Federal Communications Commission FCC 08-226
JOINT CONCURRING STATEMENT OF
COMMISSIONER MICHAEL J. COPPS 
AND 
COMMISSIONER JONATHAN S. ADELSTEIN
Re:  Applications of Eagle Broadcasting Company, Inc. and Eagle II Broadcasting 
Company, Inc., Assignors, and Saga Communications of New England, LLC, 
Assignee, for Assignment of Licenses of WHCU(AM), WYXL(FM), WNYY(AM), 
and WQNY(FM), Ithaca, New York.
The petitioners in this case allege that these license transfers are not in the public 
interest because they will perpetuate excessive concentration in the Ithaca radio market.  
The majority acknowledges that we must give a “hard look” to such allegations—even if 
the transfers comply with our general local radio ownership caps.  
Unfortunately, the majority fails to apply its own “hard look” standard, giving 
short shrift to many of petitioner’s allegations.  For instance, with respect to the 
allegation that a single entity will control 64 percent of advertising revenues in the Ithaca 
market, the majority simply asserts that the petitioners failed to justify a departure from 
our general rule and—most troubling—relies on the FCC’s discredited media ownership 
decision that was overturned and remanded by the courts for the proposition that 
advertising revenues are of “decreasing relevance” as a barometer of competition.
In the end, we are left with a record that makes it difficult to assess the true 
impact of this transaction on competition, localism, and diversity in the Ithaca market.  
Based on the limited information before us, we reluctantly concur in the majority’s 
decision.