Dear Chairman Pai:
We write to raise serious concerns regarding your proposal to essentially eliminate the existing broadcast TV ownership rules with virtually no public input. This action, taken by way of a Reconsideration Order, is an obvious attempt to evade the notice and comment requirements that should accompany a decision of this magnitude.
The draft you released on October 27 takes steps akin to a statutorily-required Quadrennial Review of these same rules. Yet the sweeping deregulation, done at the behest of Sinclair Broadcast Group, among others, will provide the public with almost no opportunity to offer input and relies on data from three years ago. Using such tactics is contrary to prior reviews by the Commission, shirks the Commission's duties under the Administrative Procedures Act, and is a disservice to the public interest.
Americans care strongly about these issues, as evidenced by the high level of public participation in the Sinclair-Tribune merger. Aside from the parties to the applications, practically all of the public comments in that merger docket are strictly opposed due to concerns about consolidation and the impact on local news. The local TV ownership rule changes you propose to make in this Reconsideration Order effectively pave the way for Sinclair to merge with Tribune without any divestitures at the local level, but at a serious cost to diversity of viewpoint from local news outlets.
This path of least resistance to approval appears only to benefit the few at the cost to the many. Americans rely on their local TV broadcasters for local and diverse content. It is frightening to imagine what the future holds if the Commission votes in favor of your proposal. There will be few boundaries for Sinclair--or other broadcasters--from consolidating the use of these important public airwaves into fewer and fewer hands.
We request that you seek additional public comment on these proposed rule changes. A transparent and open process will allow for a more thorough debate and better inform the Commission with current data before it takes such dramatic action.