TOM MARINO 
10TH DISTRICT, PENNSYLVANIA 
COMM!TIEE ON THE JUDICIARY 
COMMITIEE ON HOMELAND SECURITY 
COMMITIEE ON FOREIGN AFFAIRS 
www.marino.house.gov 
www.facebook.com/CongressmanMar'ino 
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The Honorable Tom Wheeler 
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March 24, 2014 
Chairman, Federal Communications Commission 
445 12th Street, S.W. 
NMiYtni & Inspected 
MAR 3 ·1 2014 
Washington, D.C. 20554 FCC Mail Room 
Dear Chairman Wheeler: 
WASHINGTON OFFICE 
410 CANNON HOUSE OFFICE BUILDING 
WASHINGTON, DC 20515 
1202) 225-3731 
CONSTITUENT SERVICE CENTERS: 
1020 COMMERCE PARK 0FliVE, SUITE 1A 
WILLIAMSPORT, PA 17701 
(570) 322-3961 
543 EASTON TURNPIKE, SUITE 101 
LAKE ARIEL, PA 18436 
(570) 689-6024 
35 SOUTH MARKET STREET, SUITE 1A 
SELINSGROVE, PA 17870 
(570) 374-9469 
I write to express my concern with the Federal Communications Commission's (FCC) proposal to increase 
the regulation of broadcast television joint sales agreements (JSAs) without completing a comprehensive 
review of the video marketplace and without regard for those broadcast stations that have relied on the law 
as currently written and interpreted. 
As you know, JSAs and related business arrangements are contractual tools that permit local broadcasters 
to more efficiently invest in and produce high quality local broadcast television programming that remains 
free over the air, and that serves as a critical lifeline in times of severe weather and emergency. In addition. 
JSAs allow broadcasters to more effectively compete in an increasingly fragmented local advertising 
market. Simply put, JSAs enhance broadcast localism and enhance the services that broadcasters are able 
to provide in their communities. 
Given these public interest benefits of JSAs as well as the substantial increase in local media competition, I 
am concerned by the FCC's recent proposal to declare a broadcaster as having an ownership interest in a 
station if it sells 15% or more of the advertising time for that competing station in the same market. I think 
it is imperative the FCC first take a more comprehensive review of the local marketplace and update 
underlying ownership restrictions. 
Finally, I strongly urge the FCC, should it continue down this worrisome path, to consider the equitable 
treatment of those broadcast stations that have operated in good faith under the current rules. Any change 
in the FCC's rules for JSAs should not trigger broadcast divestitures under outdated ownership regulations. 
In particular, I would ask that you carefully consider the treatment of pending transactions that may have 
been awaiting FCC approval for months. On December 20th, 2013, your office approved both the 
Gannett/Belo and the Tribune/Local TV transactions. Fairness dictates similar pending applications receive 
similar treatment and that any new rules be only applied prospectively, as opposed to retroactively. Lastly, 
as you consider new rules that substantially impact future transactions, I ask that you consider the local 
broadcasters, their employees, and the local viewership they serve. 
Thank you for your attention to this matter. I look forward to hearing your response to these concerns. 
Sincerely, 
Tom Marino 
Member of Congress 
cc: Commissioner Mignon Clyburn 
Commissioner Jessica Rosenworcel 
Commissioner Ajit Pai 
Commissioner Michael O'Rielly