Comment on Federal Communications Commission Review of Lowest Unit Charge Guidance

On September 25, 2026, Campaign Legal Center (CLC) filed a comment on the Federal Communications Commission’s (FCC) review of its March 30, 2026, public guidance interpreting the lowest unit charge requirements. The guidance expanded the lowest unit charge (a broadcast advertising discount statutorily reserved for candidates) to (1) political parties making coordinated expenditures with candidates, and (2) joint fundraising committees involving candidates. CLC’s comment urged the FCC to rescind the guidance, which is contrary to the text and purpose of federal statute and the FCC’s past guidance, and would effectively grant super PACs — which can participate in joint fundraising with candidates and subsidize the joint fundraising committee’s communications — an advertising discount.