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WASHINGTON, DC 20510 
The Honorable Thomas Wheeler 
Chairman 
Federal Communications Commission 
445 lth Street, S.W. 
Washington, D.C. 2{)554 
Dear Chairman Wheeler: 
June 12,201 4 
Although the nature of news media is rapidly changing, a robust and vital local broadcast news 
industry remains critically important to our constituents. Local newscasts are a key source of 
daily information to citizens of our states, especially in smaller or more rural markets and 
particularly in times of emergency. Unfortunately, market pressures in the broadcasting industry 
are making it harder for smaller stations to survive. If regional stations go dark, our constituents 
will be the ultimate losers. 
We are concerned, therefore, that the Federal Commtmications Commission's recently 
promulgated rules with respect to Joint Sales Agreements will further undermine the ability of 
local broadcasters to serve their communities. While we appreciate your desire to promote 
competition in the marketplace, the new rules are interrupting established business practice and 
creating substantial uncertainty in the broadcasting market. Ultimately, we fear the result will be 
less competition since certain broadcasters may be forced to cease operations, which would harm 
not only the broadcasters themselves but also the viewers they serve. 
Specifically, as a result of the FCC's decision to count JSAs between television stations as 
ownership interests, many existing agreements will have to be unwound unless specific waivers 
are granted. These existing agreements were consistent with the law and rules at the time they 
were executed, and business plans have been built around them. Forcing the broadcasters to rely 
on the speculative possibility of a waiver creates substantial business challenges. 
In addition to the business uncertainty the new rules create with respect to existing agreements, 
we are concerned that the new JSA rules going forward wi ll unnecessarily foreclose many 
agreements that have resulted in improved local service and a more robust broadcast industry. 
This is especially true in smaller markets where stations may, absent a JSA, struggle to generate 
sufticient advertising revenue to support the production of locally oriented programming. 
Finally, we are disturbed by reports that new processing guidelines looking at JSAs and other 
sharing arrangements have caused applications for broadcast station transfers to be stalled at the 
FCC. These delays create further market uncertainty and challenges. 
Fortunately, we believe the Commission can successfully address these concerns within the 
framework of the existing rules. Accordingly, we urge the Commission to adopt a waiver policy 
that does not penalize JSAs that were structured and executed prior to the issuance of the new 
rules. In addition, the Commission's waiver policy going forward should favorably regard, for 
example, JSAs that promote more or better local news, public affairs and emergency 
information, diverse programming such as foreign language and expanded ownership 
opportunities for minorities and women in broadcasting. Finally, we hope the Commission will 
take swift action on pending television station transactions in the very near future. 
Thank you for consideration of these issues. 
Sincerely, 
Charles E. Schumer 
United States Senator 
~· 
United States Senator 
Kirsten E. Gillibrand 
United States Senator 
Barbara A. Mikulski 
United States Senator 
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Robert P. Casey Jr. 
United States Senator