dissenting:
Like Chief Judge Wright and Judge Ginsburg, I too have read the statute and base my opinion as to the necessary result in this case on its plain language. Unlike my colleagues, however, I do not approach the task of this court as if we are the first called upon to construe this statute; the issue before us is not our construction of the statute de novo, but whether the Commission’s interpretation of the statute can be supported on a rational basis so that its conclusion cannot be said to be “contrary to law.” 1 Also unlike my colleagues, I reach a result supported by the General Counsel of the Federal Election Commission, the unanimous 6 to 0 vote of the Members of the Commission, and the decision of the District Judge below.2
I. STRAIGHT STATUTORY CONSTRUCTION
We start with 2 U.S.C., Ch. 14 — Federal Election Campaigns3, § 441a, Limitations on Contributions and Expenditures. There are two subsections — not just one — relevant and decisive in this case, a. Dollar limits on contributions.
***** *
*783(4) The limitations on contributions contained in paragraphs (1) and (2) do not apply to transfers between and among political committees which are national, State, district, or local committees (including any subordinate committee thereof) of the same political party.
******
(d) Expenditures by national committee, State committee, or subordinate committee of State committee in connection with general election campaign of candidates for Federal office.
******
(3) The national committee of a political party, or a State committee of a political party, including any subordinate committee of a State Committee, may not make any expenditure in connection with the general election campaign of a candidate for Federal office in a State who is affiliated with such party which exceeds—
(A) in the case of a candidate for election to the office of Senator, or of Representative from a State which is entitled to only one Representative, the greater of—
(i) 2 cents multiplied by the voting age population of the State (as certified under subsection (e) of this section); or
(ii) $20,000; and
(B) in the case of a candidate for election to the office of Representative, Delegate, or Resident Commissioner of any other State, $10,000.
The latter of the two above provisions, (d)(3), fulfills one of the two prime objectives of the Federal Election Campaign Act — to place a limit on overall expenditures in campaigns for federal office. For my colleagues this provision is sufficient unto itself to settle the question before us in this case. For me it is not sufficient, because this section alone does not purport to tell us where the money, whose total amount is limited, is coming from.4 To find out that we must look back at the first part of § 441a, Limitations on Contributions and Expenditures, to the very first subsection: (a) Dollar limits on contributions. Subsections (1), (2), and (3) deal with limits on contributions by persons, multi-candidate political committees, and individuals, provisions which are directed to the second principal objective of the FECA, i. e., eliminating undue and corrupting political influence on candidates and officeholders by limiting contributions. The subsections dealing with persons, multi-candidate political committees, and individuals are not relevant to this case, but subsection (a)(4), quoted above, certainly is.
Subsection (a)(4), far from placing any limitation, specifically provides that the pri- or limitations in (1) and (2) (persons and multi-candidate political committees) “do not apply to transfers between and among political committees which are national. State, district, or local committees (including any subordinate committee thereof) of the same political party.” As will be discussed more fully under IV below, while there are evils associated with large contributions by persons and multi-candidate political committees to candidates for federal office, there are no visible evils associated with the transfer of funds among committees of the same political parties. The contribution limitations as to the original sources have already been applied, and the connection between the recipient federal candidate and the original source of the funds is totally broken and obscured.5
So, looking again at subsection (d)(3), we might expect that the national committee *784of each political party, or a state committee of a political party, would gain a substantial amount of contributions from persons generally, and would employ those funds most efficiently to assist the candidates for Senator or Representative in each State as its judgment indicated — but within the overall limit on expenditures as provided by subsection (d)(3). However, in addition to the contributions of persons or other authorized entities, which are limited by §§ 441a(a)(l), (2), and (3), these party national and state committees have an additional source of funds, and that is a transfer of funds from one of the “political committees which are national, State, district, or local committees ... of the same political party” under subsection (a)(4). These transfers are plainly unlimited in amount, because the funds have been accumulated in obedience to the contribution limits of § 441a(a) and there is no visible evil in the transfer of funds among political committees of the same party, if both the individual contribution limits and the overall expenditure limits on any campaign race are observed.
The Senatorial Campaign Committees and the Congressional Campaign Committees of each major political party have proved to be highly successful fund-raisers. The plaintiff Democratic Senatorial Campaign Committee does not challenge in this suit that under § 441a(a)(4) either a Senatorial Campaign Committee or a Congressional Campaign Committee of either party can transfer an unlimited amount of money to either that party’s national committee or that party’s state committee in one of the individual states, and that the money so transferred can be expended on behalf of that party’s candidate for either the Senate or the House in a given state — all within the expenditure limit of (d)(3).
However, for reasons which are not obvious in the record and which are immaterial, the Senatorial and Congressional Campaign Committees of both political parties have found it administratively advantageous to make the above-described transfer of funds in an indirect way.6 Instead of the Senatorial or Congressional Campaign Committee writing its check to the order of the national committee of its party, the Senatorial or Congressional Campaign Committee of both parties has followed the practice of having the national committee authorize the Senatorial or Congressional Campaign Committee of its party to make expenditures as its agent on behalf of designated candidates for the Senate and the House. Again, such expenditures by a given national committee from all sources must be within the overall limits of subsection (d)(3).
Significantly, and interestingly, this indirect device of appointing the Senatorial or Congressional Campaign Committee as the agent of the national committee, a practice followed by both political parties, is not challenged by the plaintiff Democratic Senatorial Campaign Committee here. What is challenged is the exact parallel in direct transfer of funds by the authorization of a state committee to the Senatorial (or Congressional) Campaign Committee to expend funds on behalf of a designated candidate for the Senate or House of that political party.7 This delegation of expenditure authority is practiced only by the Republican Senatorial and Congressional Campaign Committees, but not by the Democratic. Why this is so we do not know, and it is immaterial to any court decision, because the delegation of authority from the state committee to the Senatorial or Congressional Campaign Committees rests on precisely the same rationale and statutory provisions permitting unlimited transfers as does the delegation of authority from the national committee to the Senatorial or Congressional Campaign Committees, a practice engaged in by both political parties.
II. FORM OVER SUBSTANCE
My colleagues say that we are not called upon here to pass upon a transfer case, that *785there is actually no writing of a check by the National Republican Senatorial Committee to a state committee on behalf of a Senatorial candidate in that state. This is true. The transfer of funds and the transfer of their political effect do not take place in that way; it is done indirectly as described above by the delegation of authority from the state committee to the Senatorial Committee (or from the national committee, unchallenged here).
The difference is purely one of form, not substance. It makes absolutely no difference in the scheme of control of campaign expenditures and contributions whether the National Republican Senatorial Committee in Washington writes a check and mails it to the state committee in Louisville, Kentucky, to be expended for the benefit of the Republican nominee for the Senate in the State of Kentucky, or, on the other hand, as is now the practice, the state committee in Louisville, Kentucky, writes a letter to the Senatorial Campaign Committee in Washington authorizing that committee to make expenditures on behalf of the same Republican nominee for the Senate in Kentucky. In either event, the funds expended come from the contributions accumulated by the Senatorial Committee in Washington, those contributions having been duly made in accordance with the limitations of § 441a(a), and expended within the overall limitations of § 441a(d)(3).
It is precisely because to accede to the view argued for by the plaintiff here and espoused by my colleagues would do nothing but exalt form over substance that the Federal Election Commission very sensibly responded in a requested opinion that such delegation of authorized expenditures to the Senatorial or Congressional Campaign Committee of the same party was lawful within the meaning and purpose of the statute. The FEC stated: “Since funds may be transferred between the congressional campaign and the national committee of the same political party without limitation, it is immaterial as to which committee’s funds are being expended under 2 U.S.C. § 441a(d)(3).” 8 There is simply no sense in prohibiting the letter of authorization being written in Louisville and mailed to Washington, when it is recognized that the statute plainly permits under § 441a(a)(4) a check to be written in Washington and mailed to Louisville to accomplish precisely the same purpose, i. e., spending money accumulated by the National Republican Senatorial Committee on behalf of the Republican candidate for Senator in the State of Kentucky.9
According to the majority’s view, two things will happen: First, the letters of authorization from the state committees to the National Republican Senatorial Committee will become of no effect and the Senatorial Committee in Washington will immediately start writing checks to each state committee for the amount which it has decided to allocate in support of the Republican Senatorial candidates in those states. Secondly — -and this is more than the plaintiffs have asked or bargained for— both the National Committees of the Republican and Democratic parties will immediately be required to stop writing letters of authorization to their respective Senatorial and Congressional Campaign Committees in Washington; instead, the National Committees of both parties will simply have to arrange the direct transfer of funds from their respective Senatorial and Congressional Campaign Committees, as authorized by § 441a(a)(4), and then the National Committees (instead of the Senatorial or Congressional Campaign Committees) will expend those funds within the limits of subsection (d)(3) on behalf of selected candidates for the Senate and House in the states.
The net result of plaintiff Democratic Committee’s position prevailing is that not *786one dollar less will be spent, not one dollar will be changed from where the members of the national committee, or state committee in consultation with the Senatorial or Congressional Campaign Committees of their respective parties, want the dollar to be expended. All that will happen is that the money will be transferred and administered in a manner which neither major political party has found most efficient, but which the Federal Election Commission has held is the exact practical equivalent of the practice of authorized delegation now being followed by both political parties.
An obvious question arises: If the respective committees can transfer and spend the money in precise technical compliance with both relevant subsections of the statute, why do not the committees use this form and achieve the same substance? The record is bare of any explanation of why the various committees have followed the current practice, which dates at least from 1976. Both major parties use the method of their respective National Committees authorizing the Senatorial and Congressional Campaign Committees as agents to make expenditures for candidates within the statutory limits. Only the Republicans have seen fit to have their state committees so work with the National Campaign Committees. There may be advantages of economy of scale in expenditures from one source, of available expertise in creating and placing advertisements, in obtaining media exposure, in obtaining credit during the campaign, etc.; the court can only speculate. All we know is that both parties employ the indirect method of expenditure by authorizing the committees in Washington as agents, that it must have some functional advantage, and that the Democratic Senatorial Campaign Committee (which does not act as an agent for Democratic state committees) has taken the trouble to challenge the National Republican Senatorial Committee’s actions as agent for Republican state committees.
III. ESTABLISHED PRECEDENT — ACTION AND OPINION
While the advantage of what the intervenor Republican Committee is doing is not obvious from the record, the profound — and grossly unfair — disadvantage of the court sustaining this Democratic Committee challenge at this late hour is undeniably clear. The actions challenged were in accord with the precedent established over the lifetime of the practice of delegation by both the national and state committees, which rest on the same rationale.
(1) In 1976 the Republican National Committee (RNC) designated the National Republican Senatorial Committee (NRSC) as its agent to make the expenditures for congressional campaigns permitted under subsection (a)(4) and (d)(3).10 The Democratic National Committee filed a complaint challenging this indirect method, but withdrew it.11
(2) Representative Cleveland requested an advisory opinion on the practice, which was specifically approved in Advisory Opinion 1976 — 108, cited above.12
(3) At this time the FEC was engaged in rulemaking, and produced § 110.7 Party Committee Expenditure Limitations (2 U.S.C. § 441a(d)). Regulation § 110.7(a)(4) specifically approves the national committee of a party making any authorized expenditure under § 441a(d) “through any designated agent” in connection with a presidential campaign. No reference was made to a state committee acting through an agent, although both national and state committees are authorized to make expenditures by § 441a(d); the explanation offered is that at that time in 1976 no state commit*787tee had made any agency designation in either a presidential or a congressional campaign. Furthermore, it was only in 1978, after the regulation was promulgated, that agency designations were made by state committees to the Congressional Committees in campaigns for House and Senate races.13
(4) In 1978 several Republican state committees followed the practice begun in 1976 by the RNC and designated the intervenor National Republican Senatorial (or Congressional) Committee as an agent to make expenditures for the benefit of congressional candidates. This was challenged in two complaints. In MUR 78014 the FEC concluded on 19 January 1979 that the NRSC had not violated 2 U.S.C. § 441a(d) by making § 441a(d) expenditures as agent of both the Montana Republican State Committee and the Republican National Committee. Likewise, in MUR 820 the FEC concluded on 19 June 1979 that there was no violation of § 441a(d) by the NRSC acting as agent of both the RNC and the Alabama Republican Party.15 The plaintiff here, the Democratic Senatorial Campaign Committee, did not protest or attempt to overturn these FEC rulings until May 1980 with the filing of this complaint before the FEC.
Surely this was amply reassuring precedent for the intervenor NRSC to continue in this campaign year the practice of acting as agent of the RNC and state committees to make expenditures under §§ 441a(a)(4) and (d)(3), a practice which had been validated and sustained by the FEC against every challenge since 1976. In reliance thereon the intervenor NRSC has entered into contracts for campaign activities, with the media and political suppliers, and with employees to serve during the campaign. These are substantial commitments of millions of dollars, which this court now throws into jeopardy and confusion 30 days before the campaign is to end, in spite of four years of precedential rulings contra by the responsible agency, the FEC, confirmed in this specific case by the FEC General Counsel’s opinion, the unanimous 6 to 0 vote of the FEC members, and the decision of the District Court.
One minor point perhaps should be noted at this time. While counsel for the Democratic Senatorial Campaign Committee responded in answer to a direct question from the court at oral argument that the plaintiff was “not challenging transfers in this case,” yet it has been suggested that neither the Democratic Senatorial Campaign Committee nor the National Republican Senatorial Committee (nor their respective Congressional Campaign Committees) are “national” committees within the meaning of § 441a(a)(4) authorizing unlimited “transfers between and among committees which are national, State, district, or local committees (including any subordinate committee thereof) of the same political party.” We can assume for the disposition of this case, since no party challenges it, that the Senatorial Campaign Committees are within the scope of the “transfer” provision.16
*788IV. TWO PRINCIPAL PURPOSES OF THE FEDERAL ELECTION CAMPAIGN LAWS
It is undisputed that two of the principal objectives of reform in the conduct of federal elections were, first, putting some kind of an overall limit on the horrendously escalating cost of political campaigns, and, secondly, eliminating the pernicious influence of the large campaign contributor over the political candidate or political officeholder.17 These two reform objectives were to be accomplished in three ways: first, overall limits on campaign expenditures in the races for President, the Senate, and the House; secondly, stringent limitations on the individual contributions which could be made by persons and organized entities to individual candidates and special purpose committees;18 thirdly, a system of full public disclosure of all expenditures and all except the most minor contributions.
When we look at the plain language of the statutory scheme, we see that there are overall limits on the expenditures in campaigns for the Senate and the House under § 441a(d)(3). There is no suggestion whatsoever in the plaintiff’s argument or in my colleagues’ opinion that the practice challenged here in any way is an attempt to or could evade the overall expenditure limitations of subsection (d)(3). It is perfectly clear that whatever funds of the intervenor NRSC, acting as agent of either the Republican National Committee or a state party committee, are expended on behalf of any given Senatorial candidate, those expenditures must be within the overall limits authorized to the RNC or to the state committee, respectively. This is true whether the Senatorial Committee makes the expenditure itself as a result of being designated as an agent of the state or national committee and authorized thereby to make the expenditure, or whether the Senatorial Committee writes a check to either the national committee or the state committee.
Furthermore, accountability for all funds expended on behalf of a given political candidate by any party political committee is placed in the state’s party central committee. Regulation § 110.7,19 Party committee expenditure limitations (2 U.S.C. 441a(d)) specifically provides under subsection (c)(1): “The State central committee shall be responsible for insuring that the expenditures of the entire party organization are within the limitations, including receiving reports from any subordinate committee making expenditures under paragraph (b) of this section, and filing consolidated reports showing all expenditures in the State with the Commission.” The “expenditures under paragraph (b) of this section” refers to the expenditures of “the general election campaign of a candidate for federal office in that state who is affiliated with the party,” i. e., a designated Republican or Democratic candidate for the Senate or for the House.
The second principal purpose of campaign reform, limiting contributions in order to eliminate the evil effect of huge contributions influencing candidates or officeholders, is taken care of in § 441a(a), Dollar limits on contributions.20 As was briefly discussed above, after placing specific limits on (1) persons, (2) multi-candidate political committees, and (3) individual aggregate contributions, the Congress came to consider the possible and probable “contributions” to be anticipated between political committees of the same political party. These, of course, are not “contributions” in the original sense;21 they are actually *789transfers of funds which have been received by the respective committees within the contribution limit for individuals and organizations previously set. Hence, the Congress made absolutely clear in § 441a(a)(4) that the limitations on contributions in the above paragraph “do not apply to transfers between and among political committees which are national, State, district, or local committees (including any subordinate committee thereof) of the same political party.”
The reason for this Congressional exemption of transfers between political committees of the same party is perfectly obvious: there is no evil to be prevented by barring the free exchange of funds among political committees of the same party. There is no fear of undue influence exerted by a large contributor over the individual candidate or political officeholder, for two reasons: (1) the individual contributions have originally been limited by the contribution limits in the statute; and (2) the political candidate or officeholder does not know who made the contributions to the overall national, state, district, or local committee which generously endows him with funds, or, at least, he does not- know who contributed the specific dollars which the individual candidate receives.22 And, no matter by whom or by whose agency the expenditures are made, the expenditures on any candidate’s behalf must be within the limits of § 441a(d)(3). Since there was no evil to be prevented by imposing a restriction on transfers, Congress very wisely specifically said that there were no limits on transfers; and, the Federal Election Commission, charged with implementing and enforcing the campaign laws, has very wisely and sensibly said, from the start and consistently thereafter, that the practice of designating another committee as an agent and authorizing expenditures of funds by the agent, when the funds could have been directly transferred anyway, is the equivalent of the transfers specifically authorized by the statute.
Not only is there no evil to be prevented by the limitation which the plaintiff Democratic Committee has persuaded my colleagues to write into the statute, but there are positive benefits to be gained by allowing the free interchange of funds among political committees of the same party, whether by direct transfers or indirectly by authorizing another committee to act as agent in making the expenditures. A party cannot “unduly influence” its own candidate, but by supplying funds for the individual candidate it may instill in the candidate some sense of party loyalty and party responsibility, which is generally recognized to be a beneficial relationship. Certainly to the extent an individual candidate is beholden to his own political party for a substantial portion of his campaign funds, he is much less vulnerable to individual pressure groups who would sway his vote, for good or evil, on certain critical issues.23
It should not be overlooked that the funds raised by the committees referred to in subsection (a)(4), whose funds are to be freely transferred, are funds raised from citizens all over the United States. To that extent they are an amalgamation, an expression of support from small contributors. In that respect they are similar to the funds raised through the federal tax process by the check-off on individual income tax returns, which is an expression of national policy preferring funds to be raised as anonymously and in as widespread a fashion as possible. To the extent that these funds can be used freely in individual Senate and House campaigns, we are implementing a definite national policy. The *790position urged by the plaintiff here and adopted by Judges Wright and Ginsburg cuts directly contrary to that salutary policy by eliminating the most effective and efficient method chosen.
V. FIRST AMENDMENT CONSIDERATIONS
It is quite apparent from the lengthy Congressional debates in regard to the federal election laws over a period of years that Congress was quite aware of the fact that, in imposing contribution and expenditure limitations, it was legislating in an area of vital First Amendment concerns. If there was any legislator who was not aware of that, he was surely made aware of it by the Supreme Court’s decision in Buckley v. Valeo. “The Act’s contribution and expenditure limitations operate in an area of the most fundamental First Amendment activities.” 24
There is no need to rehash the extensive Supreme Court analysis on the First Amendment grounds in Buckley. It is clear that the Court held that construction of the Act must be made in light of First Amendment rights, and so must this court’s construction here. It is sufficient to point out that the Supreme Court sustained limitations on individual contributions only because the perceived evil of undue influence by large contributors on candidates and officeholders was sufficient to justify these restrictions. At the same time, the Supreme Court struck down the limitations on individual expenditures on behalf of his own individual candidacy, because the use of money by an individual is a form of speech protected by the First Amendment, and there could be no evil of undue influence by one man exercising his First Amendment rights.
Similarly, in the case at bar, there is no visible evil in any “undue influence” by a political party on its own nominated candidate for the Senate or the House.25 Hence, there is absolutely no evil to be eliminated by gratuitously imposing a restriction on the free interchange of funds among the political committees of the same political party, so long as those funds are accounted for and the expenditures are controlled by a designated accountable committee within the overall limitations on expenditures for that office. It is illuminating to compare the specific restrictions, which Congress did clearly write into the statute, with the tortuous and convoluted construction which my colleagues find it necessary to engage in to sustain the prohibition against free interchange of funds argued for the plaintiff Democratic Committee.26 When there is no clear, specific prohibition against the action complained of, the difficulty of finding the rationale to restrict free speech should be proof positive that my colleagues are engaged in an unworthy effort.
Mark this well. No person, no group of persons (committee) needs the permission of any Congress or any court to spend money to assist candidates for public office. That is free speech. There can be limitations and regulations as to amounts, methods, *791publicity, and accountability, but the validity of those limitations will be strictly tested. The limitation must be justified by the evil which the limitation is designed to prevent, just as we test any other limitation on free speech. In this, as in any other area of free speech, the limitation must be precisely spelled out and clearly relevant to prevention of evil.27 Neither the plaintiff nor my colleagues have even claimed any evil to be prevented by the restriction they would en-graft on the statute. Section 441a(d)(3) is no prohibition on the activities of intervenor National Republican Senatorial Committee, but an overall limit on expenditures for federal elective office and a method of accounting utilizing the respective party national and state committees. The only other relevant provision, § 441a(a)(4), authorizes the intervenor NRSC to do directly what it has done indirectly here. In what the Supreme Court has termed “an area of the most fundamental First Amendment activities,” this is a shaky foundation for the decision my colleagues stretch to reach.
. 2 U.S.C. § 437g(a)(8)(C) (1976) and subsequent amendments.
The statutory standard for judicial review requires the court to overturn a Commission interpretation of its implementing statute which is “contrary to law.” Id. § 437g(a)(8)(C). The Federal Election Campaign Act delegates to the Commission especially broad discretion to set election law policy and to draw the meaningful distinctions appropriate to definitions under the election law. E. g., 2 U.S.C. § 437c(b)(l), as amended by Pub.L. No.96-187, § 306(b)(1), 93 Stat. 1355 (1979): “The Commission shall administer, seek to obtain compliance with, and formulate policy with respect to, this Act," (emphasis added); 2 U.S.C. § 431(14) — (15): “The[se] term[s] ... mean[ ] .... as determined by the Commission ” (emphasis added).
. Democratic Senatorial Campaign Committee v. FEC, No. 80-1903 (D.D.C. 28 Aug. 1980).
The penchant of this court to give no deference whatsoever to the responsible agency’s interpretation of its role and basic statute has been noted with acerbity by the Supreme Court in Vermont Yankee Nuclear Power Corp. v. NRDC, 435 U.S. 519, 98 S.Ct. 1197, 55 L.Ed.2d 460 (1978) and by commentators, e. g., Scalia, “Vermont Yankee: The APA, the D.C. Circuit, and the Supreme Court,” 1978 S.Ct.Rev. 345, 358, 371. Deference to the Commission on new issues like this before a new agency gives the agency the chance it needs to make its own interpretation, because it has the responsibility to make its statute work. Power Reactor v. Electricians, 367 U.S. 396, 408, 81 S.Ct. 1529, 1535, 6 L.Ed.2d 924 (1961). Deference to the Commission’s view on election law policy and what constitutes compliance seems particularly advised in that events occur very quickly in an election year. The Commission is the expert body charged by Congress with the coherent administration of elections and must, therefore, be competent to reach expeditious and equitable judgments drawing reason out of a melange of vaguely consistent election laws obviously adopted by the process of political compromise on this highly charged political field; it is the Commission which is prepared to read the body of election law as a whole. Moreover, the Commission is self-consciously bipartisan. Congress created a Commission, 2 U.S.C. § 437c (1976), which could make sensitive political decisions cognizant of bipartisan exigencies. Courts should tread lightly on these matters of party politics.
. The Federal Election Campaign Act of 1971 (FECA), Pub.L.No.92-225, 86 Stat. 3, was amended by the Federal Election Campaign Act Amendments of 1974, Pub.L.No.93-443, 88 Stat. 1263, by the Federal Election Campaign Act Amendments of 1976, Pub.L.No.94-283, 90 Stat. 475, by the Social Security Amendments of 1977, Title V, Sec. 502, Pub.L.No.95-216, 91 Stat. 1565, and by the Federal Election Campaign Act Amendments of 1979, Pub.L.No.96-187, 93 Stat. 1339.
. The majority, maj. op. at 778-779, appears to be singularly concerned with who may spend money under FECA rather than from where campaign money may lawfully flow. The transfer provision, 2 U.S.C. § 441a(a)(4), indicates strong legislative intent that campaign monies flow freely through a political party’s extended network. Plainly, Congress thought to permit the discretionary assignment of funds among a party’s component organizations.
. See notes 7-18, 25 infra & accompanying text. See also Common Cause v. Schmitt, 512 F.Supp. 489 at 499 & n. 40 (D.D.C.1980) (three-judge court).
. Counsel for appellant, Democratic Senatorial Campaign Committee, has informed the court that it too is the designated agent of its party’s national committee.
. Cf. Maj. op. at 781-782.
. Advisory Opinion, AO 1976-108, reprinted in Commission Appendix at 3a, reprinted in [1980] Fed.Elec.Camp.Fin. Guide (CCH) ¶5236.
. There is no question in this case of limitations on contributions under 2 U.S.C. § 441a(h) ($17,-500 contribution limit imposed on national and Senatorial Campaign Committees). This case involves only the spending of money in campaigns and applicable expenditure limits.
. See Brief for Appellee at 3; Appellant’s Brief at 20 n.16; Brief in Behalf of Intervenor, Republican National Senatorial Committee at 3-4.
. See Brief in Behalf of Intervenor, Republican National Senatorial Committee at 4.
. Reprinted in Brief for Appellee, Commission Appendix at 3a; [1980] Fed.Elec.Camp.Fin. Guide (CCH) ¶ 5236.
. See Brief in Behalf of Intervenor, Republican National Senatorial Committee at 4.
. See Commission files, Matter Under Review, MUR 780 (19 Jan. 1979).
. See Commission files, MUR 820 (19 June 1979).
. The broad, inclusive scope of the transfer provision, 2 U.S.C. § 441a(a)(4), the compelling need for Commission discretion, and the congressional contemplation of joint “national committee”/“Senatorial Campaign Committee” activity obvious in 2 U.S.C. § 441a(h), all suggest that any committee of a political party, including a party’s Senatorial Campaign Committee, would be free to initiate and receive funds transfers under § 441a(a)(4). The Senatorial and Congressional Campaign Committees are identifiable as, and are in fact, part of either the Republican or Democratic parties. See 119 Cong.Rec. S5194 (daily ed. 3 Apr. 1974) (remarks of Sen. Baker). Furthermore,
[t]he conferees also determined that it is appropriate to set a higher limit on contributions from persons to political committees of national political parties in order to allow the political parties to fulfill their unique role in the political process. In this connection, the term “political committee established or maintained by a national political party” includes the Senate and House Campaign Committees.
H.R.Rep.No.94-1057 (Conf.Rep.), 94th Cong.2d Sess. 58 (1976) (discussion of 2 U.S.C. §§ 44 la(a)( 1 )(B)-(2)(B)).
. See Buckley v. Valeo, 424 U.S. 1, 25-26, 96 S.ct. 612, 637-638, 46 L.Ed.2d 659 (1976) (per curiam).
. Controlling campaign contributions, the Supreme Court held in Buckley v. Valeo, legitimately suppressed corruption and venal influence by eliminating the possibility of quid pro quos.
. 11 C.F.R. § 110.7 (1977).
. See notes 17-18 supra & accompanying text.
. Party committees, including Senatorial and Congressional Campaign Committees, it is worth noting, are deemed incapable of making independent expenditures which were accorded great protection in Buckley v. Valeo, 424 U.S. 1, 96 S.Ct. 612, 46 L.Ed.2d 659 (1976) and Common Cause v. Schmitt, 512 F.Supp. 489 (D.D.C.1980) (three-judge court). See Brief for Appellee at 10 n.5. 2 U.S.C. § 441a(d) is the *789only statutory authorization for expenditures by party political committees. There is no support for an inference that Senatorial and Congressional Campaign Committees were meant by Congress to be excluded from making any expenditures at all in connection with campaigns. It makes more sense that these Campaign Committees should share in their parties’ overall expenditure limitations.
. See generally Common Cause v. Schmitt, 512 F.Supp. 489 (D.D.C.1980) (three-judge court).
. As a Congressman, Judge Abner Mikva, presently a member of this court, argued for the benefits of free transferability of party funds. 124 Cong.Rec. H2263 (daily ed. 21 March 1978).
. 424 U.S. 1, 14, 96 S.Ct. 612, 632, 46 L.Ed.2d 659 (1976).
. Cf. Common Cause v. Schmitt, 512 F.Supp. 489 (D.D.C.1980) (three-judge court) at Part III. A. 4. (political committees, through expenditures rather than contributions, do not pose quid pro quo threat).
. The First Amendment protects political association as well as political expression. The constitutional right of association explicated in NAACP v. Alabama, 357 U.S. 449, 460, 78 S.Ct. 1163, 1170, 2 L.Ed.2d 1488 (1958), stemmed from the Court’s recognition that “[e]ffective advocacy of both public and private points of view, particularly controversial ones, is undeniably enhanced by group association.” Subsequent decisions have made clear that the First and Fourteenth Amendments guarantee “freedom to associate with others for the common advancement of political beliefs and ideas,” a freedom that encompasses “ ‘[t]he right to associate with the political party of one's choice.' ” Kusper v. Pontikes, 414 U.S. 51, 56, 67, 94 S.Ct. 303, 307, 312, 38 L.Ed.2d 260 (1973), quoted in Cousins v. Wigoda, 419 U.S. 477, 487, 95 S.Ct. 541, 547, 42 L.Ed.2d 595 (1975).
Buckley v. Valeo, 424 U.S. 1, 15, 96 S.Ct. 612, 632, 46 L.Ed.2d 659 (1976) (emphasis added). See also Common Cause v. Schmitt, 512 F.Supp. 489 (D.D.C.1980) (three-judge court) at Part III B.
. I submit that the majority fails to grasp the significance of what the Supreme Court did in Buckley v. Valeo, 424 U.S. 1, 96 S.Ct. 612, 46 L.Ed.2d 659 (1976), in upholding limits on Contributions, but striking down limits on Expenditures. (See maj. op. at n. 27.) Both are in the First Amendment area. Where contributions are concerned, the evil of the quid pro quo is obvious, so the statutory limits are justified. Expenditures are a different matter, for there is no visible corruption when money amplifies free speech; hence the Court struck down every limitation on Expenditure challenged on First Amendment grounds. In so doing the Court spoke in terms relevant to the majority’s effort to restrict expenditures here:
“No governmental interest that has been suggested is sufficient to justify the restriction on the quantity of political expression imposed by § 608(c)’s campaign expenditure limitations.
“The interest in alleviating the corrupting influence of large contributions is served by the Act’s contribution limitations and disclosure provisions rather than by § 608(c)’s campaign expenditure ceilings.” (p. 55)
“The interest in equalizing the financial resources of candidates competing for federal office is no more convincing a justification for restricting the scope of federal election campaigns.”
“There is nothing invidious, improper, or unhealthy in permitting such funds to be spent to carry the candidate’s message to the electorate.64
As an opinion dissenting in part from the decision below noted: “If a senatorial candidate can raise $1 from each voter, what evil is exacerbated by allowing that candidate to use all that money for political communication? I know of none.” 171 U.S.App.D.C., at 268, 519 F.2d, at 917 (Tamm, J.)” [in which this writer joined], (p. 56)
“The First Amendment denies government the power to determine that spending to promote one’s political views is wasteful, excessive, or unwise. In the free society ordained by our Constitution it is not the government, but the people — individually as citizens and candidates and collectively as associations and political committees — who must retain control over the quantity and range of debate on public issues in a political campaign.
“For these reasons we hold that § 608(c) is constitutionally invalid.” (pp. 57-58)
The Court went on to validate contribution ceilings, but “[b]y contrast, the First Amendment requires the invalidation of the Act’s independent expenditure ceiling, § 608(e)(1), its limitation on a candidate’s expenditures from his own personal funds, 608(a), and its ceilings on overall campaign expenditures, § 608(c). These provisions place substantial and direct restrictions on the ability of candidates, citizens, and associations to engage in protected political expression, restrictions that the First Amendment cannot tolerate." (Emphasis added.) Id. at 58-59.
The specific holding of Buckley was, of course, as the majority suggests (maj. op. at n. 27), to invalidate the independent expenditure limitations, not to rule on expenditures of a political party committee — a ruling which, if made, would have left one point of view in the case at bar bereft of any support whatsoever. But surely the language used by the Court, the rationale of sustaining restrictions only where there was an obvious evil to be prevented, is highly relevant to our problem here. Buckley confirms that all of FECA’s campaign “contribution and expenditure limitations operate in an area of the most fundamental First Amendment activities." 424 U.S. at 14, 96 S.Ct. at 632.