Following up on my post from yesterday, Lance Olson writes:

Your reference to the FPPC “regulation” that limits contributions to $25,000 for committees that run ads at the behest of a candidate and that feature the candidate within 45 days of an election (Govt. Code section 85310) would not apply to the Governor if he calls a special election this fall–at least not as interpreted by the FPPC. FPPC regulation 18531.10(c) limits the application of 85310 to circumstances where the candidate featured is appearing on the ballot within 45 days. Of course, the Governor will not appear on the special election ballot. By the way, if the Governor were to cooperate in filming the ad, there would be little question that it was made at his behest.

Thanks for writing! If the FPPC’s interpretation would hold up, that of course makes a very big hole in the FPPC’s attempt to regulate ballot measure committees that act as alter egos of candidates. One way to counteract this interpretation is to expand the definition of what counts as candidate “control.”