Bnitcd ~rotes ~cnatr WASHINGTON, DC 20510 69 January 23, 2018 The Honorable Ajit Pai Chairman Federal Communications Commission 445 12th St. SW Washington, DC 20554 Dear Chairman Pai: As you review WWOR-TV's (My 9) operating license renewal application, we request that you consider the persistent refusal of WWOR-TV to abide by its legal obligations to provide the people of Northern New Jersey with local news and information. As you know, if the densely populated state of New Jersey had its own media market, it would be the fourth-largest media market in the country. However, due to its position between New York City and Philadelphia, the state does not have a designated market area. WWOR-TV is the only commercial high-power station in New Jersey. Carrying out a law passed in 1982, the FCC stipulated that any license holder for WWOR "devote itself to meeting the special needs of its new community (and the needs of the Northern New Jersey area in general)." The WWOR-TV license makes clear - and the FCC has confirmed on multiple occasions - that WWOR has special obligations to serve North Jersey. Yet despite these requirements, concerns about WWOR-TV's failure to live up to its broadcasting obligations in New Jersey have endured for over a decade. WWOR-TV's failure to provide local news coverage goes back several years. In 2009, WWOR­ TV reduced its news coverage by more than half. At that time WWOR-TV broadcast 8.8% as much news programming as its peer group. 1 Six years later, WWOR-TV's news programming remained stagnant at 3 hours/week, while its peer stations increased their average news coverage to 56 hours/week.2 This difference is simply startling. The FCC's refusal to hold WWOR-TV accountable is unacceptable. For years, WWOR-TV has flouted its responsibility, and yet the Commission does nothing. Moreover, the FCC's granting of a cross-ownership waiver, belies the Commission's goals of diversity, localism, and competition. These goals are even more important given the recent spate of television station "mega-mergers". 3 1 "Petition to Deny Renewal, Filed by Voice for New Jersey, Before the Federal Communications Commission: File No. BRCDT-20150202ACT." FCC.gov. May I, 2015. Accessed December 19, 2017. http://licensing.fcc.gov/cgi­ bin/prod/cdbs/fonns/prod/getimportletter_ exh.cgi?i mport_ letter_ id =64062. 2 Jbid. 3 https://www.usatoday.com/story/tech/news/2017I I I/ 05/4-states-try-block-conservative-tv-mega­ merger/82980900 I I We feel strongly that WWOR-TV's refusal to abide by its legal obligations should factor heavily in your review of its license renewal application. Thank you in advance for your prompt attention to this matter. Sincerely, "