A group of broadcasters which plan to sell some spectrum...

initial bids in the reverse auction must “exceed the expectations of potential sellers.” Secondly, the commission should avoid adopting unnecessary conditions that might keep bidders on either side of the auction away. It said a descending clock auction with intra-round bidding would be the best way to let stations realize a market value for the spectrum they contribute. Initial bids in the reverse auction might exceed the expected forward auction value in the largest markets, the coalition said. But by encouraging stations in the largest markets to participate, the commission has the best chance of creating a nationwide 120 MHz spectrum band, it said. “The only way the Commission can err is by selecting initial prices that are too low,” it said. The coalition said stations should have the flexibility to convert their bids to different “exit options” each round. And it argued against a proposal in the FCC’s notice of proposed rulemaking on the auction in which a station could bid to accept additional interference on its spectrum. “This option would counteract the agency’s efforts to simplify the auction process,” it said. Furthermore, the commission should act quickly, it said. “Neither the broadcast industry nor the wireless industry will benefit from the uncertainty resulting from an unnecessarily drawn-out auction process,” it said.