FEDERAL COMMUNICATIONS COMMISSION 
WASHINGTON 
OFFICE OF 
THE CHAIRMAN 
The Honorable C.A. Dutch Ruppersberger 
U.S. House of Representatives 
2416 Rayburn House Office Building 
Washington, D.C. 20515 
Dear Congressman Ruppersberger: 
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. Even in light of the pending proceeding, it is important that the 
Commission continues to enforce its existing 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. 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. 
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, including in 201 0 when the Commission sought additional comment as part 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. 
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. 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 this process will better protect 
competition and diversity than would merely grandfathering existing agreements. 
Page 2-The Honorable C.A. Dutch Ruppersberger 
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.