FEDERAL COMMUNICATIONS COMMISSION 
WASHINGTON 
OFFICE O F 
THE CH A IRMAN 
The Honorable Tom Marino 
U.S. House ofRepresentatives 
410 Cannon House Office Building 
Washington, D.C. 20515 
Dear Congressman Marino: 
May 1, 2014 
Thank you for your letter expressing concerns regarding the recent Commission action to 
attribute certain Joint Sales Agreements (JSAs) between television stations. I appreciate the 
opportunity to provide some clarification about the Commission's March 31, 2014 decision to 
attribute TV JSAs where one station sells 15% or more ofthe weekly advertising time on behalf 
of another station in the same market. 
The Commission is taking a comprehensive review of the broadcast ownership rules as 
part of our recently adopted Further Notice of Proposed Rulemaking that started the 2014 
Quadrennial Review. In that proceeding, we seek comment on a tentative conclusion that the 
current local TV ownership rule should be retained with a limited modification to account for the 
DTV transition. Historically, the Commission' s rules have prohibited one television broadcaster 
from owning more than one licensee in small and medium-size markets. The purpose of this is 
to foster competition, localism, and a diversity of voices in the public interest. 
Even in light of the pending proceeding, it is important that the Commission continues to 
enforce its existing rules . There has been a growing concern over the last decade that TV 
stations are using JSAs as a way to circumvent our local TV ownership restrictions, by 
influencing the core operating functions of the other station in a market where joint ownership 
would not be allowed under the rules. I do recognize that there could be some exceptions where 
an attributable JSA could be in the public interest, which is why the Commission adopted an 
expedited waiver process as part of its Order. 
Stations have been on notice since 2004 when the Commission first started a proceeding 
proposing to attribute these types of TV agreements. Since the start, the industry has participated 
in the proceeding, and again in 201 0 when the Commission sought additional comment as part of 
the Quadrennial Review of broadcast ownership rules. Additionally, in the Gannett/Belo 
transaction you cite in your letter, the Bureau put broadcasters on notice that Commission staff, 
on a going-forward basis, will be closely scrutinizing pending transactions that contain 
agreements that could raise concerns regarding the control or influence of the brokered station. 
Page 2-The Honorable Tom Marino 
By moving decisions on broadcast ownership into the open, we will enable the public and 
the Commission to consider more fully and appropriately the public interest issues raised by the 
implementation of the Commission' s rules. 
I hope this information is helpful. 
Sincerely~ j A / j 
~-b-.11~ 
Tom Wheeler