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UPDATED 8/3/2012 8 a.m. Editor’s Note: Tulsi Gabbard’s campaign briefly blocked access to her commercial on YouTube, but it is now available again.

Pay-to-play.

Those three little words have become code for the good-ol’-boy, closed-door politics of yesteryear. It’s a serious allegation, and it’s popping up in a second major race as the primary election approaches.

The specter of campaign-contributions-for-government-contracts corruption first emerged this year as a major issue in the Honolulu mayoral campaign. Now it’s leaking into the Democratic race for Congress.

The Pacific Resource Partnership made pay-to-play the central tenet of its attack campaign against anti-rail Honolulu mayoral candidate Ben Cayetano. Critical advertisements and the ensuing back-and-forth have been covered at great length in this space and elsewhere. (See the related articles on the right side of the page for a sampling.)

Now, Tulsi Gabbard is trying to make political hay out of pay-to-play and leaving it to voters to find the connection to Mufi Hannemann, her main opponent in the 2nd Congressional District Democratic primary. A new commercial released last week is titled and starts with those three ominous words.

It’s a game to them. Pay-to-play. Self-serving politicians take thousands from their contributors, then give them sweetheart deals, tax loopholes and bailouts. Tulsi Gabbard offers a fresh approach. ‘I’ll fight to end pay-to-play, focus on Hawaii’s economy and middle class, end the war in Afghanistan now, and invest in jobs here at home and protect Medicare and Social Security. I’m Tulsi Gabbard and I approve this message and no matter what I’ll always fight for you.

Watch the spot here:

Hannemann is neither mentioned by name nor pictured in the ad, but Gabbard has directly linked him to pay-to-play corruption before.

At a debate July 12, Gabbard asked Hannemann about news reports that he awarded $700 million in contracts to those who’d contributed to his campaign.

Gabbard, unavailable for an interview for three days this week, reiterated the purpose of the ad in an email to Civil Beat Wednesday. Favor-trading and undue influence by lobbyists is a factor in the country’s economic woes and Congress’ handling of healthcare, national defense and tax issues, she said.

“This type of ‘pay to play’ goes on at the expense of America’s middle class and it has to stop,” Gabbard wrote in her email. “Now, if you asked me do I think that Mufi would do anything to change that ‘pay to play’ culture in Washington, then I would have to say no, based upon his track record here in Hawai’i as Mayor.”

Her response and the structure of her new commercial — a gravelly voiced man talking about corruption gives way to a certain smiling, problem-solving City Council member — shows Gabbard’s willing to raise the specter of political corruption and even willing to link it to Hannemann, but doesn’t want to be seen as overly negative, aggressive or confrontational.

Instead, a campaign spokesman — who also represents PRP — provided three news reports to back up the pay-to-play commercial:

• An April 2008 Star-Bulletin revealing “at least 19 of the 62 firms” involved in the rail project had contributed to Hannemann’s political campaigns since 2000
• A September 2010 Hawaii Reporter revealing that $241,000 in political contributions came from people affiliated with firms with rail contracts totaling $20 million in value
• A July 2012 CBS News where “crooked lobbyist” Jack Abramoff opened his “playbook” to explain how he used money to buy powerful friends

Hannemann has fought back against the corruption allegations.

Hannemann’s campaign rejected Gabbard’s claim that he has received financial backing from “giant corporations and Wall Street banks” in a recent Star-Advertiser .

Civil Beat’s review of his of this year shows contributions from three First Hawaiian Bank executives, American Savings Bank’s CEO and Central Pacific Bank’s Political Action Committee. In the of 2012, he got some money from First Hawaiian Bank and Bank Of Hawaii. Neither report appears to include money from Wall Street financial institutions.

And when Gabbard asked him the pay-to-play question at the debate last month, the normally unflappable former Honolulu mayor bristled, saying his administration followed procurement rules. Later in the debate, he said “all the investigations in the world will never uncover anything illegal, improper with any contract that came out from my administration, whether it was rail or not.”

The recent emergence of “pay-to-play” in the race to represent Hawaii in Congress raises some complicated questions without easy answers:

• Did the PRP attacks against Cayetano lay the groundwork for Gabbard’s attacks against Hannemann by raising corruption as an issue in voters’ minds?
• Are Hannemann and Cayetano — political enemies, it should be noted — both juicy targets for corruption allegations because they’re viewed as part of Hawaii’s existing power structure?
• How big a factor is pay-to-play corruption in the way our system works, both here at Honolulu Hale and in the halls of Congress in Washington, D.C.?

Here’s another for readers to weigh in on: Is it fair to raise corruption as a campaign issue if you don’t have hard evidence that your opponent is corrupt?

And here’s one voters will soon answer: Is it effective?