with whom Justice Rehnquist and Justice Stevens join, dissenting.
The Court’s opinion is disarmingly simple and seemingly straightforward: in 1972, Congress created a right of reasonable access for candidates for federal office; the Federal Communications Commission, charged with enforcing the statute, has defined that right; as long as the agency’s action is within the zone of reasonableness, it should be accepted even though a court would have preferred a different course. This approach, however, conceals the fundamental issue in these cases, which is whether Congress intended not only to create a right of reasonable access but also to negate the longstanding statutory policy of deferring to editorial judgments that are not destructive of the goals of the Act. In these cases such a policy would require acceptance of network or station decisions on access as long as they are within the range of reasonableness, even if the Commission would have preferred different responses by the networks. It is demonstrable that Congress did not intend to set aside this traditional policy, and the Commission seriously misconstrued the statute when it assumed that it had been given authority to insist on its Own views as to reasonable access even though this entailed rejection of media judgments representing different but nevertheless reasonable reactions to access requests. As this litiga*398tion demonstrates, the result is an administratively created right of access which, in light of the pre-existing statutory policies concerning access, is far broader than Congress could have intended to allow. The Court unfortunately accepts this major departure from the underlying themes of the Communications Act and from the cases that have construed that statute. With all due respect, I dissent.
Section 312 (a) (7) provides that the Commission may revoke a broadcast license “for willful or repeated failure to allow reasonable access to or to permit purchase of reasonable amounts of time for the use of a broadcasting station by a legally qualified candidate for Federal elective office on behalf of his candidacy.” It is untenable to suggest that the right of access the Commission has created is required or even suggested by the plain language of this section. What is “reasonable” access and what are “reasonable” amounts of time that must be sold are matters about which fair minds could easily differ. The Commission recognized as much in this litigation: “The statutory language,” it said, “does not expressly define the scope of the Commission’s responsibilities or the procedures by which it should enforce them.” 74 F. C. C. 2d 631, 637. Furthermore, the Commission thought “[t]he legislative history of Section 312 (a)(7) does little to clarify those responsibilities and procedures.” Ibid. It also found the floor debates to be “equally uninstructive.” Ibid. It then announced that “[i]n the absence of further direction, we must also assume that Congress wanted to delegate to the Commission broad responsibility to define and implement the scope of Section 312 (a)(7)’s rights and duties.” Id., at 638. Having conferred carte blanche on themselves, four of the seven members of the Commission proceeded to produce some 48 printed pages of guidelines, proscriptions, prescriptions, permissions, instructions on balancing, clarifications, summaries, conclusions, and orders, all purporting to define the “reasonable” access that broadcasters must provide federal candidates for office and to explain why the networks’ *399offers of access were not reasonable under the circumstances. The Commission issued an initial opinion covering 24 pages but felt compelled to write 24 more pages on reconsideration, purporting to clarify and explain what it had meant in the first place. I think the Commission fell into serious error and that its action was arbitrary, capricious, an abuse of discretion, and otherwise contrary to law. 5 IT. S. C. § 706 (2) (A). At the very least, its decision represents “a clear error of judgment.” Citizens to Preserve Overton Park, Inc. v. Volpe, 401 U. S. 402, 416 (1971). I regret particularly that the Court of Appeals and this Court have compounded the error by suggesting that the Commission understood its task and competently performed it in an understandable manner. There are several reasons for my position.
1. The Commission seemed to approach this case as though Congress were legislating on a clean slate, without regard for other provisions of the Act and the manner in which those provisions had been construed and applied to avoid undue intrusions upon the editorial judgment of broadcasters and without regard for the longstanding statutory policies about access, including the recognized duty imposed on broadcasters to serve the public interest by keeping the citizenry reasonably informed about political candidates.
The history of the Federal Government’s regulation of the broadcast media has been recounted by this Court on several occasions. See Columbia Broadcasting System, Inc. v. Democratic National Committee, 412 U. S. 94, 103-110 (1973); Red Lion Broadcasting Co. v. FCC, 395 U. S. 367, 375-386 (1969). That history evinces Congress’ efforts to deal with the inevitable tension between the need to allocate scarce frequencies and the importance of giving licensees broad discretion in exercising editorial judgment in the use of those frequencies. These efforts have led to the creation of a general requirement that broadcast licensees operate in the public interest but that they be given considerable leeway in the fulfillment of that duty. As the Court stated in Columbia *400Broadcasting System, Inc. v. Democratic National Committee, supra, at 110: “Congress intended to permit private broadcasting to develop with the widest journalistic freedom consistent with its public obligation. Only when the interests of the public are found to outweigh the private journalistic interests of the broadcasters will government power be asserted within the framework of the Act.” In particular, Congress has explicitly provided that broadcast licensees are not common carriers, 47 U. S. C. § 153 (h), and that the Commission may not engage in censorship of radio communications. 47 U. S. C. § 326.
The parties agree that prior to the adoption of § 312 (a) (7) individuals or organizations had no specific right of access to broadcast facilities. This was the common view of the Commission, the courts, and Congress. As we said in Columbia Broadcasting System, Inc. v. Democratic National Committee, supra, at 122, Congress had “time and again rejected various legislative attempts that would have mandated a variety of forms of individual access.” Broadcasters had obligations with respect to their programming, such as the fairness doctrine which obligated them to cover issues of public importance from opposing points of view, but this obligation was enforced with care so as not to unduly infringe on the “journalistic discretion in deciding how best to fulfill the Fairness Doctrine obligations.” 412 U. S., at 111. We also observed: “[I]n the area of discussion of public issues Congress chose to leave broad journalistic discretion with the licensee. Congress specifically dealt with — and firmly rejected — the argument that the broadcast facilities should be open on a nonselective basis to all persons wishing to talk about public issues.” Id., at 105. Similarly, in FCC v. Midwest Video Corp., 440 U. S. 689 (1979), where we held that the Commission had erred in providing for a general system of access to cable television, we noted that the Commission’s authority with respect to cable television was derived from the provisions of the Communications Act and *401concluded that the Commission should not have ignored “Congress’ stern disapproval — evidenced in § 3 (h)- — of negation of the editorial discretion otherwise enjoyed by broadcasters and cable operators alike.” Id., at 708. We reaffirmed “the policy of the Act to preserve editorial control of programming in the licensee.” Id., at 705.
Broadcasters, however, had certain statutory obligations with respect to political broadcasting: As the Commission has explained, it had “recognized political broadcasting as one of the fourteen basic elements necessary to meet the public interest, needs and desires of the community.” Report and Order: Commission Policy in Enforcing Section 312 (a)(7) of the Communications Act, 68 F. C. C. 2d 1079, 1087-1088 (1978). Prior to the enactment of § 312 (a)(7):
“No legally qualified candidate had, at that time, a specific right of access to a broadcasting station. However, stations were required to make reasonable, good-faith judgments about the importance and interests of particular races. Based upon those judgments, licensees were to 'determine how much time should be made available for candidates in each race on either a paid or unpaid basis.’ There was no requirement that such time be made available for specific 'uses’ of a broadcasting station to which Section 315 'equal opportunities’ would be applicable.” 68 F. C. C. 2d, at 1088.
The Communications Act had thus long been construed to impose upon the broadcasters a duty to satisfy the public need for information about political campaigns. As this Court observed in Farmers Educational & Cooperative Union v. WDAY, Inc., 360 U. S. 525, 534 (1959), a broadcaster policy of “denying all candidates use of stations . . . would . . . effectively withdraw political discussion from the air,” and such result would be quite contrary to congressional intent. Furthermore, § 315 had long provided that should a station permit a political candidate to use its broadcasting facilities, it must “afford equal opportunities to all other such candi--*402dates for that office . . . As that section expressly provided, however, the provision for equal time created no right of initial access.
It is therefore as clear as can be that the regulation of the broadcast media has been and is marked by a clearly defined “legislative desire to preserve values of private journalism.” Columbia Broadcasting System, Inc. v. Democratic National Committee, supra, at 109. The corollary legislative policy has been not to recognize or attempt to require individual rights of access to the broadcast media. These policies have been so clear and are so obviously grounded in constitutional considerations that in the absence of unequivocal legislative intent to the contrary, it should not be assumed that § 312 (a)(7) was designed to make the kind of substantial inroads in these basic considerations that the Commission has now mandated. Section 312 (a) (7) undoubtedly changed the law governing access in some respects, but the language of the section, as the Commission itself concedes, does not require the access rights the Commission has now created; and the legislative history, far from supporting the Commission’s actions in these cases, has a contrary thrust.
2. The legislative history, most of which the Commission ignored, shows that Congress was well aware of the statutory and regulatory background recounted above. It also shows that Congress had no intention of working the radical change in the roles of the broadcaster and the Commission that the Commission now insists is consistent with the statutory mandate.
The initial effort to incorporate the “reasonable access” concept into the Communications Act arose in 1970 as part of a floor amendment to S. 3637, a bill designed to repeal the equal time provisions of the Act with respect to Presidential and Vice Presidential elections and to require the sale of broadcast time to be made at the “lowest unit charge” available to commercial advertisers. S. 3637, 91st Cong., 2d Sess. (1970). The amendment provided that “consistent with the other needs of the community broadcast licensees shall make *403a reasonable amount of time available for legally qualified candidates for federal elective offices during [prime time].” It also limited expenditures by candidates on broadcast time. 116 Cong. Nee. 11593 (1970). Senator Pastore, sponsor of the amendment, explained that its purpose was “to avoid any misunderstanding as to the obligation of the licensee in making time available to candidates for a Federal elective office.” Ibid. The amendment was adopted by the Senate, but not by the House. However, the House Committee Report made clear that “[t]he presentation of legally qualified candidates for public office is an essential part of any broadcast licensee’s obligation to serve the public interest.” H. R. Rep. No. 91-1347, p. 7 (1970). Senator Pastore’s amendment would have codified that obligation with respect to federal elective office. The final bill was vetoed by President Nixon.
A second effort, this time by Senator Scott, to codify a “reasonable access” provision arose in the next session of Congress. That provision would have directed the Commission to promulgate regulations that would “insure that all licensees make available to legally qualified candidates for public office reasonable amounts of time for use of broadcasting stations.” S. 956, 92d Cong., 2d Sess., § 302 (c) (1971). The then Chairman of the Commission testified that he understood this proposal to codify the existing obligation of broadcasters to present political broadcasts under the public interest standard. Federal Election Campaign Act of 1971: Hearings on S. 1, S. 382, and S. 956 before the Subcommittee on Communications of the Senate Committee on Commerce, 92d Cong., 1st Sess., 189 (1971). This proposal also was not enacted.
The third effort to codify a reasonable access standard met with success in the form of § 312 (a) (7) which the Senate Committee on Commerce added to Title I of what ultimately became the Federal Election Campaign Act of 1971. S. 382, 92d Cong., 1st Sess. (1971). The portions of this bill that addressed broadcast media included a repeal of the equal time provision of the Communications Act with respect to Presi*404dential and Vice Presidential elections, a requirement that broadcasters charge political candidates a "lowest unit charge” during certain periods of a campaign, and limitations on expenditures by candidates for federal office.1 The Senate Committee indicated that these provisions should not result in the "diminution in the extent of such programming.” S. Rep. No. 92-96, p. 28 (1971). And in this precise regard, §312 (a)(7) was included in the bill “[i]n order to emphasize the public interest obligation inherent in making broadcast time available to candidates covered by the spending limitation in the legislation . . . .” Ibid. Section 312 (a)(7) was primarily a device to insure that other provisions of the bill would not dilute the pre-existing public interest standard as applied to federal elections. Consistent with this approach, the Committee described the section and observed that
“[t]he duty of broadcast licensees generally to permit the use of their facilities by legally qualified candidates for these public offices is inherent in the requirement that licensees serve the needs and interests of the [communities] of license.” Id., at 34.
The legislative history thus reveals that Congress sought to codify what it conceived to be the pre-existing duty of the broadcasters to serve the public interest by presenting political broadcasts. It also negates any suggestion that Congress believed it was creating the extensive, inflexible duty to provide access that the Commission has now fastened upon the broadcasters. This is not to say that § 312 (a) (7) did not work important changes in the law, for it did put teeth in the obligation of the broadcasters’ duty to serve the public interest by providing the remedy of license revocation for willful or repeated refusals to provide a candidate for federal elec*405tive office with reasonable access to broadcast time. The need for this remedy arose out of the concern that other provisions of the Federal Election Campaign Act could lead to a misunderstanding regarding the broadcasters’ continuing duty to afford reasonable access to federal candidates.
The Commission almost totally ignored the legislative history as a possible limitation on the reach of the broadcasters’ duty to provide reasonable access or upon the scope of its oversight responsibilities. The Commission did note that one of the purposes of the 1971 Act had been described as affording candidates a greater access to the broadcast media. But none of these statements indicated that this was the purpose of § 312 (a)(7), the provision at issue here. That purpose was served by other provisions of the amendments, such as the provision requiring the sale of broadcast time at the lowest unit charged during specified periods; § 312 (a)(7) itself aimed at preventing the charge limitation from reducing access that might otherwise be available.2
The Commission also noted, and' the Court now heavily relies on, the so-called conforming amendment to § 315 (a), the equal time provision, which then provided that “[n]o obligation is imposed upon any licensee to allow the use of its station by any such candidate.” 47 U. S. C. § 315 (a) (1970 ed.). But in its original form, 48 Stat. 1088, this portion of § 315 had provided that “no obligation is hereby imposed”— the word “hereby” being omitted by the codifier of Title 47 of the United States Code. To the extent that § 315 without *406the conforming amendment, which returned the relevant provision to approximately its original form, suggested that the Act in no way required access to political candidates, it also called into the question the Commission’s public interest policy of requiring stations to give reasonable access to political candidates. That the conforming amendment was made is understandable, but the Court gives it undue significance.
In any event, the Court relies on the conforming amendment for no more than an affirmative indication that Congress intended to give individual candidates a right of reasonable access, a right that did not exist prior to the enactment of §312 (a)(7). This much may be conceded, but nothing in this bit of legislative history, or in any other, furnishes any support for the Commission’s sweeping decision in these cases. On the contrary, the legislative history negates the Commission’s conclusion that it was free to so drastically limit the discretion of the broadcasters and to so radically expand its own oversight authority.
3. The Court relies, as it must, on the authority of the Commission to interpret and apply the statute and on the deference that courts should accord to agency views with respect to the legislation it is charged with enforcing. As the Court has said, however, “[t]he amount of deference due an administrative agency’s interpretation of a statute . . . 'will depend upon the thoroughness evident in its consideration, the validity of its reasoning, its consistency with earlier and later pronouncements, and all those factors which give it power to persuade, if lacking power to control.’ ” St. Martin Evangelical Lutheran Church v. South Dakota, 451 U. S. 772, 783, n. 13 (1981), quoting Skidmore v. Swift & Co., 323 U. S. 134, 140 (1944). I find the Commission’s current radical version not only quite inconsistent with its prior views but also singularly unpersuasive.
As for its past views, the Commission’s policy statement issued in 1972, shortly after the enactment of the Federal Election Campaign Act, expressed the view that the section *407had expressly imposed on the public interest obligation of broadcasters the “additional” specific requirement that candidates for federal public office be afforded reasonable access to broadcast time, but it also clearly eschewed anything approaching the negation of broadcaster discretion and the extensive agency oversight that the Commission’s present decision inevitably involves:
“3. Q. How is a licensee to comply with the requirement of section 312 (a) (7) that he give reasonable access to his station to, or permit the purchase of reasonable amounts of time by, candidates for Federal elective office? .
“A. Each licensee, under the provisions of sections 307 and 309 of the Communications Act, is required to serve the public interest, convenience, or necessity. In its Report and Statement of Policy Re: Commission En Banc Programming Inquiry {I960), the Commission stated that political broadcasts constitute one of the major elements in meeting that standard. (See Farmers Educational and Cooperative Union of America, North Dakota Division v. WDAY, Inc., 360 U. S. 525 (1959), and Red Lion Broadcasting Co., Inc. v. FCC, 395 U. S. 367, 393-394 (1969).) The foregoing broad standard has been applied over the years to the overall programming of licensees. New section 312 (a) (7) adds to that broad standard specific language concerning reasonable access.
“. . . The test of whether a licensee has met the requirement of the new section is one of reasonableness. The Commission will not substitute its judgment for that of the licensee, but, rather, it will determine in any case that may arise whether the licensee can be said to have acted reasonably and in good faith in fulfilling his obligations under this section.
“8. Q. Some stations have in the past had the policy *408of not selling short political spot announcements (e. g., 10 seconds, 1 minute) on the ground that they did not contribute to an informed electorate. In light of the enactment of section 312 (a)(7), may stations have such policies, or must they sell reasonable numbers of short spots to legally qualified candidates for Federal office if requested?
“A. We have, prior to the enactment of section 312 (a)(7), when stations were (under the provisions of section 315) not required to allow use of their facilities by particular candidates for public office, ruled that licensees may have such policies. In so ruling, we have cautioned that licensees have the public interest consideration of making their facilities available to candidates, but have left to the good-faith judgment of the licensee the determination of how the facilities were to be used to serve the public interest. As complaints arose, we looked to the reasonableness of that judgment in a particular fact pattern. (31 F. C. C. 2d 782) (1971)). Section 312 (a) (7) now imposes on the overall obligation to operate in the public interest the additional specific requirement that reasonable access and purchase of reasonable amounts of time be- afforded candidates for Federal office. We shall, under this new section, apply the same test of reasonableness of the judgment of the licensee.” Use of Broadcast and Cablecast Facilities by Candidates for Public Office, 34 F. C. C. 2d 510, 536-538 (emphasis supplied).
There was no suggestion in 1972 that the “needs” of the requesting candidate shall be paramount. Indeed, the Commission embraced its prior practice. Discretion was thought to remain with the broadcaster, not to be placed in the hands of the candidates or subjected to close and exacting oversight by the Commission. Clearly, the Commission’s contemporaneous construction of § 312 (a) (7) is inconsistent with the sweeping construction of the section it has now adopted. See Udall v. Tollman, 380 U. S. 1, 16 (1965).
*409Subsequent interpretations of the scope of § 312 (a) (7), including the comprehensive Report and Order: Commission Policy in Enforcing Section 312 (a)(7) of the Communications Act, 68 F. C. C. 2d 1079 (1978), have consistently refrained from curtailing broadcaster discretion by refusing to impose stringent standards or to second-guess the broadcaster’s good-faith judgments. In the Report and Order, the Commission explained:
“Since the passage of Section 312 (a) (7) as part of the Federal Election Campaign Act of 1971, the Commission’s policy has generally been to defer to the reasonable, good faith judgment of licensees as to what constitutes 'reasonable access’ under all the circumstances present in a particular case. The Commission desired, through its inquiry into this area, to learn whether that policy was proving manageable and equitable for candidates and licensees or whether additional rules or guidelines would be advisable.” Id., at 1079-1080.
After a detailed examination of the question, the Commission concluded:
“We continue to believe that the best method for achieving a balance between the desires of candidates for air time and the commitments of licensees to the broadcast of other types of programming is to rely on the reasonable, good faith discretion of individual licensees. We are convinced that there are no formalized rules which would encompass all the various circumstances possible during an election campaign.” Id., at 1089.
The Commission went on to suggest some very broad guidelines it considered essential in effectuating the intent of Congress under § 312 (a)(7). For example, candidates generally were to be afforded some access to prime time, and access was to be flexible, including the possibility of program time and “spot” announcements. Candidates were not entitled, however, “to a particular placement of his or her political an*410nouncement on a station’s broadcast schedule. ... It is best left to the discretion of a licensee when and on what date a candidate’s spot announcement or program should be aired” 68 F. C. C. 2d, at 1091. The Commission specifically refused to arrogate to itself the power to determine when the reasonable access duty attached except on a case-by-case basis leaving the initial judgment in the hands of the broadcast licensee. Finally, there is no statement in this report that requires broadcasters to look to the needs of a candidate in the initial determination of reasonable access other than the admonition that broadcasters could not “follow a policy of flatly banning access by a Federal candidate to any of the classes and lengths of program or spot time in the same periods which the station offers to commercial advertisers.” Id., at 1090. Like the initial policy statement issued in 1972, this report lends little credence to the new-found power of the Commission to oversee with an iron hand the implementation of § 312 (a)(7).
In terms of the degree to which broadcaster editorial judgments should be subject to review and reversal by the Commission — the most important issue in this litigation — it is evident that the Commission has been quite inconsistent. Its present radical interpretation of § 312 (a) (7) plainly rejects its earlier and more contemporaneous pronouncements as to the meaning and scope of the broadcasters’ duties and of its own authority under § 312 (a)(7).
4. Equally, if not more fundamental, the Commission’s opinions in this case are singularly unpersuasive. They contain a plethora of admonitions to the broadcast industry, some quite vague and others very specific but often inconsistent. Altogether, in operation and effect, they represent major departures from prior practice, from prior decisions, including those of this Court, and from congressionally recognized policies underlying the Federal Communications Act. As I have indicated, we should not endorse them without much clearer congressional direction than is apparent in the actions leading to the adoption of § 312 (a) (7). I shall men*411tion my major difficulties with the Commission’s opinion and judgment.
4a. The Commission stated in a footnote that it should not differ with broadcaster decisions with respect to a candidate’s access unless “ 'arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law,’ ” an approach reflecting its traditional stance vis-a-vis the broadcasters. 74 F. C. C. 2d, at 642, n. 16. The Commission had already determined, however, that because § 312 (a) (7) was not self-explanatory on its face and because it failed to find explicit guidance to the contrary in the legislative history, it would and should exercise wide discretion in interpreting and enforcing the Act. It is therefore not surprising that the Commission’s assertions of deference to editorial judgment are palpably incredible.3
The Commission first confounds itself by announcing that the duty to provide access attaches when the campaign begins and that this threshold issue was to be “based on [an] independent evaluation of the status of the campaign taking into account the position of the candidate and the networks as well as other factors” 74 F. C. C. 2d, at 665. This effectively withdrew the issue of timing from the area of broadcaster judgment and transformed it into a question of law to be determined by the Commission de novo. It was also a major shift in the agency’s position, for its Broadcast Bureau just two years before had ruled that the assessment of when a campaign is sufficiently underway to warrant the provision of access was to be left to broadcaster discretion: “A licensee’s discretion in providing coverage of elections extends not only to the type and amount of time to be made available to candi*412dates, but to the date on which its campaign coverage will commence.” Anthony R. Martin—Trigona, 66 F. C. C. 2d 968, 969 (Broadcast Bureau 1977), application for review denied, 67 F. C. C. 2d 33, reconsideration denied, 67 F. C. C. 2d 743 (1978). Although I have some difficulty in perceiving why the access obligation should begin when “the campaign” is underway, even if there is such a triggering event, reasonable men could differ as to when that moment has arrived. The Commission overstepped its authority in imposing its own answer on the industry and in rejecting the networks’ reasonable submissions. The Commission gave no explanation whatsoever for its action in this respect. In fact, it did not even acknowledge that it was making its own de novo determination until it issued its opinion on reconsideration.
4b. The Commission ruled that in responding to its obligation to provide reasonable time, a broadcaster should place particular emphasis on the candidates’ needs, weigh each request in its own specific context on a particularized basis, and tailor its response to the individual candidate. This approach expressly rejects the thesis of § 315 that all candidates be treated equally. If the networks in this case had responded affirmatively to the candidate’s request, § 315 would require that equal time be extended to all other Democratic candidates and would forbid any kind of individualized consideration that would result in giving them less time than had been previously given to their competitor. There is no trace of support in the language of the Act or in the legislative history for this unrealistic approach to §312 (a)(7). Nor does the Commission offer any tenable explanation why a broadcaster’s decision to provide equal time for all candidates is a violation of the obligation to provide reasonable time to each of them. The inference may be drawn from the Commission’s position that reasonable access may require unequal access, but § 315 requires equal time for all once it is *413granted to anyone. The Commission’s rejection of the equality approach as one of the possible ways of complying with § 312 (a) (7) is a plain error.
Of course, the individualized-need approach requires a broadcaster to make an assessment with respect to each request for time, and each of these countless assessments will be subject to review by the Commission. If the degree of oversight to be exercised by the Commission is to be measured by its work in these cases, there will be very little deference paid to the judgment and discretion of the broadcaster. The demands of the candidate will be paramount. As Commissioner Lee said in this litigation: “I have listened carefully to my colleagues explain how this decision leaves broadcast discretion with the networks. However, the decision doesn’t have this effect. By the time the majority finishes its analysis of the networks’ reasons for not giving time, the networks do not have any choice other than to give the requested time. No other weighing of factors is reasonable in the view of the majority.” 74 F. C. C. 2d, at 681 (footnote omitted).
4c. Indicative also of the stringent degree of oversight that the Commission now intends to exercise is the manner in which it dealt with the networks’ suggestions that in responding to the request for time involved here, they were entitled to take into account the fact that a total of 122 persons had filed notices of candidacy for the Presidency with the Federal Election Commission. The Commission conceded that this was a proper concern and that Republican candidates might have to be treated equally with Democrats. The Commission, however, in its political wisdom, concluded that it was “unlikely” that more than a tiny percentage of all candidates would request time, the net effect being that the networks’ anticipations based on their professional experience were rejected. As petitioner CBS submits in its brief: “Broadcasters are not permitted to consider the likelihood of multiple future requests by similarly situated candidates un*414less the imminence of such requests can be demonstrated to a near certainty. But the likelihood that there will be multiple demands from other candidates is not susceptible to proof in advance. Candidate needs are necessarily shifting in nature, and no candidate can supply a precise prediction of his future plans. Thus, under the Commission’s approach, broadcasters can give only limited, if any, weight to potential disruption of normal program schedules, or their view that other material would better serve the interests of their audiences.” Brief for Petitioner in No. 80-207, p. 38 (footnotes omitted).
4d. The Court tells us: “If broadcasters take the appropriate factors into account and act reasonably and in good faith, their decisions will be entitled to deference even if the Commission’s analysis would have differed in the first instance.” Ante, at 387. But this language can be taken with a grain of salt, since the Commission, the Court of Appeals, and the majority give the networks no deference whatsoever. This is so because the “appropriate factors” are designed to eviscerate broadcaster discretion. The abrupt departure from accepted norms and the truly remarkable extent to which the Commission will seek to control the programming of political candidates in the future is best demonstrated by its rejection, as being unreasonable, of the submissions filed by the networks in response to the complaints, these submissions being summarized in the networks’ briefs as follows:
CBS:
“On October 11, 1979, Gerald M. Rafshoon, President Carter’s media adviser, asked CBS to offer the Carter/ Mondale Presidential Committee, Inc. (the 'Carter Committee’) a thirty-minute paid program on the CBS Television Network between 8:00 p.m. and 10:30 p.m. EST during the period December 4 to 7, 1979. The program, which was to be run following President Carter’s anticipated announcement of his candidacy for reelection on *415December 4, was described as ‘a documentary outlining the President’s record and that of his administration.’ J. A. 39. CBS declined to offer a half-hour period that early in the campaign, but did offer two five-minute periods, one in the prime evening hours and one in the daytime hours, as it had to two other presidential candidates. J. A. 44-45.
“On October 29, 1979, the Carter Committee filed a complaint with the Commission alleging that CBS, ABC and NBC had violated Section 312(a)(7). In its response to the complaint and later pleadings, CBS asserted that its decision had been reasonable. CBS stated that it had traditionally sold half-hour periods during later campaign periods and that it intended to do so in the 1980 campaign. J. A. 80. It emphasized that its sales policies were designed to assure evenhanded treatment of candidates. J. A. 170-173. CBS pointed out that the Carter Committee request had been made even before the President had announced his candidacy and more than a year before the general election. It also pointed out that campaigns for the presidential nominations consisted not of one national contest, but of a series of state delegate contests extending over a long period of time; that the first of these contests was more than four months away; and that it was not reasonable to expect networks to sell half-hour periods nationally at such an early date. Moreover, CBS noted that there were a large number of actual and potential candidates for the Presidency; that two candidates for the Republican nomination had already requested half-hour periods; and that a substantial disruption of regular programming would occur if multiple requests were received and granted. J. A. 78-84. CBS further pointed out that an incumbent President has unparalleled opportunities to present his views to the public by means of the broadcast media. J. A. 170-71.” *416Brief for Petitioner in No. 80-207, pp. 4-5 (footnotes omitted).
NBC:
“NBC responded by letter of October 23, 1979 declining the request to purchase time (JA 42). In its letter NBC noted that it had carefully evaluated the request, but concluded that the earliness of the requested broadcast dates (eight months before the Democratic National Convention and 11 months before the national election), the multiplicity of federal candidates at that stage of the campaign (12 announced candidates had held national elective office or been Governor of a state), and NBC’s obligation under Section 315 (a) of the Communications Act to provide equal half-hour time periods to all candidates requesting it should NBC honor the President’s request, were all factors in its decision. NBC also noted that since the nomination process was focused at that time on political activities in individual states, such as the Iowa Caucus, the Committee might wish to contact individual local stations in those states.” Brief for Petitioner in No. 80-214, pp. 3-4.
ABC:
“In a letter dated October 23, 1979, ABC advised Mr. Rafshoon that it could not comply with the Committee’s request for time on one of the early December dates, but that it expected to make time available early in 1980. J. A. 41. . . .
“In response, ABC explained the factors which had led it to conclude that political time sales could reasonably commence in early January, 1980 — instead of on the specific dates requested. Thus, the first of 36 Presidential primaries was, at that time, nearly four months away and the Democratic National Convention was more than *417eight months away. J. A. 54 — 55. ABC also noted that the potential for program schedule disruption would be considerable if the Committee were sold time in early December, as multiple candidates would likely assert equal opportunities rights under Section 315 (a) of the Communications Act. J. A. 56. In this regard, ABC observed that at least nine Republicans had already declared their candidacy and that two Democratic leaders and a tenth prominent Republican were expected to announce within a short period of time. Finally, ABC emphasized that its continuing news coverage ensured that ‘the mixture of issues, developments (including candidate announcements) and personalities that dominate this early stage of the campaign are brought to the public’s attention.’ J. A. 57.” Brief for Petitioner in No. 80-213, pp. 6-7.
None of these justifications is patently unreasonable. They become so only because of the Commission’s conclusion, adopted by the majority, that the reasonableness of access is to be considered from the individual candidate’s perspective, including that candidate’s particular “needs.” While both the Court and the Commission describe other factors considered relevant such as the number of candidates and disruption in programming, the overarching focus is directed to the perceived needs of the individual candidate. This highly skewed approach is required because, as the Court sees it, the networks “seek the unilateral right to determine in advance how much time to afford all candidates.” Ante, at 389. But such a right, reasonably applied, would seem to fall squarely within the traditionally recognized discretion of the broadcaster. Instead of adhering to this traditional approach, the Court has laid the foundation for the unilateral right of candidates to demand and receive any “reasonable” amount of time a candidate determines to be necessary to execute a particular campaign strategy. The concomitant Commission in*418volvement is obvious. There is no basis in the statute for this very broad and unworkable scheme of access.4 Commissioner Washburn’s dissenting observation is surely correct:
“In addition, the document adopted by the majority today goes far beyond the proper limits of Commission responsibility in political broadcasting matters. In detail (see pages 12-13, paragraphs 13-35) it substitutes the Commission’s judgment for the broadcaster’s own good faith interpretation of candidate requests and his response thereto. Such governmental intrusion is unwarranted, is illegal and, I fear, will have far-reaching consequences that will come back to haunt the Commission and the public again and again.” 74 F. C. C. 2d, at 682.
The bill as enacted did not include the proposed repeal of the equal time provisions with respect to Presidential and Vice Presidential elections. 86 Stat. 3. In addition, the expenditure limitations of the Federal Election Campaign Act of 1971 have been repealed. 88 Stat. 1278.
One of the major purposes of the Federal Election Campaign Act was to shorten the length of campaigns, thereby reducing campaign costs. See S. Rep. No. 92-96, pp. 20-21, 28 (1971). Television advertising was described as “unquestionably the most used media in political campaigns, and it has been the most significant contributor to the spiraling cost of these campaigns.” Id., at 30. The majority’s interpretation of § 312 (a) (7) runs directly contrary to this broad goal. This decision is nothing more than an open invitation to start campaigning early, thus increasing the overall length of the campaign and the overall costs to all the candidates.
The statute permits revocation upon "willful or repeated” refusal to afford reasonable access. I think this language indicates that the Commission would intervene in only the most egregious of circumstances — such as an outright refusal to afford any time regardless of the circumstances. Consistent with this view, Senator Scott described § 312 (a) (7) as directed at those few broadcasters who acted in “blatant disregard for the public interest.” Federal Election Campaign Act of 1971: Hearings before the Subcommittee on Privileges and Elections of the Senate Committee on Rules and Administration, 92d Cong., 1st Sess., 103 (1971). The majority, however, reads this language as an open invitation for Commission intervention. A single “willful” violation is sufficient to trigger overview and immediate revocation. Ante, at 378. Since the Court has sustained the Commission’s finding that the networks violated § 312 (a) (7) and since a violation of § 312 (a) (7) requires either willful or repeated refusal of reasonable access, it follows that the networks have been found to have acted willfully within the meaning of the statute and that their licenses are subject to immediate revocation. I doubt Congress intended to put the licenses of all broadcasters into a state of jeopardy on such tenuous grounds.