A lawyer for Fletcher, Heald spelled out some of the...

they're not codified and could change without notice, Steve Lovelady wrote on the law firm’s blog (http://xrl.us/bmzh7y). “There’s no guarantee that the staff won’t perceive in your particular deal some reason to change things up along the way without telling anybody (including you) in advance.” In the past, staff analyses of such deals have hit on three major elements of a station’s operation, he said: programming, financing and personnel. Because FCC rules attribute a cognizable interest to any party that supplies more than 15 percent of the total weekly programming to a station, that 15 percent threshold, or 25 hours per week in a 24/7 station, is an important limit, he said. In the past, FCC “staff has insisted that each station licensee must retain control over the entertainment programming aired on its station,” Lovelady said. Staff also appears to have concerns with agreements where the service providing entity owns or controls more than 80 percent of the asset value of the station receiving services, he said. Staff has indicated that a recipient of services must keep at least two full-time employees on its payroll, he said. One of them must be a manager with “full editorial discretion,” he said. “Parties looking to enter into SSA/JSA arrangements should exercise caution,” he said. “The staff’s ad hoc approach ... usually implemented through informal conversations, has not resulted in a substantial body of written precedent."