The FCC should start the incentive spectrum auction process by...

needs volunteers, and how many of them, to produce a workable and efficient nationwide plan,” it said (http://bit.ly/13TKJ7I). That would let the FCC project what it can expect to raise in auction proceeds, the NAB said. Finally, it can direct its resources to providing incentives to stations in markets where it “truly requires volunteers,” it said. The trade association argued against adopting a variable or split band plan and urged the FCC not to use the repacking as a “pretext for a straight, government-directed reallocation,” of spectrum. In other replies that were posted to the FCC’s website before our deadline Tuesday other broadcasters addressed their concerns with ideas raised in the first round of comments. An anonymous broadcaster in “one of the largest -- and for the purposes of the incentive auction, most important -- markets” and represented by former FCC Chairman Richard Wiley urged the FCC to allow stations who choose to share channels to change their city of license while staying within a designated market area (DMA). Initial comments showed that the FCC’s tentative proposal to require sharing stations to meet existing community of license service obligations would prevent stations from entering into such arrangements, it said (http://bit.ly/ZxD3kl). “Due to the location of stations’ transmission facilities and their communities of license in the DMA, [the] Broadcaster does not appear to have a viable partner” whose facilities it could operate from, or who could operate from its facilities, it said. That would force “otherwise willing stations in the nation’s most important markets ... to sit on the sidelines rather than participate in the auction.” The operator of several affiliates of the ABC, CBS and NBC networks focused its comments on protecting stations that do not participate in the auction (http://bit.ly/YqdEYV). It also urged the agency to coordinate interference issues with Canada and Mexico. “The commission should take the time to analyze, and prepare appropriately flexible rules in response to the international coordination ... rather than straining to get underway quickly,” they said. An owner of Class A stations urged the FCC to set a future date, such as the commencement of the reverse auction, by which stations’ repacking protections would be calculated (http://bit.ly/ZxDtr3). Failure to do that would violate the Fifth Amendment, Venture Technologies Group said. “Arbitrarily cutting off repacking protection rights as for Feb. 22, 2012 would interfere with stations’ reasonable investment-backed expectations and amount to an impermissible regulatory taking,” it said. Spectrum Evolution, a Low-Power TV (LPTV) station operator, said the auction would lead to a “disastrous fate” for the LPTV industry unless the FCC gives it more attention. “What small business or new entrants would be foolish enough to invest in spectrum technology in the future when their fate would be governed by an agency that seems willing to sweep them aside, take resources they have worked so hard to develop and sell those resources to the wealthiest available buyer without a nod or nickel to those from whom the resources were taken” it said (http://bit.ly/ZxEkrC).