WASHINGTON – Ronald Bruno will sell his 11 Class A TV station licenses if conditions are right, he told the Federal Communications Commission in a filing on its incentive auction Notice of Proposed Rulemaking.

“While Bruno Goodworth Network, Inc. is willing to consider relinquishing all 11 of its Class A licenses in the reverse spectrum auction, it is willing to do so only if it is treated fairly and equitably, which includes getting a fair and reasonable return for its two decades of hard work,” he said.

Bruno is the president of Pittsburgh-based Bruno Goodworth Network, which owns WBGN-DC, an independent station in that market that runs standard-definition, syndicated programming on the primary channel, 59.1, as well as live mass from St. Mary of Mercy Catholic Church from downtown Pittsburgh. The station also transmits Home Shopping Network, RTV and Live Well on three digital subchannels. WBGN is carried on 12 separate broadcast towers throughout Pittsburgh, according to the station website. The same programming is carried on 10 more Bruno Goodworth stations in Pennsylvania, West Virginia and Ohio.

“Bruno Goodworth Network, Inc. should receive the same compensation for each 6 MHz block in contributes as any other licensee relinquishing spectrum,” Bruno said in response to comments suggesting that station spectrum value be scored on the basis of Nielsen ratings. “Any such basis for evaluating the acceptability of reverse auction bids lacks rationality.”

The commission is proposing to hold the incentive auction in two parts. The first, a reverse auction, would allow broadcasters to determine what their licenses would be worth to wireless providers. It was also give the FCC an idea how much spectrum could be made available for auction in each market. The second, a forward auction, is where TV spectrum actually becomes available to bidders. A repacking of TV stations into whatever TV spectrum remains will follow.

The NPRM also would limit participation to stations that obtained licenses as of Feb. 22, 2012. Bruno said this penalizes Class A stations that had not built out digital facilities by that time. LPTVs were not under the same June, 2009, digital-transition deadline as full-power TV stations.

“We have built a substantial portion of our digital stations since Feb. 22, 2012,” Bruno said. “In fact, three of our Class A stations are still operating in analog mode, but will have finished converting to digital before commencement of the reverse auction process. All of our Class A stations now have digital construction permits, but over half of those… were not received until 2012 or even 2013. As a result, we could not possibly have constructed its (sic) digital facilities by Feb. 22, 2012.”

Bruno suggests instead that the FCC use the reverse-auction commencement date to determine eligibility. He further reasons that doing so will motivate more Class As to build out digital facilities in order to participate, resulting in greater coverage by those unable to do so.

He also said the commission should adopt a “package” bidding procedure for operations with multiple stations in a single market. Such groups, he said, would not be willing to sell just a few of their stations in a particular market.