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NOTICE OF EX PARTE MEETING WITH FEDERAL COMMUNICATIONS COMMISSION...

Notice of Ex Parte Meeting with Federal Communications Commission Chairman Tom Wheeler, Chair of the Incentive Auction Task Force Gary Epstein, and Vice Chair of the Incentive Auction Task Force Howard Symons

June 24, 2015

Marlene H. Dortch
Secretary Federal Communications Commission
Office of the Secretary
445 12th Street, SW
Washington, DC 20554

Re:   In the Matter of Expanding the Economic and Innovation Opportunities of Spectrum  Through Incentive Auctions (Docket No. 12-268); Competitive Bidding Procedures for Broadcast Incentive Auction 1000, Including Auctions 1001 and 1002 (Docket No. 14-252) 

Dear Ms. Dortch: 

This letter is to notify you that on June 22, 2015, Lonna Thompson, Executive Vice President, Chief Operating Officer and General Counsel, of the Association of Public Television Stations; Cindy Campbell, Vice President, Operations, of the Corporation for Public Broadcasting; and Thomas Rosen, Senior Counsel, of the Public Broadcasting Service (collectively, “PTV”) met with Federal Communications Commission Chairman Tom Wheeler, Chair of the Incentive Auction Task Force Gary Epstein, and Vice Chair of the Incentive Auction Task Force Howard Symons, as well as other representatives of the broadcast industry and members of the Commission staff.  Chairman Wheeler requested the meeting with representatives of the commercial and noncommercial broadcast sectors in order to discuss the upcoming Incentive Auction Procedures Public Notice. 

PTV recommended that the Commission reduce or eliminate the proposed discounts to opening bids for moving to the VHF band in the broadcast spectrum incentive auction.  PTV noted that a fixed percentage discount to the opening bid price for moving to the VHF band is inconsistent with the purpose of the auction, which is to use market mechanisms to determine the value that a broadcaster is willing to accept to relinquish its current channel.  PTV recommended that the Commission provide opening VHF bids for all licensees that are comparable to full relinquishment, with downward pressure on the price resulting from the actual supply of VHF channels in a given market and the bidder demand for those channels.  This approach is the most likely to ensure a robustly successful incentive auction because it will attract the maximum number of stations willing to consider a move to the VHF band, which in turn maximizes competition in the reverse auction and ensures final prices will reflect the competitive market value of the winning station’s move.

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