8 Finally, the Administrative Costs Allocation Regulation is contrary to law. Under 11 C.F.R. § 106.6(c), committees must use “at least 50 percent Federal funds” for “administrative expenses, costs of generic voter drives, and costs of public communications that refer to any political party.” An obvious problem is this rule applies in oddnumbered years when there are no federal elections. If later this November EMILY’s List were to say “vote a straight Democratic ticket for the city counsel” in a broadcast in Walla Walla, Washington, no less than half of the cost would have to be expensed to a federal account, even though there is no federal race to influence. The FEC is explicit: if a communication mentions a political party, then context is irrelevant. See FEC Advisory Op. 2005-13, at 4–5 (Oct. 20, 2005) (the duty to “pay the costs of public communications that refer to a political party with at least 50 percent Federal funds does not change based on the activities of [the committee] in the particular State”). Contrary to this regulation’s premise, moreover, certain “administrative expenses” do not always reflect a federal purpose, mixed or otherwise. A committee, for example, that opposes human cloning (and thus supports many different state and federal candidates and laws throughout the nation) may launch an outpost in a state that is considering an anticloning measure and organize a voter drive there,6 even though the group has no intention of participating in any federal election. By this regulation, a full half of the costs 6 A “generic voter drive” includes “any . . . activities that urge the general public to . . . support candidates . . . associated with a particular issue, without mentioning a specific candidate.” 11 C.F.R. § 106.6(b)(1)(iii) (emphasis added). Thus, if a committee says “support candidates for the General Assembly who oppose human cloning” in an odd-numbered year, hard money is required.