FEDERAL COMMUNICATIONS COMMISSION 
WASHINGTON 
O F FI C E OF 
T H E CHAIRMAN 
The Honorable Mary Landrieu 
United States Senate 
328 Hart Senate Office Building 
Washington, D.C. 20510 
Dear Senator Landrieu: 
July 22, 2014 
Thank you for your letter expressing concerns regarding the Commission's March 31, 
2014, action to attribute certain Joint Sales Agreements (JSAs) between television stations. I 
appreciate the opportunity to provide you with some additional context for the decision. 
Our action should not have been a surprise to the industry. Stations have been on notice 
of potential regulatory action on JSAs since 2004 when the Coqunission first started a 
proceeding proposing to attribute JSAs where one station sells 15 percent or more of the weekly 
advertising time on behalf of another station in the same market. The concern then- as it is 
today- was that the use of such JSAs provides the incentive and potential to unduly influence 
the core operating functions of the brokered station, including programming decisions. In 
fmalizing our decision, we sought additional comment in the 2010 Quadrennial Review on these 
issues and also considered the evidence from our license transfer application process, where we 
have reviewed an increasing number of JSAs in recent years. These JSAs have generally 
involved the sale of 100 percent of the advertising time of the brokered station in conjunction 
with a number of other operational and fmancial arrangements between the stations. It is also 
clear that in many instances such arrangements reduce or homogenize local news. 
The existing agreements between stations cited in your letter are the result of a business 
practice that evolved to circumvent the Commission's local TV ownership rules that promote 
competition and viewpoint diversity by restricting the common-ownership of more than one 
station in small and medium-sized markets. Our action was necessary to close this loophole in 
the rules and enforce the restrictions we have on the books. The adoption of the new JSA 
attribution rules will require adjustment for some stations in the industry, which is why we 
allowed a two-year period for stations to come into compliance from the effective date of the 
rules. 
I do recognize that there could be some exceptions where attributing a JSA for purposes 
of our ownership rules could be in the public interest, which is why we adopted an expedited 
waiver process. I believe that adopting the rule with a waiver process will better protect 
competition, localism, and diversity than merely grandfathering existing agreements. I agree 
with you that the Commission should- and will- look to all of the facts presented in a waiver 
request, including the impact of the JSA on the ability of the brokered station to continue to serve 
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their communities. I encourage any station that believes its existing JSA is in the public interest 
to file a waiver request early in this period. 
For stations that have pending license transfer applications that involve JSAs, Shared 
Services Agreements (SSAs), and other fmancial agreements, the Media Bureau is actively 
working with the parties to discuss possible amendments to those applications, where necessary. 
I strongly support the close scrutiny that the Bureau must apply to ensure that these proposed 
agreements do not result in undue influence or control. Since mid-March, the Bureau has 
granted 50 full-power television assignment and transfer of control applications, which represent 
20 separate transactions. The Bureau staff will continue to process other pending applications. 
I hope this information is helpful. 
~Y;~t 
Tom Wheeler