With the party conventions and fall election getting closer, the Federal Election Commission (FEC) has published a brochure that explains restrictions on paid broadcasts that mention federal candidates 30 days before a primary or party convention and 60 days before a general election. This is the first election implementing the "electioneering communications" rule, which passed as part of the Bipartisan Campaign Reform Act of 2002 (BCRA). FEC regulations exempt 501(c)(3) organizations and unpaid broadcasts. The rule has raised new questions for the FEC on how it must be applied, including public service announcements where federal candidate appear, the breadth of the news exemption and advertising for Michael Moore's new film Fahrenheit 9/11. In Advisory Opinion 2004-14 the FEC ruled that Rep. Tom Davis (R-VA) can appear in a public service announcement broadcast within the blackout period, because the airtime for the announcement is free and the message is a permissible fundraising for a charitable organization. Davis is promoting the Kidney Foundation's Cadillac Invitational Golf Tournament, which will be held in his district. The National Rifle Association (NRA) is testing the breadth of the media exemption to the electioneering communications rule by launching a radio program that includes attacks on Sen. John Kerry (D-MA) for his voting record on gun issues and disputes his fitness to be commander-in-chief. The NRA began broadcasting its three-hour news program June 17 on Sirius satellite radio. The show reaches 400,000 listeners, many in swing states, between 2 and 5 p.m. and repeats the following morning between 6 and 9 a.m. on Right Channel 142. The NRA show raises questions about what types of communications qualify for the media exemption, and FEC definitions of what constitutes a "news story, commentary or editorial broadcast." The exemption does not apply if the broadcaster is controlled by a political party, candidate or political committee regulated by the FEC. In particular, there are factual questions about whether or not the NRA's control of the show takes it out of the media exemption, because the NRA has a federally regulated political committee. In addition, Sirius says it is broadcasting the show for free and the electioneering communications rule only applies to paid broadcasts. So far no enforcement complaints against the NRA have been filed with the FEC. The FEC also faces questions about the media exemption relating to advertising for documentaries that mention federal candidates. On June 24 the FEC approved Advisory Opinion 2004-15, which held broadcast ads by the Bill of Rights Educational Foundation for a planned documentary featuring President Bush are electioneering communications and cannot be paid for with corporate funds during the 30/60 day blackout periods. The Bill of Rights Foundation did not claim the media exemption, but the issue immediately arose when Citizens United filed an enforcement complaint against Michael Moore for ads promoting the documentary Fahrenheit 9/11. Members of the Congressional Black Caucus joined Moore at a press conference the next day, calling the complaint a violation of first amendment rights. Moore vowed to fight the complaint.