dissenting.
Because the plurality opinion is largely concerned with questions that need not be answered in order to decide this case,1 I believe it is important to identify the actual issue with some care. The narrow question we must address is whether a state public utility commission may require the fundraising solicitation of a consumer advocacy group to be carried in a utility billing envelope. Since the utility concedes that it has no right to use the extra space in the billing envelope for its own newsletter, the question is limited to whether the Commission’s requirement that it be the courier *36for the message of a third party violates the First Amendment. In my view, this requirement differs little from regulations applied daily to a variety of commercial communications that have rarely been challenged — and to my knowledge never invalidated — on First Amendment grounds.
I
As the California Public Utilities Commission summarized its own ruling: “[T]his decision . . . grants, in modified form, the complaint of Toward Utility Rate Normalization (TURN) proposing access to the extra space in Pacific Gas and Electric Company’s (PG&E) billing envelope by consumer representative organizations for the purpose of soliciting funds to be used for residential ratepayer representation in proceedings of this Commission involving PG&E.” App. to Juris. Statement A-l. Accord, id., at A-4.2 The Commission did not select among competing advocacy groups yearning to reach residential ratepayers through the billing envelope; “no other ratepayer organizations . . . sought access to the extra space.” Id., at A-24.
In my view the propagandizing and sloganeering feared by the plurality is not authorized by paragraph 5(b) of the Commission’s order, which provides that “PG&E and TURN shall each determine the content of [its] own material.” Id., at A-32. In context, it is clear that the limited editorial license afforded by that provision is confined to “a billing envelope extra space insert . . . which (1) explains the program, (2) *37sets forth a list of pending and anticipated PG&E applications and other cases likely to have a significant effect on customers’ rates and services, and (3) invites voluntary donations to support advocacy by [TURN] on behalf of PG&E’s residential customers before the Commission. The insert would also include a return envelope for mailing donations to a central collection point for transmittal to [TURN].” Id., at A-4, A-5. It is unrealistic to suppose that the Commission, after adopting a program so detailed as to prescribe the subject matter of the communication and even to require return envelopes, can be thought to have sanctioned the freewheeling political debate the plurality opinion presupposes. Far from creating the postal equivalent of the soapbox in the park, the Commission “order[ed] that proposal 3” of the “Consumer Advocacy Checkoff” alternatives listed in TURN’S complaint “be implemented.” Id., at A-17. Accord, id., at A-31. That proposal, in marked contrast to the typically broad prayers for relief found in most complaints, limited the requested insert to the three matters described above, see id., at A-78, and even provided a full illustrative insert as an exhibit, see id., at A-85, A-86. Simply as a matter of construing a decision by a regulatory agency I find it difficult to understand the plurality’s preference for discussing issues in their most abstract form. And as a matter of constitutional law there is surely no warrant for presuming that the Commission acted indiscriminately, insensitively, and without regard to the First Amendment questions raised by its access requirement. If any presumption is invoked, it should be that in favor of the regularity and constitutionality of governmental action, and the Commission’s order should be construed narrowly as a consequence.
II
I assume that the plurality would not object to a utility commission rule dictating the format of the bill, even as to required warnings and the type size of various provisos and *38disclaimers.3 Such regulation is not too different from that applicable to credit card bills, loan forms, and media advertising. See, e. g., 15 U. S. C. §§ 1632(a), 1663; 12 CFR §§226.6-226.8, 226.10 (1985).4 I assume also the plurality would permit the Commission to require the utility to disseminate legal notices of public hearings and ratemaking proceedings written by it. See ante, at 15-16, n. 12 (attempting to distinguish legal notices).5 These compelled statements *39differ little from mandating disclosure of information in the bill itself, as the plurality recognizes.6
Given that the Commission can require the utility to make cértain statements and to carry the Commission’s own messages to its customers, It seems but a small step to acknowledge that the Commission can also require the utility to act as the conduit for a public interest group’s message that bears a close relationship to the purpose of the billing envelope.7 An analog to this requirement appears in securities law: the Securities and Exchange Commission requires the incumbent board of directors to transmit proposals of dissident shareholders which it opposes.8 Presumably the plurality does not doubt the constitutionality of the SEC’s requirement *40under the First Amendment, and yet — although the analogy is far from perfect — it performs the same function as the Commission’s rule by making accessible the relevant audience, whether it be shareholders investing in the corporation or consumers served by the utility, to individuals or groups with demonstrable interests in reaching that audience for certain limited and approved purposes.
If the California Public Utilities Commission had taken over company buildings and vehicles for propaganda purposes, or even engaged in viewpoint discrimination among speakers desirous of sending messages via the billing envelope, I would be concerned. But nothing in this case presents problems even remotely resembling or portending the ones just mentioned. Although the plurality’s holding may wisely forestall serious constitutional problems that are likely to arise in the future, I am not convinced that the order under review today has crossed the threshold of unconstitutionality. Accordingly, I respectfully dissent.
For the plurality, the question in this case is whether a public utility commission “may require a privately owned utility company to include in its billing envelopes speech of a third party with which the utility disagrees.” Ante, at 4. The plurality seems concerned that the California Public Utilities Commission’s decision may be the harbinger of future decisions requiring publicly regulated institutions to bear banners antithetical to their own self-interest. Henceforth, a company’s buildings and vehicles might display signs and stickers proclaiming the benefits of conservation, lower rates, and perhaps even government ownership. See ante, at 6-7, n. 4.
The Commission’s access order is plainly limited to TURN’S fund-raising appeal: Subsections (f) through (i) of paragraph 5 of the order, which make provision for funds received in response to TURN’S solicitation, make no sense if TURN is not required to solicit funds. See App. to Juris. Statement A-32, A-33.
That the Commission is serious about this limitation is borne out by its denial of access to a group which did not itself wish to participate in Commission proceedings and which failed to allege that its use of the billing envelope would enhance consumer participation in Commission proceedings. See ante, at 7, n. 5.
Since 1919 the predecessor to the California Public Utilities Commission ordered that each electric bill reprint the regulations “regarding payment of bills, disputed bills and discontinuance of service.” Pacific Gas & Electric Co., 17 Decisions of the Railroad Comm’n 143, 147 (1919). Other States have similar requirements.
“Numerous examples could be cited of communications that are regulated without offending the First Amendment, such as the exchange of information about securities, SEC v. Texas Gulf Sulphur Co., 401 F. 2d 833 (CA2 1968), cert. denied, 394 U. S. 976 (1969), corporate proxy statements, Mills v. Electric Auto-Lite Co., 396 U. S. 375 (1970), [and] the exchange of price and production information among competitors, American Column & Lamber Co. v. United States, 257 U. S. 377 (1921).” Ohralik v. Ohio State Bar Assn., 436 U. S. 447, 456 (1978).
At various times the Commission has required that inserts be placed in billing envelopes to “explai[n] the reasons behind [a] gas rate increase,” Pacific Gas & Electric Co., 9 P. U. C. 2d 82, 94 (1982), and to “describ[e] the components of the utility’s costs,” San Diego Gas & Electric Co., 8 P. U. C. 2d 410 (1982). See Pacific Gas & Electric Co., 7 P. U. C. 2d 349, 518 (1981) (“By March 1, 1982, PG&E shall mail to all its customers a bill insert which describes the components of the utility’s costs. The complete bill insert to be sent is given in Appendix G of this decision. Its size and form shall be approved by the Executive Director in writing prior to inclusion with any customer’s bill”).
California has also enacted legislation requiring that utilities notify their customers of rate increases. These notices, which by statute must be included in utility bill envelopes, “shall state the amount of the proposed increase expressed in both dollar and percentage terms, a brief statement of the reasons the increase is required or sought, and the mailing address of the commission to which any customer inquiries relative to the proposed increase . . . may be directed.” Cal. Public Utilities Code Ann. § 454(a) (West 1975). Other States likewise require certain service-related communications to be carried in a utility company’s billing envelope.
See ante, at 18 (the result in Miami Herald Publishing Co. v. Tornillo, 418 U. S. 241 (1974), would not differ if the forced reply had appeared in a separate insert rather in the newspaper proper). See also ante, at 11, n. 7.
Because TURN’S purpose is to solicit funds to fight utility rate increases, the success of its appeal bears directly on the size of the bill which, after all, the billing envelope contains.
17 CFR § 240.14a-8 (1985). This regulation cannot be justified on the basis of the commercial character of the communication, because the Rule can and has been used to propagate purely political proposals. See, e. g., Medical Committee for Human Rights v. SEC, 139 U. S. App. D. C. 226, 229, 432 F. 2d 659, 662 (1970) (shareholder proposal to stop sale of napalm in part because of use in Vietnam), vacated as moot, 401 U. S. 973 (1971). See generally Weiss, Proxy Voting on Social Issues: A Growth Industry, Bus. and Soe’y Rev. 16 (Autumn 1974).
Even if the SEC Rule were justified largely on the basis of the commercial character of the communication, that justification is not irrelevant in this ease. The messages that the utility disseminates in its newsletter are unquestionably intended to advance the corporation’s commercial interests, and its objections to the public interest group’s messages are based on their potentially adverse impact on the utility’s ability to obtain rate increases. These commercial factors do not justify an abridgment of the utility’s constitutionally protected right to communicate in its newsletter, but they do provide a legitimate and an adequate justification for the Commission’s action in giving TURN access to the same audience that receives the utility’s newsletter.