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                               JOINT STATEMENT OF

      COMMISSIONER JONATHAN S. ADELSTEIN AND COMMISSIONER MICHAEL J. COPPS

   In the Matter of Sonshine Family Television, Inc, and Sinclair Broadcast
   Group, Inc., Notice of Apparent Liability for Forfeiture

   Growing abuses of the public trust in recent years are shaking Americans'
   confidence in the press. When pundits are paid to promote a corporate or
   government agenda while the public is never told, all commenters and
   journalists become suspect. The repeated revelations of advertisers paying
   their way onto news programming without disclosure undercut the
   credibility of all journalists. When budget cuts in newsrooms lead
   broadcasters to substitute advertisements disguised by slick public
   relations firms as news instead of paying for their own work, viewers and
   listener wonder what they can believe. When newsrooms are too strapped or
   sloppy to perform their due diligence and provide disclosure
   announcements, as required by law, it leads to a crisis of confidence.

   So we now face a crisis in American journalism. That is why today's action
   by the Commission is so important. It sends a clear message that the
   public has a right to know who is trying to persuade them so they can make
   up their own minds about what is presented to them.

   While some will try to turn this into a First Amendment issue, sponsorship
   identification in no way requires anyone to limit anything they
   communicate. On the contrary, it requires more speech, not less. The only
   reason it can be construed as limiting expression is because broadcasters
   and cable operators are too embarrassed to reveal who paid to produce or
   espouse material they are pretending is their own product. In fact,
   established ethical guidelines, which are routinely ignored, call for just
   such disclosure. The reticence to disclose, or to otherwise refrain from
   using material paid for by a sponsor, is not a restraint upon free
   expression.

   Today, with the release of this Notice of Apparent Liability for
   Forfeiture, the Commission again puts broadcasters and cable operators on
   notice that the public deserves a clear statement on whether or not the
   programming they are watching is sponsored by a government or corporate
   interest.

   This Forfeiture Notice reinforces the rule that the Commission's
   disclosure obligations do not only apply to broadcasters. Rather, the
   Commission is serious about applying the rules to everyone up and down the
   chain of production and distribution. Today, the Commission places
   broadcasters, producers and distributors on notice. Each and every
   individual has a duty to report the real source of any programming on
   television or radio. Employers and employees must ensure the audience
   knows where the programming they are watching originated or who paid for
   it. The argument that the overall presentation of the material obviates
   the need to provide sponsorship identification announcements is
   unavailing. Under our clear rules, any consideration must be revealed to
   the audience.

   Failure to disclose Armstrong Williams was paid by the Department of
   Education to promote an agenda on the air by itself violates Federal law.
   On top of that, without making a positive or negative judgment of the
   content aired, we find that in the instant case a licensee could not, in
   good faith, consider the material to be "anything but political." The
   Commission has already concluded that electoral issues are presumptively
   controversial and of public importance. In fact, we both struggle to find
   an issue more important to many parents than their child's education. We
   feel it is not too much of a stretch for programmers to understand what is
   a political issue and what is not. Broadcasters should strive to present
   independent and honest broadcasting, and should ethically desire to be
   forthcoming and open about where its programming is coming from.

   The integrity of the press is of paramount importance to any democracy. As
   the Commission has clearly warned, audience members must be able to tell
   where the program they are watching ends and the paid advertisement
   begins. Today's Forfeiture Notice reaffirms the affirmative legal
   obligation of broadcasters to alert the public to any payola punditry and
   places the industry on notice that the Commission will act to ensure the
   public is protected from special interest groups who attempt to trick the
   public.

   While this action is overdue, we are pleased the Commission takes this
   issue seriously. This Forfeiture Notice demonstrates how important it is
   for broadcast stations to clearly announce any sponsors furnishing
   material or services, particularly for use in connection with the
   broadcast of political material or discussion of a controversial issue of
   public importance. Accordingly, we speak in a unanimous voice.

   See Letters from Enforcement Bureau, FCC, to Graham Williams Group and
   Ketchum, Inc., File No. EB-05-IH-0031 (July 23, 2007).

   Section 507 of the Communications Act of 1934, as amended, codified at 47
   U.S.C. S: 508. See Letter from Enforcement Bureau, FCC, to Graham Williams
   Group, Inc., File No. EB-05-IH-0031 (July 23, 2007)("[T]he record
   established that Williams and GWG [the Graham Williams Group] received
   more than nominal consideration from DoED [Department of Education] to
   include particular material in programming supplied to and intended for
   transmission by broadcast stations and that the material was, in fact,
   aired by various broadcast stations. In these circumstances, Williams and
   GWG were obligated under Section 507 to disclose to the licensees
   reviewing the programming that the NCLB-related broadcast material was
   sponsored by DoED. The record also established that such disclosure was
   not provided by either Williams or GWG. We conclude that WGB and Williams
   violated Section 507 of the Communications Act.").

   Forfeiture Notice at footnote 45.

   Federal Communications Commission FCC 07-152