Comments filed with the FCC in response to a Wireless Telecommunications Bureau public notice seeking input on procedures to govern the upcoming advanced wireless service (AWS)-3 auction offered a variety of refinements to promote efficiency and certainty among auction participants. While most entities expressed support for the FCC’s proposals, Verizon Wireless and several other parties called on the FCC to waive application of the “former defaulter” rule to the AWS-3 auction. Under the former defaulter rule, applicants that have been in default or delinquent on any federal debt are required to make a substantial, additional upfront payment before participating in an FCC auction. That rule applies without regard to the size of the debt, how long ago the debt was incurred and whether the debt in question has since been repaid. Voicing support for “requests from DirecTV, EchoStar, the Competitive Carriers Association, the Consumer Electronics Association, CTIA and NTCA that the Commission waive application of the former defaulter rule,” Verizon advised the FCC that, “while there may have been a valid premise for this rule at one time, the rule as adopted is overly broad.” Similarly, the Competitive Carriers Association (CCA) reiterated its request “to waive the enhanced upfront payment requirement for certain bidders that were formerly in default on debt owed to federal agencies,” arguing, “in circumstances where the debts at issue were incurred and resolved more than three years prior to the start of Auction97 and/or  were  for  immaterial  amounts,  a  significantly  higher  upfront  payment  would  needlessly  constrain  auction  participation.” While recommending a waiver of the defaulter rule, DISH Network further urged the FCC to “later open a rulemaking to overhaul the rule for future auctions.” DISH also took issue with proposals to establish combined bidding eligibility, activity waivers and auction stopping rules for unpaired AWS-3 channels at 1695-1710 MHz and for paired spectrum at 1755-1780/2155-2180 MHz on grounds that that the paired/unpaired licenses “appear not to be interchangeable in terms of their characteristics and likely uses, and it is thus unlikely that the two bands offer licenses that could be used as close substitutes.” As Verizon suggested reductions in the proposed minimum acceptable bid percentage and minimum opening bid and eligibility amounts “to encourage participation both at the beginning of the auction and throughout the auction,” CCA asked the FCC to reconsider plans to implement an anonymous bidding format, asserting that, “while anonymous bidding can help to prevent retaliatory bidding, it unnecessarily increases both complexity and uncertainty in the auction, putting small and midsize carriers at a disadvantage.”