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fair way to do it
The manual does not address this.  It only addresses the situation where a list has run out or no list has been made -- in which case it goes by PB value.  All of the rookie drafts and the RT monthly drafts have been done this way over the past two seasons as far as I remember.
FWIW -- I think that, especially for rookies, having Mike submit a commissioners list for unmanaged teams is the fairest way to do it.