The Honorable Tom Wheeler 
Chairman 
tinit(d ~tat(S ~(nat( 
WASHINGTON. DC 20510 
March 26,2014 
Federal Communications Commission 
445 12111 Street SW 
Washington, DC 20554 
Dear Chai1man Wheeler: 
We write to express our deep concern regarding your proposal to change media ownership po licy 
in the discrete matter of attributing joint sales agreements (JSAs) between TV broadcasters. We 
are further troubled that the Commission plans to move forward on this ownership matter at its 
March Open Meeting when the agency has not started the 2014 Quadrennial Review of all its 
media ownership rules as required by law, and has fai led to complete the 20 10 Quadrennial 
Review. 
As you noted in your March 6 posting on the Commission's blog, ·' it's been six years since the 
Commission last completed a quadrennial review, so it goes without saying that the video 
marketplace has changed dramatically since the FCC last updated these rules." We agree with 
this assessment. and call upon the Commission to work quickly to fu lfill its long-overdue 
statutory ob ligation. We are nevertheless surprised by and disagree with your suggestion that, 
before attending to its statutory obligation, the Commission should act to change attribution rules 
for TV station joint sales agreements in isolation. 
The quadrennial review requi rement is designed to ensure that the Commission has a timely and 
relevant understanding of the competitive landscape to in fo rm its review of the media ownershi p 
rules in their entirety, avoiding a piecemeal approach. lt is difficult to understand the sudden 
urgency to carve out one specific facet of the rules lo r modification when the intended, 
statutori ly-requi red process for measured, comprehensive consideration has been neglected for 
so long. 
Moreover, your proposed action on attribution of joint sa les agreements may have the practi cal 
efl'ect of undermining the values of competition, localism, and diversity you contend to promote. 
The number of minority-owned TV stat ions has dropped significantly within the past ten years. 
Several such stations today, including the only three stations owned by African-Americans. 
operate with joint sales agreements. Competition, localism, and diversity would likely be 
significant casualties o f your proposed action to force the undoing of such agreements. 
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We strongly urge the Commission to carry out its rev iew of media ownership rules in a 
comprehensive manner, following the quadrennial review proc\ ss envisioned and enacted by 
Congress to facilitate a broad, well-informed perspective on thes.e ru les and the complicated 
ecosystem they govern. However, should you consider changing the rules governing joint sales 
agreements in isolation, the Commission must bear in mind the potential negative impact of this 
change to minority television ownership. 
Sincerely, 
Timothy E. Sc6tt 
U.S. Senator 
Dan Coats 
U.S. Senator 
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Pat Toomey 
U.S. Senator