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Re: Application of Great Empire Broadcasting, Inc. and Journal Broadcast Corp. for Transfer of Control of Omaha Great Empire Broadcasting, Inc., licensee of WOW(AM) and WOW(FM), Omaha, Nebraska; File Nos. BTC-980831GH and BTCH-980831GI

I write separately to briefly respond to my colleagues' concerns with the radio market definition used in this case. As I indicated in my separate statement in our recent decision in Pine Bluff Radio, Inc.,1 I recognize that the existing market definition used by the Commission in cases such as this can sometimes lead to anomalous results. But I don't believe that the result in this case is such an anomaly and I assume my colleagues' concurrence in the result reached here reflects their agreement with this view. As to the means of addressing the market definition question, I continue to believe, for the reasons I noted in my separate statement in Pine Bluff Radio, Inc., that this matter is best addressed in a well-considered rulemaking proceeding, not in the context of an adjudicatory determination such as this.

1. Applications of Pine Bluff Radio, Inc. and Seark Radio, Inc., FCC No. 99-67 (released April 15, 1999).