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 DISSENTING  STATEMENT  OF  COMMISSIONER  MICHAEL  J.  COPPS 
 Re:  Applications  of  Golden  Triangle  Radio,  Inc.  and  Cumulus  Licensing  Corp.  For  Consent  to  the  Assignment  of  the  Licenses  of  WKOR-  FM,  Columbus,  MS,  WMXU(  FM)  and  WSSO(  AM) 
 Starkville,  MS,  and  Application  of  Charisma  Broadcasting  Co.  and  Cumulus  Licensing  Corp.  For  Consent  to  the  Assignment  of  the  License  of  WKOR(  AM)  Starkville,  MS,  and  Application  of  Bravo 
 Communications,  Inc.  and  Cumulus  Licensing  Corp.  For  Consent  to  the  Assignment  of  the  License  of  WSMS(  FM),  Artesia,  MS,  and  Applications  of  Radio  Columbus,  Inc.  and  Cumulus 
 Licensing  Corp.  For  Consent  to  the  Assignment  of  the  Licenses  of  WJWF(  AM)  and  WMBC(  FM),  Columbus,  MS; 


 This  Order  denies  a  Petition  for  Reconsideration  of  an  Order  we  released  in  2002.  I  dissent  to  this  Order  for  the  same  reasons  I  dissented  to  the  underlying  Order. 
 This  transaction,  along  with  four  others  decided  at  the  same  time,  also  highlights  what  had  been  an  important  part  of  the  Commission’s  merger  review  process.  When  a  merger  or  acquisition  provided 
 one  corporation  with  50  percent  or  two  corporations  with  70  percent  of  the  revenue  in  a  market,  the  Commission  conducted  an  analysis  of  the  impact  in  the  specific  market.  After  conducting  this  market-specific 
 analysis,  the  Commission  unanimously  sent  one  of  these  five  transactions  to  a  hearing.  The  Commission,  however,  has  now  eliminated  this  additional  analysis  even  for  mergers  that  result  in  high 
 levels  of  concentration.  It  is  particularly  ironic  that  the  Commission  took  this  step  at  a  time  when  the  courts  have  faulted  the  Commission  for  not  adequately  taking  into  account  the  structure  of  particular 
 markets. 
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