The Expanding Opportunities for Broadcasters Coalition says it has given the FCC plenty of hard data supporting EOBC's proposed changes to the incentive auction framework.
Comments were due March 13 and EOBC had 10 megabytes worth of data—"not just rhetoric," EOBC executive director Preston Padden said–showing that its suggested auction pricing model, which it has dubbed Round Zero Reserve (RZR), cleared more spectrum and caused less impairment than the FCC's proposed Dynamic Reserve Pricing (DRP).
“The FCC asked for fact-based data-driven Comments and that is exactly what our Coalition has submitted," said Padden in submitting the comments. "To generate real data - not just rhetoric - we conducted tens of thousands of sophisticated auction simulations. Attached to our Reply Comments is an updated 61 page Expert Report by Dr. Peter Cramton and a totally new 49 page Technical Appendix that details the methodology of our simulations."
EOBC also wants the FCC to revise its bid starting price formula—which will up those prices by billions of dollars, and says that will produce an auction that is "more robust, is likely to clear more spectrum and is more faithful to the market value for spectrum revealed by the AWS-3 auction and to the FCC’s promise to pay Stations based on their impact on clearing spectrum."
Padden said nobody else has come close to backing up its case with the kind of data-driven arguments EOBC was making, which includes for the FCC to adopt the RZR approach, up the starting prices, give broadcasters more information, clear as much spectrum as possible, and go slower on the price drops in the reserve auction—EOBC wants it to go down in 1% decrements rather than the proposed 3% to 10%.
EOBC represents TV stations interested in giving up spectrum for auction at the right price. EOBC members do not have to identify themselves, but separately, NAB members Tribune, Ion, Fox and Univision have all signaled to the FCC they would be willing to give up spectrum at the right price.
Stations do not have to go out of business to participate. They can give up spectrum and share a channel, or get paid to move from a UHF to VHF channel assignment, or from a high V to a low V, though they will not get as much as if they gave up spectrum.
The FCC is still targeting a first quarter 2016 auction.