The Commission would rather that you identify yourself any time you wish to comment on the record in one of its proceedings. However, it concedes that television companies exploring whether or not to participate in incentive auctions may have reason to keep their identity a secret. And it explains how to do that.
“Generally,” explained the FCC, “when a party identifies itself it improves the ability of both the Commission and the public to evaluate the position the party takes in the proceeding, thus benefiting the rulemaking process. Our existing rules, however, allow the filing of anonymous rulemaking comments. Section 1.419(e) requires that a party filing in electronic format and not represented by an attorney provide its name and mailing address.”
Basically, all a party needs is legal representation. The FCC wrote, “We want to encourage those broadcasters interested in auction participation to raise issues of specific concern to them regarding the incentive auction process so that we may develop a robust record to assist us in devising auction-related rules. At the same time, we recognize that broadcasters may have legitimate reasons for not wanting to disclose their potential interest in reverse auction participation. Thus, we remind broadcasters that they may file anonymously by paper, or electronically so long as they have an attorney of record. We request, however, that any broadcaster filing anonymously provide sufficient basic information to enable to Commission and the public to understand and evaluate the positions it takes in its comments. Such information may include, for example, the market tier in which the station operates and whether it is network-affiliated or independent. Finally, we note that broadcasters wishing to file anonymous comments electronically without an attorney of record must seek a waiver of section 1.419(e).”