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 Federal  Communications  Commission  FCC  04-  232
 Before  the  Federal  Communications  Commission
 Washington,  D.  C.  20554
 In  re  Application  of  )  )
 Michael  Radio  Group,  )  Assignor  )
 )  and  )  File  No.  BAPH-  20001101ABD
 )  Clear  Channel  Broadcasting  Licenses,  Inc.,  )
 Assignee  )  )
 For  Assignment  of  the  Construction  Permit  )  of  Station  KDAM(  FM),  1  Hope,  North  Dakota  )  Facility  ID  No.  88502
 MEMORANDUM  OPINION  AND  ORDER
 Adopted:  September  30,  2004  Released:  December  2,  2004
 By  the  Commission:  Commissioners  Copps  and  Adelstein  dissenting  and  issuing  a  joint  statement.
 1.  The  Commission  has  before  it  an  Application  for  Review  filed  by  Monterey  Licenses,  L.  L.  C.  (  Monterey)  on  June  25,  2001.  Monterey  seeks  review  of  the  May  24,  2001,  decision  by  the  Media  Bureau
 (  Bureau)  denying  Montereys  petition  to  deny  and  granting  an  application  to  assign  the  construction  permit  of  station  KDAM(  FM)  (at  the  time,  KCHY(  FM)),  Hope,  North  Dakota,  from  Michael  Radio  Group
 (  MRG)  to  Clear  Channel  Broadcasting  Licensees,  Inc.  (  Clear  Channel).  2  On  July  12,  2001,  Clear  Channel  filed  an  Opposition  to  the  Application  for  Review,  to  which  Monterey  filed  a  Reply  on  July  20,
 2001.  The  Commission  also  has  before  it  Montereys  January  15,  2002,  motion  to  stay  the  effectiveness  of  the  Staff  Decision  and  Clear  Channels  January  22,  2002,  Opposition  to  the  motion.  For  the  reasons  set  forth
 below,  we  deny  the  Application  for  Review  and  dismiss  the  Motion  for  Stay  as  moot.  3
 2.  Monterey  is  the  licensee  of  several  radio  stations  that  compete  with  Clear  Channels  stations  in  the  Fargo,  North  Dakota,  market.  4  Monterey  reiterates  the  arguments  it  made  to  the  staff,  as  follows:  (1)  in
 1  The  call  sign  of  the  subject  station  was  changed  from  KCHY(  FM)  to  KDAM(  FM)  effective  October  8,  2002.
 2  See  Letter  to  Paul  A.  Cicelski,  Esq.  and  Christopher  L.  Robbins,  Esq.  (MMB  May  24,  2001)  (  Staff  Decision).
 3  Monterey  moves  that  we  stay  the  effectiveness  of  the  Staff  Decision  to  preserve  the  status  quo  and  prevent  any
 irreparable  injury  resulting  from  Clear  Channels  acquisition  of  KDAM(  FM)  pending  final  action  on  the  Application  for  Review.  Given  our  action  here  denying  the  Application  for  Review,  we  need  not  reach  the  motion
 for  stay.  See  Rebecca  Radio  of  Marco,  5  FCC  Rcd  2913,  2914  n.  5  (1990).
 4  Monterey  is  the  licensee  of  stations  KQWB(  FM)  and  KVOX(  FM),  Moorhead,  Minnesota;  KLTA(  FM),
 Breckenridge,  Minnesota;  KPFX(  FM),  Fargo,  North  Dakota;  and  KQJD(  AM)  and  KQWB(  AM),  West  Fargo,  North
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 the  Fargo,  North  Dakota-  Moorhead,  Minnesota  metropolitan  area  as  defined  by  Arbitron  (the  Fargo  Metro),  Clear  Channel  controlled  six  of  the  markets  fourteen  stations,  including  station  KRVI(  FM),  Detroit
 Lakes,  Minnesota,  and  was  thus  already  at  its  statutory  ownership  limit;  5  (2)  an  alternative  prediction  methodology  to  plot  the  contour  for  KRVI(  FM)  is  justified  by  the  anomalous  terrain  in  the  area  and  results  in
 KRVI(  FM)  being  counted  against  Clear  Channels  ownership  limit;  (3)  Clear  Channel  already  controlled  53.  2%  of  the  advertising  revenue  in  the  Fargo  Metro,  and  thus  any  increase  in  Clear  Channels  market  share
 when  KDAM(  FM)  commenced  operations  would  be  problematic;  and  (4)  the  Commissions  definition  of  a  radio  market  does  not  comport  with  economic  reality  and  the  KDAM(  FM)  application  should  be  deferred
 until  the  Commission  has  completed  its  rule  making  on  defining  radio  markets.  6  In  its  Application  for  Review,  Monterey  requests  that  the  Commission  reverse  the  Bureaus  decision  and  deny  the  MRG/  Clear
 Channel  assignment  application  or  at  a  minimum  defer  action  on  the  application  until  the  Commission  resolves  [the  issues  raised  in  Market  Definition  NPRM].
 3.  The  staff  correctly  rejected  Montereys  contention  that  the  KDAM(  FM)  acquisition  violates  the  numerical  limits  contained  in  the  Commissions  local  radio  ownership  rule.  Under  the  ownership  rules
 then  in  effect,  both  the  definition  of  a  radio  market  and  the  number  of  stations  counted  as  being  in  that  market  were  based  on  signal  contours,  not  on  an  Arbitron-  based  or  other  geographic-  based  methodology.
 As  in  its  Petition  to  Deny,  Monterey  argues  that  the  transactions  compliance  with  the  ownership  limits  should  be  evaluated  in  the  context  of  the  Fargo  Arbitron  Metro,  where  only  14  commercial  stations  are
 listed  as  home.  In  a  14-  station  market,  Clear  Channel  may  only  own  up  to  five  stations,  with  up  to  three  in  the  same  service.  Montereys  reliance  on  the  Arbitron-  defined  Fargo  Metro  to  calculate  the
 number  of  stations  in  the  market  is  simply  misplaced,  however.  Although  the  Commission  adopted  in  mid-  2003  a  geographic-  based  methodology  for  stations  in  Arbitron  rated  markets,  7  it  did  not  do  so  until
 Dakota.  Clear  Channel  is  the  licensee  of  three  radio  stations  licensed  to  Fargo  (KFGO(  AM)/-  FM  and  WDAY-  FM)  as  well  as  three  stations  licensed  to  nearby  communities:  KVOX(  AM),  Moorhead,  Minnesota,  KULW(  FM),
 Kindred,  North  Dakota,  and  KRVI(  FM),  Detroit  Lakes,  Minnesota.
 5  See  47  C.  F.  R.    73.  3555(  a)  (promulgated  pursuant  to  Section  202(  b)(  1)  of  the  Telecommunications  Act  of  1996).
 6  When  Monterey  filed  its  Petition  to  Deny,  the  Commissions  rule  making  proceeding  focusing  on  radio  market
 definition  was  pending.  See  Definition  of  Radio  Markets,  MM  Docket  No.  00-  224,  15  FCC  Rcd  25077  (2000)  (  Market  Definition  NPRM).  That  proceeding  was  subsequently  incorporated  into  an  omnibus  rule  making
 addressing  various  broadcast  cross-  ownership  and  multiple  ownership  rules.  The  Commission  released  its  Order  in  that  omnibus  proceeding  on  July  2,  2003.  See  2002  Biennial  Regulatory  Review,  ("  Ownership  Report  and  Order"),
 18  FCC  Rcd  13620  (2003),  aff'd  in  part  and  remanded  in  part,  Prometheus  Radio  Project,  et  al.  v.  FCC,  373  F.  3d  372  (2004)  ("  Prometheus  Remand  Order"),  stay  modified  on  rehearing,  No.  03-  3388  (3d  Cir.  Sept.  3,  2004)
 ("  Prometheus  Rehearing  Order").  The  Notice  of  Proposed  Rule  Making  included  in  the  Ownership  Report  and  Order  sought  comment  on  developing  a  geographic-  based  methodology  to  evaluate  local  radio  ownership  in  markets
 not  rated  by  Arbitron,  and  that  proceeding  remains  pending.  On  September  3,  2003,  the  United  States  Court  of  Appeals  for  the  Third  Circuit,  which  is  hearing  the  consolidated  appeals  of  the  Ownership  Report  and  Order,
 granted  a  stay  of  the  effective  date  of  the  new  ownership  rules  adopted  in  that  Order,  stating  that  the  prior  ownership  rules  remain  in  effect  pending  resolution  of  those  proceedings.  Prometheus  Radio  Project,  et  al.  v.
 F.  C.  C.,  No.  03-  3388,  slip  op.  at  3  (3d  Cir.  Sept.  3,  2003)  (per  curiam).  In  the  Prometheus  Rehearing  Order,  however,  the  Court  of  Appeals  lifted  the  stay  for  the  local  radio  ownership  rule  revisions,  including  using  Arbitron
 Metro  markets  to  define  local  markets.
 7  See  Ownership  Report  and  Order,  supra,  18  FCC  Rcd  at  13725-  30    273-  86.
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 long  after  the  staff  had  approved  (on  May  24,  2001)  and  the  parties  had  consummated  (on  January  22,  2002)  the  sale  of  KDAM(  FM).  We  do  not  generally  apply  changes  in  ownership  rules  retroactively  so  as
 to  require  divestiture  of  existing  combinations,  as  suggested  by  Monterey,  and  we  did  not  do  so  when  we  revised  the  local  radio  rule.  8  Thus,  examining  the  subject  transaction  under  the  contour-  based
 methodology  set  forth  in  the  local  radio  ownership  rule  in  effect  at  the  time  of  the  staff  decision,  we  confirm  the  staffs  finding  that  the  KDAM(  FM)  acquisition  complied  with  that  rule.
 4.  At  the  same  time  that  Monterey  argues  for  use  of  the  Arbitron  Metro,  it  reiterates  that  the  Commission  should  apply  an  alternative  signal  contour  prediction  methodology  for  one  station  because
 the  terrain  at  issue  differs  widely  from  that  assumed  by  the  normal  prediction  methodology.  9  Monterey  acknowledges  that,  under  the  Commissions  definition  of  a  radio  market  in  effect  at  the  time  the  subject
 application  was  analyzed,  Clear  Channels  KRVI(  FM),  Detroit  Lakes,  Minnesota,  is  not  counted  as  one  of  the  stations  Clear  Channel  owns  in  the  same  market  as  the  subject  stations.  10  Use  of  the  alternative
 methodology,  Monterey  contends,  demonstrates  that  the  principal  community  contour  of  KRVI(  FM)  overlaps  that  of  KDAM(  FM)  and,  thus,  that  the  two  stations  are  in  the  same  market.  Consequently,
 Monterey  argues,  Clear  Channels  acquisition  of  KDAM(  FM)  will  exceed  both  the  total  number  of  stations  and  the  number  of  FM  stations  permitted  under  Section  73.3555(  a).
 5.  In  declining  to  consider  Montereys  use  of  an  alternative  prediction  methodology  to  demonstrate  that  KRVI(  FM)  should  be  considered  part  of  the  subject  market  here  --  a  methodology  that
 would  carry  Clear  Channel  over  the  number  of  FM  stations,  but  not  over  the  total  number  of  stations,  it  can  own  in  the  market  --  the  staff  stated  that  it  had  previously  rejected  the  use  of  supplemental
 engineering  showings  in  the  context  of  multiple  ownership  compliance  demonstrations,  whether  from  petitioners  11  or  from  applicants.  12  Consistent  with  that  precedent,  the  staff  was  not  persuaded  that  a
 departure  from  the  standard  prediction  methodology  was  warranted  for  KRVI(  FM).  Monterey  argues  that  the  staff  decisions  cited  by  the  Bureau,  such  as  Battle  Ground,  13  can  be  afforded  little  or  no  weight  in  light
 of  the  Commissions  acceptance  of  alternative  contour-  prediction  methodologies  to  demonstrate  that  television  stations  signals  do  not  overlap  for  purposes  of  applying  the  multiple  ownership  rules.
 8  See,  e.  g.,  id.  at  13807-  09    482-  86  (grandfathering  existing  station  combinations).  See  also  FCC  v.  National
 Citizens  Committee  for  Broadcasting,  436  U.  S.  775,  802-  815  (1978)  (upholding  Commission  decision  to  require  divestiture  of  newspaper/  broadcast  combinations  only  in  egregious  cases).
 9  Monterey  indicates  that  the  subject  terrain  is  quite  flat,  sloping  from  the  transmitter  site  to  the  Red  River  Valley
 in  which  Fargo  lies.
 10  Clear  Channels  multiple  ownership  study,  using  the  Commissions  prescribed  contour-  prediction  methodology,
 demonstrates  that  the  contour  for  KRVI(  FM)  does  not  overlap  that  of  any  other  station  proposed  to  be  commonly  owned  by  Clear  Channel  as  a  result  of  this  transaction.  Clear  Channel  therefore  did  not  include  KRVI(  FM)  in  the
 defined  radio  market  in  this  case.  Monterey  correctly  notes  that  the  contours  of  KDAM(  FM)  and  KRVI(  FM),  computed  according  to  the  standard  prediction  methodology  set  forth  in  47  C.  F.  R.    73.  313,  are  separated  by  0.  2
 kilometers.
 11  See  WIIZ(  FM),  Battle  Ground,  Indiana,  10  FCC  Rcd  3159  (MMB  1995)  (  Battle  Ground).
 12  See  WZNY(  FM),  Augusta,  Georgia,  13  FCC  Rcd  9467  (MMB  1998)  (  Augusta).
 13  See  supra  note  11.
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 Monterey  cites  three  Commission  decisions  in  cases  involving  television  stations  --  Heritage  Media  Services,  Inc.,  John  H.  Phipps,  Inc.,  and  Southern  Oregon  Broadcasting  Co.  14  --  in  support  of  its  position.
 6.  It  is  our  current  and  express  policy  not  to  apply  an  alternative  prediction  methodology  in  the  context  of  evaluating  compliance  with  the  local  radio  ownership  rule.  15  In  the  Technical  Streamlining
 NPRM,  discussing  specifically  the  point-  to-  point  (  PTP)  alternative  prediction  methodology,  we  explained  our  position  as  follows:
 In  instances  involving  major  radio  markets,  multiple  ownership  studies  often  involve  dozens  of  stations.  Selective  application  of  the  PTP  method  to  some,  but  not  all,  stations  in  a  relevant
 market  would  invite  disputes  where  contradictory  results  would  occur.  Conversely,  in  light  of  the  sometimes  radical  differences  between  PTP  calculations  and  standard  predicted  contours,
 utilizing  the  PTP  method  for  all  stations  could  affect  these  ownership  studies  in  ways  not  anticipated  when  the  current  multiple  ownership  rules  were  adopted.  We  believe  that,  in  most
 instances,  the  use  of  the  PTP  methodology  could  significantly  alter  the  definition  of  stations  included  in  a  particular  market  and  use  of  this  methodology  in  this  context  would  serve  no  useful
 function  in  administering  our  ownership  policies.  16
 We  are  unpersuaded  that,  because  we  accepted  the  use  of  an  alternative  prediction  methodology  in  the  context  of  the  television  duopoly  rules  in  Heritage,  Phipps,  and  Southern  Oregon,  17  we  must  or  should  do
 so  here.  In  each  of  the  cases  cited  by  Monterey,  the  Commission  accepted  and  analyzed  an  alternative  contour  prediction  showing  to  determine  whether  or  not  there  was  overlap  between  two  television
 stations.  To  determine  how  many  stations  are  in  a  radio  market  using  alternative  contours,  we  would  need  to  study  those  contours  for  dozens  of  stations.  18  As  we  stated  in  the  Technical  Streamlining  NPRM,
 this  could  affect  radio  ownership  studies  in  ways  not  anticipated  when  the  current  ownership  rules  were  adopted.  19  We  therefore  agree  with  the  staffs  conclusion  that  it  was  not  appropriate  to  accept  Montereys
 14  Heritage  Media  Services,  Inc.,  13  FCC  Rcd  5644  (1998);  John  H.  Phipps,  Inc.,  11  FCC  Rcd  13053  (1996);
 Southern  Oregon  Broadcasting  Co.,  9  F.  C.  C.  2d  241  (1967).
 15  See  1998  Biennial  Regulatory  Review    Streamlining  of  Radio  Technical  Rules  in  Parts  73  and  74  of  the
 Commissions  Rules,  Notice  of  Proposed  Rule  Making  and  Order,  13  FCC  Rcd  14849,  14865  (1998)  (  Technical  Streamlining  NPRM)  (seeking  comment  on  a  supplemental  point-  to-  point  (  PTP)  prediction  model  designed  to
 provide  a  more  accurate  prediction  of  FM  radio  interfering  signal  contours  and  stating  our  proposal  not  to  allow  use  of  the  PTP  methodology  in  multiple  ownership  showings).
 16  Id.  In  a  subsequent  order,  we  deferred  adoption  of  our  proposed  PTP  methodology  on  the  basis  of  comments
 raising  issues  regarding  the  accuracy  and  reliability  of  the  proposed  signal  propagation  prediction  model.  See  1998  Biennial  Regulatory  Review    Streamlining  of  Radio  Technical  Rules  in  Parts  73  and  74  of  the  Commissions  Rules,
 Second  Report  and  Order,  15  FCC  Rcd  21649,  21652-  53    7-  9  (2000).
 17  See  supra  note  14.
 18  Monterey  proposes  the  use  of  an  alternative  contour  analysis  only  with  respect  to  KRVI(  FM).  That  is  exactly  the
 kind  of  selective  use  which  the  staff  appropriately  rejected  in  Augusta,  supra  note  13.
 19  Technical  Streamlining  NPRM,  13  FCC  Rcd  at  14865.
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 supplemental  engineering  study  demonstrating  overlap  between  KDAM(  FM)  and  KRVI(  FM)  based  on  an  alternative  contour-  prediction  model.  20
 7.  We  also  disagree  with  Montereys  claim  that  the  transaction  raised  antitrust  concerns  warranting  denial  or  deferral  of  action  on  the  application.  The  staffs  independent  analysis  at  the  time  21
 indicated  that  Clear  Channel  already  controlled  stations  in  the  Fargo  Metro  garnering  53.6%  of  the  advertising  revenue  share,  and  that  the  combined  revenue  share  of  Clear  Channel  and  Monterey,  the
 second  largest  radio  owner  in  the  market,  was  92.6%.  The  staff  further  noted  that  the  post-  transaction  revenue  shares  would  remain  the  same:  as  an  unbuilt  station,  KDAM(  FM)  had  no  reported  revenue  share.
 Rather,  KDAM(  FM)  constituted  new  capacity  in  the  Fargo  Metro  that  would  provide  new  choices  for  listeners  and  advertisers.
 8.  Since  grant  of  the  subject  assignment  application,  Clear  Channels  advertising  revenue  share  has  fallen  to  50.1%,  notwithstanding  the  addition  of  KDAM(  FM)  to  its  station  group  in  the  Fargo  Metro,
 and  the  combined  revenue  share  of  Clear  Channel  and  Monterey  has  decreased  to  90.4%.  22  Although  Clear  Channel  maintains  a  significant  market  position  in  the  Metro  today,  it  appears,  according  to  the  BIA
 data  base,  that  Forum  Communications,  Tom  Ingstad,  Triad  Broadcasting,  and  Vision  Media  offer  sufficient  alternative  sources  so  that  advertisers  can  buy  around  a  number  of  the  formats  offered  by
 Clear  Channel.  These  opportunities  should  constrain  the  ability  of  Clear  Channel  to  exercise  market  power  against  advertisers  in  the  Fargo  Metro.  Additionally,  the  rivalry  offered  by  the  non-  Clear  Channel
 stations  should  provide  an  incentive  for  Clear  Channel  to  compete  by  pricing  its  advertising  efficiently.  Such  rivalry  may  also  result  in  Clear  Channels  introduction  of  innovative  advertising  services  and
 packages  that  will  improve  the  overall  quality  of  radio  advertising  services  available  in  the  Fargo  Metro.  In  view  of  these  conclusions,  we  find  that  Monterey  has  not  raised  a  substantial  and  material  question  of
 fact  warranting  further  inquiry  on  this  issue.
 9.  Montereys  final  claim  is  that  staff  action  on  the  application  was  contrary  to  our  pronouncements  on  deferral  in  the  Market  Definition  NPRM.  In  support,  Monterey  cites,  inter  alia,  to  the
 following  excerpt:
 As  a  general  matter,  we  will  continue  to  process  applications  under  the  existing  standards,  unless  and  until  they  are  changed  in  this  proceeding.  In  cases  raising  concerns  about  how  we  count  the
 number  of  stations  a  party  owns  in  a  market,  however,  we  will  defer  decision  pending  resolution  of  that  issue  in  this  proceeding.  As  we  concluded  in  the  1998  Biennial  Review  Report,  the
 20  In  refusing  to  accept  Montereys  supplemental  showing,  we  do  not  intend  to  give  premature  effect  to  the  proposal
 in  our  Technical  Streamlining  NPRM  but  merely  to  emphasize  that  rule  makings  recognition  of  existing  practice.  See  supra  note  15  and  accompanying  text.
 21  The  Commission  had  not  yet  adopted  the  Order  in  which  it  announced  an  Interim  Policy  establishing  a  specific
 framework  for  evaluating  the  competition  aspects  of  proposed  radio  transactions.  See  Rules  and  Policies  Concerning  Multiple  Ownership  of  Radio  Broadcast  Stations  in  Local  Markets,  16  FCC  Rcd  19861,  19894-  97  
 84-  89  (2001).
 22  A  number  of  factors  may  explain  Clear  Channel's  reduced  revenue  share,  such  as,  for  example,  Tom  Ingstad's  new
 station  KDJZ-  FM,  which  began  its  operations  in  the  Fargo  Metro  in  2001,  and  the  improved  performance  of  Forum  Communications'  WDAY(  AM),  which  rose  to  become  the  fourth-  highest  rated  station  in  the  latest  ratings  period.
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 shifting  market  definition  in  our  counting  methodology  appears  illogical  and  contrary  to  Congress  intent.  23
 Monterey  argues  that  the  cited  language  indicates  that  we  will  defer  action  on  any  case  in  which,  for  example,  the  Commissions  computation  of  the  number  of  stations  in  a  market  differs  from  the  count  listed  by
 Arbitron  or  BIA.  24  This  is  incorrect.  As  explained  in  the  Staff  Decision,  25  pending  the  conclusion  of  the  radio  market  rule  making  proceeding,  the  Commission  will  defer  acting  on  applications  if  compliance
 with  the  local  radio  ownership  rule  depends  on  the  inclusion  of  certain  attributable  station  interests  of  the  applicant  in  the  total  count  of  stations  in  the  market.  26  There  is  no  such  issue  in  this  case.
 10.  Accordingly,  the  June  25,  2001,  Application  for  Review  filed  by  Monterey  Licenses,  L.  L.  C.  IS  DENIED,  and  its  January  15,  2002,  Motion  for  Stay  IS  DISMISSED  AS  MOOT.
 FEDERAL  COMMUNICATIONS  COMMISSION
 Marlene  H.  Dortch  Secretary
 23  Market  Definition  NPRM,  15  FCC  Rcd  at  25082    14.
 24  Application  for  Review  at  8.
 25  See  Staff  Decision  at  6.
 26  E.  g.,  Pine  Bluff  Radio,  Inc.,  14  FCC  Rcd  6594  (1999).
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 DISSENTING  STATEMENT  OF  COMMISSIONERS  MICHAEL  J.  COPPS  AND  JONATHAN  S.  ADELSTEIN
 Re:  Michael  Radio  Group,  Assignor  and  Clear  Channel  Broadcasting  Licenses,  Inc.,  Assignee  For  Assignment  of  Construction  Permit  of  Station  KDAM(  FM),  Hope,  North  Dakota
 In  this  case,  the  majority  approves  Clear  Channels  acquisition  of  a  radio  station  in  a  market  in  which  Clear  Channel  already  controls  over  50  percent  of  the  market  and  Clear  Channel  and  the  next
 largest  owner  together  control  over  90  percent.  Given  this  extreme  level  of  market  concentration,  we  cannot  support  grant  of  this  transfer  absent  additional  information  on  the  public  interest  benefits  of  the
 transaction.  Yet,  here,  the  majority  has  not  even  considered  the  public  interest  benefits  or  harms.  We  are  troubled  by  the  trend  toward  greater  and  greater  consolidation  of  the  media,  particularly  in  smaller  radio
 markets,  and  this  Commissions  acceptance  of  such  levels  of  concentration  with  hardly  any  analysis.  For  a  robust  marketplace  of  ideas  to  survive,  every  community  deserves  to  have  a  diversity  of  sources  of
 information  available  to  its  members  -  not  just  those  who  live  in  the  largest  cities.  We  find  that  the  amount  of  concentration  at  issue  here  is  potentially  very  harmful  to  competition,  to  the  listening  public
 and  to  America's  deeply  held  values  of  localism  and  diversity.
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