FEDERAL COMMUNICATIONS COMMISSION 
WASHINGTON 
OFFICE OF 
THE CH A IR MA N 
The Honorable Barbara A. Mikulski 
United States Senate 
503 Hart Senate Office Building 
Washington, D.C. 20510 
Dear Senator Mikulski: 
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 of the weekly advertising time on behalf of 
another station in the same market. 
Stations have been on notice of potential regulatory action on JSAs since 2004 when the 
Commission first adopted a Notice of Proposed Rulemaking proposing to attribute these types of TV 
agreements. Since the start, the industry has participated in the proceeding, including in 2010 when 
the Commission sought additional comment as pa1t of the Quadrennial Review of broadcast 
ownership rules. In fact, it is our understanding that stations have been noting the possible change in 
policy as part of their SEC filings, and the Commission has consistently noted the pending 
proceeding to attribute JSAs in prior decisions on broadcast transactions that involve JSAs. 
Additionally, the Commission action on the TV JSA rule mirrors the path taken in 2002, when the 
Commission attributed JSAs for radio stations in the same manner and provided a 2-year period for 
stations to come into compliance. 
Historically, the Commission's rules have prohibited one television broadcaster from owning 
more than one station in small and medium-size markets. The purpose of this is to foster 
competition, localism, and a diversity of voices in the public interest. In the last few years, however, 
some broadcasters approached the Commission to approve agreements that effectively granted them 
ownership without a formal transfer of control. This practice rapidly evolved from an exception to 
common practice, with the number of such agreements ballooning in recent years to become a direct 
means of circumventing the Commission's ownership rules. In the case of public companies, the 
Securities and Exchange Commission filings acknowledge this reality in unmistakable terms. 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 ofthe Commission's rules. 
I hope this information is helpful. 
;?iftJ 
Tom Wheeler