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                    SEPARATE STATEMENT OF 
                       KEVIN J. MARTIN
            APPROVING IN PART, CONCURRING IN PART

Re:  Entercom Kansas City License, LLC, Licensee of Station 
KQRC(FM), Leavenworth, KS, and Entercom Wichita License, 
LLC, Licensee of Station KFH(AM), Wichita, KS, Notice of 
Apparent Liability for Forfeiture (September 22, 2004)

     Consistent with my past statements, I believe we should 
be fining broadcasters on a ``per utterance'' basis.1  In 
this instance, we could have found several violations within 
the broadcasts at issue and therefore could have assessed a 
larger fine.

_________________________

1 See, e.g., Separate Statement of Commissioner Martin, 
Infinity Broadcasting Operations, Inc., Licensee of Station 
WKRK-FM, Detroit, Michigan, Notice of Apparent Liability, 18 
FCC Rcd. 6915, 6939 (2003) (urging the Commission to fine 
violators ``per utterance'').