one State. If he intends to reach persons in two or more States
in which he is actively seeking primary votes or convention delegates,
the amount will be apportioned among such States. However, after the
selection of all delegates to a national convention is completed and
before the convention, the total amount must be apportioned among all
the States reached by the broadcast.
11. If political committees or individual persons pay for the use of
broadcasting stations, newspapers, or magazines to benefit a
candidate's campaign, are these payments applied to the candidate's
limitations?
Yes. Amounts spent for the use of communications media on behalf of
any legally qualified candidate for Federal elective office are deemed to
have been spent by the candidate if the use (1) involves his participation
by voice or image or advocates his candidacy; or (2) identifies the
candidate, directly or by implication, or advocates his candidacy. The
candidate, therefore, will need to maintain records of all expenditures for
communications media in his behalf to make sure he does not exceed the
limitations provided by the law. Political committees and other persons,
as well as candidates, are required to report these expenditures as
outlined in Titles I and III of the Act.
12. Are amounts spent by a candidate, or a political committee or other
person in behalf of a candidate, for use of communications media to
urge an opponent's defeat or derogating an opponent's stand on
campaign issues chargable against the spending limitation of the
candidate?
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Candidate A is not charged with amounts spent attacking any of his
opponents unless he directly or indirectly authorizes the spending.
The media may charge for such spending by other persons, provided that
the person signs a statement that he is not authorized by candidate A
and the media takes reasonable precautions. In such case, the ad must
contain a conspicious disclaimer. Criminal penalties apply to false
or fraudulent statements by any such person.
13. If a candidate for presidential nomination has not reached his
spending limit in 45 states but has reached his limit in 5 states,
can he have a paid nationwide telecast before his party's national
convention?
No. Unless the five states are blackedout, he will be exceeding
his spending limit in those states, and thus be in violation of Title I
of the Act.
14. How will expenditures for television and radio and other media in
two or more states by candidates for presidential nomination be
apportioned?
The broadcasting station or the network will inform the candidate
of its "primary service" coverage in each state reached. This will be
estimated based on the Grade B contour for television, the 1 mv/m contour
for FM radio, and the daytime and nighttime coverage for AM radio. These
are technical terms which are defined by FCC standards. Newspapers,
magazines and outdoor advertising companies will inform the candidate
of their coverage in each state.
15. If two or more candidates for Federal Election office combine in
a single use of a particular communications media, how should the
amounts attributable to the expenditure limitation of each candi-
date be determined?
The distribution of the single expenditure among the candidates
involved should be made on a reasonable basis and as agreed upon and
certified by them.
16. Are agent's commissions included in the amount charged to the media
spending limitations?
Yes. If they are agents commissions allowed the agent by the media,
they are included within the amount charged to the candidate's spending
limitation and must be included in the candidates' certification to the
media.
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STATEMENT BY THE COMPTROLLER GENERAL OF THE UNITED STATES
ELMER B. STAATS
The Federal Election Campaign Act of 1971, approved by the
President February 7, 1972, represents a major departure from previous
legislation governing Federal elections. The Act, effective on April 7,
1972, imposes dollar limitations for the first time on spending by
candidates for media use and, in addition, requires full disclosure of
contributions and expenditures by candidates and their political
committees for all purposes.
The Comptroller General of the United States has the responsibility
for promulgating regulations to carry out the requirements and restrictions
relating to the use of newspapers, magazines, outdoor advertising and
telephones. Similar regulations pertaining to radio and television are
the responsibility of the Federal Communications Commission.
The Act establishes three supervisory officers to administer Title III
of the Act, "Disclosure of Federal Campaign Funds." This Title sets forth
detailed provisions for the recording, reporting and making public virtually
all campaign contributions and expenditures.
While the time for development of the regulations has been brief,
there is agreement among the Comptroller General, the Federal Communications
Commission, the Secretary of the Senate, and the Clerk of the House that
it is important to have the regulations go forward at the earliest
practicable time in order to allow maximum opportunity for all individuals
and committees concerned to become familiar with the provisions of the Act
and the implementing regulations. The three supervisory officers are in
full agreement with respect to the detailed reporting provisions required
by the Act. Similarly, consistent regulations have been developed with
respect to Title I between the Comptroller General and the Federal
Communications Commission.
We intend that these regulations will serve the objective the
Congress sought to attain in the best way possible. This is a difficult
area in which to regulate and, while we have attempted to anticipate
as many problems as possible in the time available, there is no sure
way in which regulations--or a statute, either--can be drawn so as to
cover specifically every imaginable situation.
I think the regulations are sound and workable but I would expect
that, despite our best efforts, both the media and the candidates
themselves may discover difficult administrative problems from time to
time which we could not foresee.
It has to be said, however, that no law or set of regulations
can be self-executing; nor when restraints or administrative requirements
are imposed, such as here, are they entirely painless. So, in the final
analysis, it is only through the efforts of the media and the candidates
themselves that the overall objectives and the intent of the law can be
achieved.
I have established an Office of Federal Elections in the U.S. General
Accounting Office, 441 G Street, NW., Washington, D.C., to assist me in
carrying out the duties assigned by the Act.
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