To whom it may concern:

Shortly after Senator Barbara Boxer brought to the FCC's attention the existence of several studies suggesting that local ownership is good for the dissemination of local news, FCC Chair Kevin Martin issued a public statement regarding what Boxer called the "deep sixed" [0] localism and radio industry papers.

"Thank you for your letters, first following up on the June 2004 draft of an FCC staff working paper on localism, and then making me aware of the draft 2003 'Review of the Radio Industry'," Martin wrote.

"As with the previous study, I was not Chairman at the time this report was drafted. I had not seen -- nor was I aware of -- this draft report before you brought it to my attention. No one on my staff had seen this report nor were they aware of it."

Martin then assured Boxer that he would make the 2003 "Review of the Radio Industry" publicly available on the FCC's Web site, which he did. Go to the FCC Headlines 2006 [1] page and search for: Draft 2003 "Review of the Radio Industry" or for "9/19/06" and you will find the pdf file [2] for the report.

But if you read the Report carefully, you will discover that it may not have been completed in 2003. It may have been compiled in 2004, or perhaps even 2005.

I raise this possibility because of the page after numbered page 29 in the report--the 35th page in the pdf file. The top of the page reads "Non-Public / For Internal FCC Use Only." The title is "BROADCAST / CABLE ATTRIBUTION RULES TIMELINE."

And to the right, the page is dated 9/21/04.

How could a "2003 report" have a timeline dated late September of the following year?

In fairness, the 9/21/04 timeline may have been subsequently appended to the 2003 Report. But if the report was actually produced in 2003, it was produced very late in the year. A footnote to numbered page seven cites a study dated June 30, 2003. And a chart on numbered page 29 cites information about fiscal quarter September 2003, data that may not have been compiled and known until the following quarter in 2004, or even later.

These dates raise the possibility that the "2003 report" was completed in 2004, or very late in 2004, or perhaps even in 2005.

I think that an accurate dating of the document is a legitimate concern. President Bush designated Kevin Martin Chair of the FCC on March 18, 2005.

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