FEDERAL COMMUNICATIONS COMMISSION 
WASHINGTON 
OFFICE OF 
THE CHAIRMAN 
The Honorable Richard E. Neal 
U.S. House ofRepresentatives 
2208 Rayburn House Office Building 
Washington, D.C. 20515 
Dear Congressman Neal: 
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. 
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. 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. 
Stations have been on notice of potential regulatory action on JSAs 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, including in 201 0 when the 
Commission sought additional comment as part of the Quadrennial Review ofbroadcast 
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. 
The Commission's 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. 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. I believe that adopting the rule with a waiver 
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process will better protect competition and diversity than merely grandfathering existing 
agreements. 
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.