Discussion of the Novel Auction Rules Should Not Be Limited to a Few Details Comments on DA 00-2404, “COMMENT SOUGHT ON MODIFYING THE CALCULATION FOR DETERMINING MINIMUM ACCEPTED BIDS AND CHANGING THE PROVISIONS CONCERNING LAST AND BEST BIDS”

Public Notice DA 00-2404 seeking comments for possible improvements of the novel auction rules that the Commission plans to use for Auction No.31 is a step in the right direction. However, the Commission should open a discussion on the auction design proposed in the Public Notice DA 00-1486 as a whole. Limiting the scope of the discussion to a few details only, makes the process of improving the auction design, as well as the details in question, difficult if not impossible to conduct in a meaningful and productive way. In our August 1, 2000, Ex Parte communication with the Commission, we explained why a serious consideration of the auction rules proposed in the Public Notice DA 00-1486 is necessary. We include this letter in the addendum. We think that the modifications for which comments are sought are of limited importance and are not sufficient to impact the overall quality of the auction. This holds particularly for the proposed modification of the “last and best” bids option. As for the proposed modification of the calculation for determining minimum accepted bids, we see