Candidate Debates, 72616-72618 [2015-29494]
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[FR Doc. 2015–29676 Filed 11–19–15; 8:45 am]
BILLING CODE 6450–01–P
FEDERAL ELECTION COMMISSION
11 CFR Part 110
[Notice 2015–11]
Candidate Debates
Federal Election Commission.
Notice of Disposition of Petition
for Rulemaking.
AGENCY:
ACTION:
The Commission announces
its disposition of a Petition for
Rulemaking (‘‘petition’’) filed on
September 11, 2014, by Level the
Playing Field. The petition asks the
Commission to amend its regulation on
candidate debates to revise the criteria
governing the inclusion of candidates in
presidential and vice presidential
candidate debates. The Commission is
not initiating a rulemaking at this time.
DATES: November 20, 2015.
ADDRESSES: The petition and other
documents relating to this matter are
available on the Commission’s Web site,
www.fec.gov/fosers (reference REG
2014–06), and in the Commission’s
Public Records Office, 999 E Street NW.,
Washington, DC 20463.
FOR FURTHER INFORMATION CONTACT: Mr.
Robert M. Knop, Assistant General
SUMMARY:
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Counsel, or Ms. Jessica Selinkoff,
Attorney, 999 E Street NW.,
Washington, DC 20463, (202) 694–1650
or (800) 424–9530.
SUPPLEMENTARY INFORMATION: On
September 11, 2014, the Commission
received a Petition for Rulemaking from
Level the Playing Field regarding the
Commission’s regulation at 11 CFR
110.13(c). That regulation governs the
criteria that debate staging organizations
(which the petitioner refers to as
‘‘sponsors’’) use for inclusion in
candidate debates. The regulation
requires staging organizations to ‘‘use
pre-established objective criteria to
determine which candidates may
participate in a debate’’ and further
specifies that, for general election
debates, staging organizations ‘‘shall not
use nomination by a particular political
party as the sole objective criterion to
determine whether to include a
candidate in a debate.’’ 11 CFR
110.13(c). The petition asks the
Commission to amend 11 CFR 110.13(c)
in two respects: (1) To preclude
sponsors of general election presidential
and vice presidential debates from
requiring that a candidate meet a polling
threshold in order to be included in the
debate; and (2) to require sponsors of
general election presidential and vice
presidential debates to have a set of
objective, unbiased criteria for debate
participation that do not require
candidates to satisfy a polling threshold.
The Commission published a Notice
of Availability seeking comment on the
petition on November 14, 2014.
Candidate Debates, 79 FR 68137. The
Commission received 1264 comments in
response to that notice. One comment,
that of an organization that stages
presidential and vice presidential
debates, opposed the petition; the
remaining comments either supported
the petition or took no position thereon.
The petition and many of the
comments supporting it argue that a
staging organization’s requirement that a
candidate meet a polling threshold for
inclusion in a debate unfairly benefits
major party candidates at the expense of
independent and third party candidates.
As an alternative, the petition and some
of the comments proposed requiring
staging organizations to include each
candidate who has qualified for the
general election ballot in states that
collectively have enough Electoral
College votes for the candidate to attain
the presidency.1 The petition states that
1 Specifically, the petitioner proposes that a
presidential candidate who, at a given date during
the election year, has secured ballot access in states
that collectively have at least 270 Electoral College
votes (of a total possible 538 votes), could
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Federal Register / Vol. 80, No. 224 / Friday, November 20, 2015 / Proposed Rules
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this would provide an objective, and
more inclusive, criterion preferable to
polling thresholds. Other commenters
did not necessarily support or oppose
the petitioner’s proposed alternative but
supported a rulemaking to determine if
changes are warranted. Still other
commenters proposed alternative and
additional rule modifications for the
Commission’s consideration, such as a
requirement that debate staging
organizations provide the public with
information about candidates not
included in a debate.
The commenter that opposed the
petition urged the Commission to
continue allowing a debate staging
organization substantial discretion in
formulating the nonpartisan objective
candidate selection criteria of its choice.
This commenter further argued that its
particular polling thresholds are
reasonable and objective selection
criteria adopted for nonpartisan reasons
and designed to advance voter
education. This commenter also
asserted that the petitioner’s proposed
alternative would favor early ballot
qualification by candidates with the
most resources over more meaningful
measures of candidate support and
viability.
The Commission has evaluated the
petition and comments and decided not
to initiate a rulemaking to amend 11
CFR 110.13(c) at this time.
As the Commission stated in adopting
the current candidate debate rule in
1995, ‘‘the purpose of section 110.13
. . . is to provide a specific exception
so that certain nonprofit organizations
. . . and the news media may stage
debates, without being deemed to have
made prohibited corporate contributions
to the candidates taking part in
debates.’’ Corporate and Labor
Organization Activity; Express
Advocacy and Coordination with
Candidates, 60 FR 64260, 64261 (Dec.
14, 1995).2 Accordingly, the
Commission has required that debate
‘‘staging organizations use preestablished objective criteria to avoid
the real or apparent potential for a quid
pro quo, and to ensure the integrity and
fairness of the process.’’ Id. at 64262. In
discussing objective selection criteria,
potentially qualify to participate in the general
election debate.
2 See also Funding and Sponsorship of Federal
Candidate Debates, 44 FR 76734 (Dec. 27, 1979)
(explaining that, through candidate debate rule,
costs of staging multi-candidate nonpartisan
debates are not contributions or expenditures); 11
CFR 100.92 (excluding funds provided for costs of
candidate debates staged under 11 CFR 110.13 from
definition of ‘‘contribution’’); 11 CFR 100.154
(excluding funds used for costs of candidate debates
staged under 11 CFR 110.13 from definition of
‘‘expenditure’’).
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the Commission has noted that debate
staging organizations may use them to
‘‘control the number of candidates
participating in . . . a meaningful
debate’’ but must not use criteria
‘‘designed to result in the selection of
certain pre-chosen participants.’’ Id. The
Commission has further explained that
while ‘‘[t]he choice of which objective
criteria to use is largely left to the
discretion of the staging organization,’’
the rule contains an implied
reasonableness requirement. Id. Within
the realm of reasonable criteria, the
Commission has stated that it ‘‘gives
great latitude in establishing the criteria
for participant selection’’ to debate
staging organizations under 11 CFR
110.13.3 First General Counsel’s Report
at n.5, MUR 5530 (Commission on
Presidential Debates) (May 4, 2005),
https://eqs.fec.gov/eqsdocsMUR/
000043F0.pdf.
The Commission has a wellestablished history of ensuring that
corporate contributions are not made to
candidates taking part in debates,
including by evaluating the objectivity
and neutrality of a debate staging
organization’s selection criteria in the
Commission’s enforcement process.
Enforcement matters regarding that
issue have involved a wide range of
candidate selection criteria, including
polling thresholds (from 5% to 15%),
campaign finance activity levels (such
as a minimum number of contributors as
shown in reports filed with the
Commission), campaign engagement
levels (such as numbers of yard signs or
participation in neighborhood
association meetings), ballot access, and
office eligibility. See, e.g., First General
Counsel’s Report at 5 n.5, MUR 5530
(Commission on Presidential Debates)
(May 4, 2005), https://eqs.fec.gov/
eqsdocsMUR/000043F0.pdf (including
15% polling threshold and ballot access
criteria). In each of these matters, the
Commission evaluated whether the
criteria were objective, pre-established,
and not arranged in a manner to
promote or advance one candidate over
another so as to constitute corporate
contributions to the participating
candidates.
In these enforcement matters, the
Commission has carefully examined the
use of polling thresholds and found that
they can be objective and otherwise
lawful selection criteria for candidate
debates. Indeed, almost two decades
ago, the Commission found that a
staging organization’s use of polling
data (among other criteria) did not result
3 See Candidate Debates and News Stories, 61 FR
18049 (Apr. 24, 1996) (quoting H.R. Rep. No. 93–
1239 at 4 (1974)).
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72617
in an unlawful corporate contribution,
with five Commissioners observing that
it would make ‘‘little sense’’ if ‘‘a debate
sponsor could not look at the latest poll
results even though the rest of the
nation could look at this as an indicator
of a candidate’s popularity.’’ MUR 4451/
4473 Commission Statement of Reasons
at 8 n.7 (Commission on Presidential
Debates) (Apr. 6, 1998), https://
www.fec.gov/disclosure_data/mur/
4451.pdf#page=459. Citing this
statement, one court noted with respect
to the use of polling thresholds as
debate selection criteria that ‘‘[i]t is
difficult to understand why it would be
unreasonable or subjective to consider
the extent of a candidate’s electoral
support prior to the debate to determine
whether the candidate is viable enough
to be included.’’ Buchanan v. FEC, 112
F. Supp. 2d 58, 75 (D.D.C. 2000).
Because the regulation at issue is
designed to provide debate sponsors
with discretion within a framework of
objective and neutral debate criteria,
and because the Commission can
evaluate the objectivity and neutrality of
a debate sponsor’s selection criteria
through the enforcement process, the
Commission finds that the rulemaking
proposed by the petition is not
necessary at this time. The Commission
concludes that section 110.13(c) in its
current form provides adequate
regulatory implementation of the
corporate contribution ban and is
preferable to a rigid rule that would
prohibit or mandate use of particular
debate selection criteria in all debates.
See 11 CFR 200.5(c) (listing desirability
of proceeding on case-by-case basis as
consideration in declining to initiate
rulemaking); see also MUR 4451/4473
Commission Statement of Reasons at 8–
9 (Commission on Presidential Debates)
(noting that Commission cannot
reasonably ‘‘question[ ] each and every
. . . candidate assessment criterion’’ but
can evaluate ‘‘evidence that [such a]
criterion was ‘fixed’ or arranged in some
manner so as to guarantee a preordained
result’’).
The petition and the commenters who
support it rely primarily on policy
arguments in favor of debate selection
criteria that would include more
candidates in general election
presidential and vice presidential
debates. The rule at section 110.13(c),
however, is not intended to maximize
the number of debate participants; it is
intended to ensure that staging
organizations do not select participants
in such a way that the costs of a debate
constitute corporate contributions to the
candidates taking part. Corporate and
Labor Organization Activity; Express
Advocacy and Coordination with
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Candidates, 60 FR at 64261–62. Staging
organizations’ use of polling criteria is
a reasonable way for a debate staging
organization to select and ‘‘control the
number of candidates participating in
. . . a meaningful debate,’’ id., and to do
so in a way that is objective and does
not constitute a corporate contribution.
A per se rule prohibiting the use of
polling criteria is therefore not
necessary to prevent debates from
constituting unlawful contributions.
Furthermore, the rule at 11 CFR
110.13(c) already permits the use of
criteria by staging organizations that
could result in larger numbers of
candidates participating in debates.
Indeed, the specific criterion that the
petition asks the Commission to include
in a revised section 110.13(c) is already
lawful: A debate staging organization
has the discretion to stage a general
election presidential or vice presidential
debate using selection criteria similar to
the Electoral College approach preferred
by the petitioner (so long as the
organization’s reasonable selection
criteria are pre-established, objective,
and not designed to result in the
selection of certain pre-chosen
participants). No rule change is
necessary to enable that approach, and
the petitioner may sponsor a debate
using such criteria or persuade a debate
sponsor to do so.4
The petition sets forth certain data in
support of its argument that the use of
polling thresholds as a debate selection
criterion by one staging organization
‘‘creates a hurdle that third-party and
independent candidates cannot
reasonably expect to clear,’’ and
therefore is designed to result in the
selection of certain pre-chosen
participants. Petition at 15. The use of
polling data by a single debate staging
organization for candidate debates for a
single office, however, does not suggest
the need for a rule change. The
Commission acknowledges that lower
(or no) polling threshold selection
criteria may open debates to more
candidates and that polling thresholds
could be used to promote or advance
4 If the petitioner (or another entity) is unsure
whether it is a debate ‘‘staging organization’’ as
defined in 11 CFR 110.13(a), it may ask the
Commission for an advisory opinion on the matter.
See, e.g., Advisory Opinion 1988–22 (San Joaquin
Republicans) (concluding that advisory opinion
requestor, which did not yet have relevant tax
status, was not within candidate debate exemption).
Similarly, if a debate staging organization wishes to
ask the Commission to conclude that its proposed
candidate selection criteria are objective and not
designed to result in the selection of certain prechosen participants (and thus protect itself from a
later enforcement action), it may seek an advisory
opinion on that question. See 52 U.S.C. 30108(c)
(establishing scope of protection of advisory
opinions).
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one candidate (or group of candidates)
over another. But to the extent that a
debate staging organization uses nonobjective selection criteria ‘‘designed to
result in the selection of certain prechosen participants,’’ this would
already be unlawful under the
Commission’s existing regulation.
Corporate and Labor Organization
Activity; Express Advocacy and
Coordination with Candidates, 60 FR at
64262.
Finally, the Commission notes that
the petition focuses on and seeks to
amend the rule only with respect to
polling threshold criteria in the
selection of participants for presidential
general election debates. However, the
candidate debate rule applies to all
debates (primary and general election)
‘‘at the presidential, House, and Senate
levels.’’ Funding and Sponsorship of
Candidate Debates, 44 FR 39348 (July 5,
1979).5 In the absence of any indication
that polling thresholds are inherently
unobjective or otherwise unlawful as
applied to all federal elections (and the
Commission is aware of no such
indication),6 the Commission declines
to initiate a rulemaking that would
impose a nationwide prohibition on the
use of such thresholds, or that could
result in giving different legal effect to
the use of polling criterion in different
elections.
For all of the above reasons, the
Commission therefore declines to
commence a rulemaking to amend the
criteria for staging candidate debates in
11 CFR 110.13(c).
On behalf of the Commission.
Dated: November 9, 2015.
Ann M. Ravel,
Chair, Federal Election Commission.
[FR Doc. 2015–29494 Filed 11–19–15; 8:45 am]
BILLING CODE 6715–01–P
5 Indeed, the Commission has analyzed, in the
enforcement context, debate staging organizations’
criteria under 11 CFR 110.13(c) at all levels of
federal elections. See, e.g., MUR 5650 (Associated
Students of the Univ. of Arizona) (Senate debate);
MUR 5530 (Commission on Presidential Debates)
(presidential general election debates).
6 The petitioner provided data intended to
demonstrate that polling figures are sometimes
inaccurate, but the fact that polls can be inaccurate
does not mean that a staging organization acts
unobjectively by using them.
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Federal Aviation Administration
14 CFR Part 25
[Docket No. FAA–2015–4279; Notice No. 25–
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ACTION: Notice of proposed special
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Agencies
[Federal Register Volume 80, Number 224 (Friday, November 20, 2015)]
[Proposed Rules]
[Pages 72616-72618]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-29494]
=======================================================================
-----------------------------------------------------------------------
FEDERAL ELECTION COMMISSION
11 CFR Part 110
[Notice 2015-11]
Candidate Debates
AGENCY: Federal Election Commission.
ACTION: Notice of Disposition of Petition for Rulemaking.
-----------------------------------------------------------------------
SUMMARY: The Commission announces its disposition of a Petition for
Rulemaking (``petition'') filed on September 11, 2014, by Level the
Playing Field. The petition asks the Commission to amend its regulation
on candidate debates to revise the criteria governing the inclusion of
candidates in presidential and vice presidential candidate debates. The
Commission is not initiating a rulemaking at this time.
DATES: November 20, 2015.
ADDRESSES: The petition and other documents relating to this matter are
available on the Commission's Web site, www.fec.gov/fosers (reference
REG 2014-06), and in the Commission's Public Records Office, 999 E
Street NW., Washington, DC 20463.
FOR FURTHER INFORMATION CONTACT: Mr. Robert M. Knop, Assistant General
Counsel, or Ms. Jessica Selinkoff, Attorney, 999 E Street NW.,
Washington, DC 20463, (202) 694-1650 or (800) 424-9530.
SUPPLEMENTARY INFORMATION: On September 11, 2014, the Commission
received a Petition for Rulemaking from Level the Playing Field
regarding the Commission's regulation at 11 CFR 110.13(c). That
regulation governs the criteria that debate staging organizations
(which the petitioner refers to as ``sponsors'') use for inclusion in
candidate debates. The regulation requires staging organizations to
``use pre-established objective criteria to determine which candidates
may participate in a debate'' and further specifies that, for general
election debates, staging organizations ``shall not use nomination by a
particular political party as the sole objective criterion to determine
whether to include a candidate in a debate.'' 11 CFR 110.13(c). The
petition asks the Commission to amend 11 CFR 110.13(c) in two respects:
(1) To preclude sponsors of general election presidential and vice
presidential debates from requiring that a candidate meet a polling
threshold in order to be included in the debate; and (2) to require
sponsors of general election presidential and vice presidential debates
to have a set of objective, unbiased criteria for debate participation
that do not require candidates to satisfy a polling threshold.
The Commission published a Notice of Availability seeking comment
on the petition on November 14, 2014. Candidate Debates, 79 FR 68137.
The Commission received 1264 comments in response to that notice. One
comment, that of an organization that stages presidential and vice
presidential debates, opposed the petition; the remaining comments
either supported the petition or took no position thereon.
The petition and many of the comments supporting it argue that a
staging organization's requirement that a candidate meet a polling
threshold for inclusion in a debate unfairly benefits major party
candidates at the expense of independent and third party candidates. As
an alternative, the petition and some of the comments proposed
requiring staging organizations to include each candidate who has
qualified for the general election ballot in states that collectively
have enough Electoral College votes for the candidate to attain the
presidency.\1\ The petition states that
[[Page 72617]]
this would provide an objective, and more inclusive, criterion
preferable to polling thresholds. Other commenters did not necessarily
support or oppose the petitioner's proposed alternative but supported a
rulemaking to determine if changes are warranted. Still other
commenters proposed alternative and additional rule modifications for
the Commission's consideration, such as a requirement that debate
staging organizations provide the public with information about
candidates not included in a debate.
---------------------------------------------------------------------------
\1\ Specifically, the petitioner proposes that a presidential
candidate who, at a given date during the election year, has secured
ballot access in states that collectively have at least 270
Electoral College votes (of a total possible 538 votes), could
potentially qualify to participate in the general election debate.
---------------------------------------------------------------------------
The commenter that opposed the petition urged the Commission to
continue allowing a debate staging organization substantial discretion
in formulating the nonpartisan objective candidate selection criteria
of its choice. This commenter further argued that its particular
polling thresholds are reasonable and objective selection criteria
adopted for nonpartisan reasons and designed to advance voter
education. This commenter also asserted that the petitioner's proposed
alternative would favor early ballot qualification by candidates with
the most resources over more meaningful measures of candidate support
and viability.
The Commission has evaluated the petition and comments and decided
not to initiate a rulemaking to amend 11 CFR 110.13(c) at this time.
As the Commission stated in adopting the current candidate debate
rule in 1995, ``the purpose of section 110.13 . . . is to provide a
specific exception so that certain nonprofit organizations . . . and
the news media may stage debates, without being deemed to have made
prohibited corporate contributions to the candidates taking part in
debates.'' Corporate and Labor Organization Activity; Express Advocacy
and Coordination with Candidates, 60 FR 64260, 64261 (Dec. 14,
1995).\2\ Accordingly, the Commission has required that debate
``staging organizations use pre-established objective criteria to avoid
the real or apparent potential for a quid pro quo, and to ensure the
integrity and fairness of the process.'' Id. at 64262. In discussing
objective selection criteria, the Commission has noted that debate
staging organizations may use them to ``control the number of
candidates participating in . . . a meaningful debate'' but must not
use criteria ``designed to result in the selection of certain pre-
chosen participants.'' Id. The Commission has further explained that
while ``[t]he choice of which objective criteria to use is largely left
to the discretion of the staging organization,'' the rule contains an
implied reasonableness requirement. Id. Within the realm of reasonable
criteria, the Commission has stated that it ``gives great latitude in
establishing the criteria for participant selection'' to debate staging
organizations under 11 CFR 110.13.\3\ First General Counsel's Report at
n.5, MUR 5530 (Commission on Presidential Debates) (May 4, 2005),
https://eqs.fec.gov/eqsdocsMUR/000043F0.pdf.
---------------------------------------------------------------------------
\2\ See also Funding and Sponsorship of Federal Candidate
Debates, 44 FR 76734 (Dec. 27, 1979) (explaining that, through
candidate debate rule, costs of staging multi-candidate nonpartisan
debates are not contributions or expenditures); 11 CFR 100.92
(excluding funds provided for costs of candidate debates staged
under 11 CFR 110.13 from definition of ``contribution''); 11 CFR
100.154 (excluding funds used for costs of candidate debates staged
under 11 CFR 110.13 from definition of ``expenditure'').
\3\ See Candidate Debates and News Stories, 61 FR 18049 (Apr.
24, 1996) (quoting H.R. Rep. No. 93-1239 at 4 (1974)).
---------------------------------------------------------------------------
The Commission has a well-established history of ensuring that
corporate contributions are not made to candidates taking part in
debates, including by evaluating the objectivity and neutrality of a
debate staging organization's selection criteria in the Commission's
enforcement process. Enforcement matters regarding that issue have
involved a wide range of candidate selection criteria, including
polling thresholds (from 5% to 15%), campaign finance activity levels
(such as a minimum number of contributors as shown in reports filed
with the Commission), campaign engagement levels (such as numbers of
yard signs or participation in neighborhood association meetings),
ballot access, and office eligibility. See, e.g., First General
Counsel's Report at 5 n.5, MUR 5530 (Commission on Presidential
Debates) (May 4, 2005), https://eqs.fec.gov/eqsdocsMUR/000043F0.pdf
(including 15% polling threshold and ballot access criteria). In each
of these matters, the Commission evaluated whether the criteria were
objective, pre-established, and not arranged in a manner to promote or
advance one candidate over another so as to constitute corporate
contributions to the participating candidates.
In these enforcement matters, the Commission has carefully examined
the use of polling thresholds and found that they can be objective and
otherwise lawful selection criteria for candidate debates. Indeed,
almost two decades ago, the Commission found that a staging
organization's use of polling data (among other criteria) did not
result in an unlawful corporate contribution, with five Commissioners
observing that it would make ``little sense'' if ``a debate sponsor
could not look at the latest poll results even though the rest of the
nation could look at this as an indicator of a candidate's
popularity.'' MUR 4451/4473 Commission Statement of Reasons at 8 n.7
(Commission on Presidential Debates) (Apr. 6, 1998), https://www.fec.gov/disclosure_data/mur/4451.pdf#page=459. Citing this
statement, one court noted with respect to the use of polling
thresholds as debate selection criteria that ``[i]t is difficult to
understand why it would be unreasonable or subjective to consider the
extent of a candidate's electoral support prior to the debate to
determine whether the candidate is viable enough to be included.''
Buchanan v. FEC, 112 F. Supp. 2d 58, 75 (D.D.C. 2000).
Because the regulation at issue is designed to provide debate
sponsors with discretion within a framework of objective and neutral
debate criteria, and because the Commission can evaluate the
objectivity and neutrality of a debate sponsor's selection criteria
through the enforcement process, the Commission finds that the
rulemaking proposed by the petition is not necessary at this time. The
Commission concludes that section 110.13(c) in its current form
provides adequate regulatory implementation of the corporate
contribution ban and is preferable to a rigid rule that would prohibit
or mandate use of particular debate selection criteria in all debates.
See 11 CFR 200.5(c) (listing desirability of proceeding on case-by-case
basis as consideration in declining to initiate rulemaking); see also
MUR 4451/4473 Commission Statement of Reasons at 8-9 (Commission on
Presidential Debates) (noting that Commission cannot reasonably
``question[ ] each and every . . . candidate assessment criterion'' but
can evaluate ``evidence that [such a] criterion was `fixed' or arranged
in some manner so as to guarantee a preordained result'').
The petition and the commenters who support it rely primarily on
policy arguments in favor of debate selection criteria that would
include more candidates in general election presidential and vice
presidential debates. The rule at section 110.13(c), however, is not
intended to maximize the number of debate participants; it is intended
to ensure that staging organizations do not select participants in such
a way that the costs of a debate constitute corporate contributions to
the candidates taking part. Corporate and Labor Organization Activity;
Express Advocacy and Coordination with
[[Page 72618]]
Candidates, 60 FR at 64261-62. Staging organizations' use of polling
criteria is a reasonable way for a debate staging organization to
select and ``control the number of candidates participating in . . . a
meaningful debate,'' id., and to do so in a way that is objective and
does not constitute a corporate contribution. A per se rule prohibiting
the use of polling criteria is therefore not necessary to prevent
debates from constituting unlawful contributions.
Furthermore, the rule at 11 CFR 110.13(c) already permits the use
of criteria by staging organizations that could result in larger
numbers of candidates participating in debates. Indeed, the specific
criterion that the petition asks the Commission to include in a revised
section 110.13(c) is already lawful: A debate staging organization has
the discretion to stage a general election presidential or vice
presidential debate using selection criteria similar to the Electoral
College approach preferred by the petitioner (so long as the
organization's reasonable selection criteria are pre-established,
objective, and not designed to result in the selection of certain pre-
chosen participants). No rule change is necessary to enable that
approach, and the petitioner may sponsor a debate using such criteria
or persuade a debate sponsor to do so.\4\
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\4\ If the petitioner (or another entity) is unsure whether it
is a debate ``staging organization'' as defined in 11 CFR 110.13(a),
it may ask the Commission for an advisory opinion on the matter.
See, e.g., Advisory Opinion 1988-22 (San Joaquin Republicans)
(concluding that advisory opinion requestor, which did not yet have
relevant tax status, was not within candidate debate exemption).
Similarly, if a debate staging organization wishes to ask the
Commission to conclude that its proposed candidate selection
criteria are objective and not designed to result in the selection
of certain pre-chosen participants (and thus protect itself from a
later enforcement action), it may seek an advisory opinion on that
question. See 52 U.S.C. 30108(c) (establishing scope of protection
of advisory opinions).
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The petition sets forth certain data in support of its argument
that the use of polling thresholds as a debate selection criterion by
one staging organization ``creates a hurdle that third-party and
independent candidates cannot reasonably expect to clear,'' and
therefore is designed to result in the selection of certain pre-chosen
participants. Petition at 15. The use of polling data by a single
debate staging organization for candidate debates for a single office,
however, does not suggest the need for a rule change. The Commission
acknowledges that lower (or no) polling threshold selection criteria
may open debates to more candidates and that polling thresholds could
be used to promote or advance one candidate (or group of candidates)
over another. But to the extent that a debate staging organization uses
non-objective selection criteria ``designed to result in the selection
of certain pre-chosen participants,'' this would already be unlawful
under the Commission's existing regulation. Corporate and Labor
Organization Activity; Express Advocacy and Coordination with
Candidates, 60 FR at 64262.
Finally, the Commission notes that the petition focuses on and
seeks to amend the rule only with respect to polling threshold criteria
in the selection of participants for presidential general election
debates. However, the candidate debate rule applies to all debates
(primary and general election) ``at the presidential, House, and Senate
levels.'' Funding and Sponsorship of Candidate Debates, 44 FR 39348
(July 5, 1979).\5\ In the absence of any indication that polling
thresholds are inherently unobjective or otherwise unlawful as applied
to all federal elections (and the Commission is aware of no such
indication),\6\ the Commission declines to initiate a rulemaking that
would impose a nationwide prohibition on the use of such thresholds, or
that could result in giving different legal effect to the use of
polling criterion in different elections.
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\5\ Indeed, the Commission has analyzed, in the enforcement
context, debate staging organizations' criteria under 11 CFR
110.13(c) at all levels of federal elections. See, e.g., MUR 5650
(Associated Students of the Univ. of Arizona) (Senate debate); MUR
5530 (Commission on Presidential Debates) (presidential general
election debates).
\6\ The petitioner provided data intended to demonstrate that
polling figures are sometimes inaccurate, but the fact that polls
can be inaccurate does not mean that a staging organization acts
unobjectively by using them.
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For all of the above reasons, the Commission therefore declines to
commence a rulemaking to amend the criteria for staging candidate
debates in 11 CFR 110.13(c).
On behalf of the Commission.
Dated: November 9, 2015.
Ann M. Ravel,
Chair, Federal Election Commission.
[FR Doc. 2015-29494 Filed 11-19-15; 8:45 am]
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