Tag: bidding rules

Same Old, Same Old: How T-Mobile and the Rural Telecommunications Group Propose to Wreck the AWS-3 Auction.

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M2Z Networks recently filed a study I prepared for them in the AWS-3 service rules proceeding (07-195) before the FCC.

In this study I identified how a coordinated effort between T-Mobile and the Rural Telecommunications Group threatened to wreck the AWS-3 auction by writing rules excluding technology proposed by key potential new entrants, including M2Z Networks, and adopting disastrous combinatorial bidding rules like those which provided a nearly half-billion dollar windfall for Verizon in the 700 MHz Band auction.

In brief, T-Mobile has proposed a “bandwidth maximization plan,” first mooted in this filing and elaborated here. The T-Mobile plan would split the J Block in half, giving 5 MHz for uplink and joining the other 5 MHz of J Block with 20 MHz of AWS-3 spectrum for downlink. This would force abandonment of the Time Division Duplex (TDD) technology envisioned by the FNPRM in favor of Frequency Division Duplex (FDD) technology favored by T-Mobile.

That might seem innocuous enough at first glance, but it eliminates consideration of a technology which is both more efficient and more robust than T-Mobile’s FDD alternative, and it is never a good idea to throttle new technologies at the bidding of vested incumbents. However, it is more pernicious still in that it aims at excluding the TDD technology on which Sprint, Intel, Arraycom, and M2Z proposed to build a nationwide network, effectively erecting entry barriers to major competitors to T-Mobile.

The irony is that T-Mobile proposes to kill TDD technology in AWS-3 on the pretext of preventing interference between AWS-3 and AWS-1 spectrum (T-Mobile was a major acquirer of AWS-1 spectrum). However, the FCC’s Office of Engineering and Technology conducted extensive testing and found that such interference presented no significant problem. T-Mobile’s justification for the technologically-discriminatory erection of this entry barrier is, thus, a lie.

But it gets worse.

More below…

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Verizon's “Perfect Storm”: A Reason Why 700 MHz Band's C Block Cleared On the Cheap

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Some critics of the 700 MHz Band Auction (Auction 73) attribute the failure of C Block — which consisted of large Regional Economic Grouping (REAG) licenses — to clear at the kinds of premium over the licenses in the AWS-1 auction that the Economic Area (EA) and Cellular Marketing Area (CMA) in the A, B, and E Blocks did to the fact that C Block had wireless Carterfone service rules attached.

However, careful analysis of the dynamics of the auction suggest that interaction of the auction’s combinatorial bidding, eligibility and activity rules, and the way in which minimum acceptable bids were calculated created a “perfect storm” in which Verizon was able to scoop up the two most populous REAGs for nearly half a billion dollars less than bidders were willing to pay earlier in the auction. This had a seriously depressing effect on the price at which C Block cleared and had nothing to do with the wireless Carterfone service rules.

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700 MHz: Breaking the C Block Package

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I apologise for the hiatus between this and my last 700 MHz Auction update, but with 36,419 bids over 261 rounds, analysing the data set is taking a bit of time.

Among the several controversies arising the from now-completed auction has been ATT’s claim that bidders were deterred from bidding on C Block because of the open access rules imposed on the block. I can say with confidence that this is a bald-faced lie.

Twenty-six companies bid on C Block spectrum: Alltel Corporation, AST Telecom, LLC, AT&T Mobility Spectrum, LLC, Bluewater Wireless, L.P., Cellco Partnership d/b/a Verizon Wireless, Cellular South Licenses, Inc., CHEVRON USA INC., Choice Phone LLC, Club 42 CM Limited Partnership, Copper Valley Wireless, Inc., Cox Wireless, Inc., Cricket Licensee 2007, LLC, Google Airwaves Inc., King Street Wireless, L.P., Thomas K. Kurian, MetroPCS 700 MHz, LLC, NatTel, LLC, PTI Pacifica, Inc., Pulse Mobile LLC, QUALCOMM Incorporated, SAL Spectrum, LLC, SeaBytes, L.L.C., Small Ventures USA, L.P., Triad 700, LLC, Vulcan Spectrum LLC, and Xanadoo 700 MHz DE, LLC.

Note that the lying buggers at ATT bid on REAGs 2 and 4. They were deterred, but only by Verizon’s deeper pockets.

The interesting dynamic in C Block is the effect of combinatorial bidding on the outcome. Under the combinatorial bidding rules three packages of REAGs were available (the 50 state package, the Atlantic package, and the Pacific package) as well as the individual REAGs. The rules provided that so long as the bid on a package exceeded the total amount of the bids on all the individual REAGs in that package, the package bidder would win (assuming that the package bid reached the reserve price). If the total amount bid on the individual REAGs exceeded the package bid in a round, then the package was “broken” and the package bidder wouldn’t be required to take any REAGs if it couldn’t have the whole package (this was to prevent a bidder who wanted a national footprint from getting stuck with less if another bidder outbid on one or two crucial components of the package).

Echostar was a strong proponent of combinatorial bidding, insisting that they wouldn’t show up and bid if the C Block did have a combinatorial bidding rule. Oddly enough, they got the rule and then their bidding entity, Frontier Wireless, didn’t even show in C Block bidding (they bid mainly in E Block without combinatorial bidding). But what they inadvertently did was screw at least one major bidder with the combinatorial bidding rules they insisted on.

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Senator Pryror Angry At Right Problem, But Picks Wrong Solution.

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UPDATE: On reflection, I’ve decided to modify the tone of this considerably. After all, when someone basically agrees with you (the incumbents have too much market power), slapping them around for relying on the press is a pretty stupid and counterproductive move. Besides, my real frustration is with the press for offering up speculation as if it were fact, not Pryor for reading the press and getting upset about the supposed failure of the auction to produce a new competitor. So with apologies to Pryor for needless snark the first time around, here we go again.

Senator Mark Pryor (D-Ark) is upset with reports that AT&T or Verizon probably won C Block. More specifically, he is angry that we don’t have more wireless competition. That’s good. But he accusses Kevin Martin of fixing the 700 MHz auction to benefit the telcos. That’s where he goes wrong, in my opinion. As I’ve said before, I don’t think Martin rigged this for the telcos, especially in light of Verizon’s persistent efforts to get the C Block conditions “clarified” away and Martin’s telling them to go take a hike. Further, adoption of the anonymous bidding rules means that we don’t know yet who won the licenses. We may very well be surprised when we see the results.

But if it turns out that, as predicted, the incumbents did win the lion’s share of the licenses, that doesn’t make the outcome Martin’s fault. Rather, Senator Pryor should direct his anger where it belongs — at the statutory requirement for the FCC to auction licenses for use of the public airwaves. As I explain below, and as many of us explained before the auction, incumbents enjoy real advantages even under the best of conditions because they don’t have additional costs new entrants have — like building the network from scratch or pulling customers away from a service they already use. To make matters worse, Senator Pryor’s Republican colleagues are constantly haranguing the FCC to “not pick winners” and objecting to any kind of mechanism that could neutralize these incumbent advantages.

We can’t have it both ways, and Congress makes the call. Either Congress eliminates auctions, or allows the FCC to exclude incumbents from the auction, or gives up on auctions as a way of generating competition and goes back to regulating market power directly. But blaming Kevin Martin and the FCC for the fact that incumbents keep winning auctions makes as much sense as blaming Bud Selig for the fact that the Yankees and the Red Sox always make the playoffs and the Nationals haven’t gotten to the World Series.

More below . . . .

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700 MHz: More Evidence for Success of Anonymous Bidding Rules

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I’d like to reiterate what fellow Wetmachiner Harold Feld wrote yesterday: the telecoms incumbents’ claims of problems arising from anonymous bidding are nonsense, part of a campaign to sow disinformation lest Auction 73 (700 MHz) and its success persuade the FCC to permanently adopt anonymous bidding rules for its auctions.

I call your attention to this table, which compares the number of bids on each license in B Block in rounds 1-26 of Auction 73 to the number of bids on each comparable CMA in Auction 66 (AWS-1) in rounds 1-26 of that auction. Note that in general the smaller the CMA number, the larger the population of the CMA (e.g., CMA001 is New York City and its immediate environs, CMA002 is the Los Angeles area, etc.).

What is striking about the data presented in this table is threefold. First, significantly more bids are being placed in general in rounds 1-26 in Auction 73 than in Auction 66. Second, extraordinarily more bids are being placed on the smaller and intermediate-size CMAs in Auction 73 than in Auction 66. Third, a much smaller percentage of licenses are receiving no bids in the first 26 rounds in Auction 73 than in Auction 66.

I am hard put to find an explanation of this extraordinary increase in competition, particularly for the smaller and intermediate-size licenses, which does not involve the effects of anonymous bidding. I suggest that the data, even though they do not disclose bidder identities, are entirely consistent with a more vigorous presence of new entrant and non-incumbent bidders who are protected from retaliatory and blocking bidding by large incumbents by anonymous bidding and are, therefore, more willing to engage in strong competition.

The telcos and cablecos can wail and moan to Communications Daily about the “risks” of anonymous bidding to the FCC, but the principal risk of anonymous bidding seems thus far to be the risk that fat-cat telecoms incumbents won’t be able to get all the spectrum in this auction by their usual bullying and exclusionary tactics. There’s no risk at all to the treasury — revenue from the auction is already wildly exceeding pre-auction projections — and there’s no risk that competition will be wan, as the data presented here amply demonstrate.

Chutzpah, Thy Name Is Wireless Incumbent.

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So here we are in the middle of the most intensely competitive auction ever. As you can tell looking at the recent postings by fellow Wetmachiner Greg Rose this auction has dramatically pushed up the amount of money paid by bidders for licenses and has created more intense competition for a broader group of licenses than previous auctions, strongly suggesting that — as Greg and I predicted when we first started pushing anonymous bidding in March 2006 — anonymous bidding eliminates all kinds of targeting, collusion and retaliation that typically held back smaller bidders and allowed larger bidders to pick up licenses for a song. An utter smashing success (at least from the perspective of those who favor using auctions for distribution of licenses), right? Who could have a bad word to say about it?

Answer: All the people who hate anonymous bidding BECAUSE it eliminates the ability to signal, retaliate, and collude and thus makes the auction more competitive. i.e. The incumbent wireless licensees (other than Verizon, which wanted anonymous bidding to avoid being targeted).

More below . . . .

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Assessing the 700 MHz Order Part III — Anonymous Bidding Alone Makes This a Big Win

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Regular readers will know that, as far as I am concerned, getting anonymous bidding automatically makes this Order a big win. I pushed hard on this in the lead up to the AWS auction a year and a half ago. Sadly, I lost. As a result, the cable companies were able to block the DBS guys from winning any new licenses, and the incumbents generally succeeded in keeping out any potentially disruptive new entrants (the cable guys having made it clear they would not compete with the cellular guys).

Fortunately, Greg Rose spent a year crunching the data and demonstrated that if the incumbents hadn’t rigged the auction, it sure looked like it from a statistical analysis/game theory perspective. With this “smoking gun” evidence in hand (utterly dickish footnotes by the Wireless Bureau staff to the contrary), we were able to persuade the Commission that adopting anonymous bidding rules would make the auction more competitive, give new entrants a better chance, and as a result probably increase the auction revenue overall.

So, having lost this last time around, I consider it a real coup to get it now. As both Google and Frontline supported anonymous bidding as necessary to encourage new entrants, I am hopeful that we may still get our “third pipe” provider even without wholesale open access.

Analysis below . . . .

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Dr. Rose Proves It Was Spectrum Co. In The Kitchen With the Candlestick . . .

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My good friend Dr. Gregory Rose has released two studies on last summer’s AWS Auction. I just bloged about them at length over at the Public Knowledge policy blog. So rather than repeat myself, I will merely say:

I argued after the AWS auction that cable companies and wireless incumbents had used the auction to kill DBS as a competitor. Rose proves that in his first report,
How Incumbents Blocked New Entrants In The AWS-1 Auction: Lessons For The Future.

Rose’s second report, Tacit Collusion In The AWS Auction: The Signalling Problem, looks at the use of bids to communicate. Again, as I’ve argued before, only by adopting anonymous bidding rules can the FCC stop bidders from suing the auction process to signal each other.

For the rest of my commentary, check out my PK blog.

Stay tuned . . . .

Anonymous bidding and not so anonymous shakedowns at the FCC

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Say what you like about Martin in other areas, but he is (so far) sticking to his guns on whether to require anonymous bidding for the upcomming AWS spectrum auction. MAP has actively supported this proposal, because it will make the auctions work better and facilitate entry by minority owned businesses and new, disruptive competitors (I’m stuck with them by statute, so I may as well try to get them to work right).

In perhaps the most telling evidence that anonymous/blind/sealed bidding (in which the identity of the bidder is not disclosed during the action) is a good idea, every incumbent (except VZ Wireless, which has been “targeted” in certain auctions) is lobbying fiercly against it. My favorite little tidbits of when the Sausage Factory turns nasty below.

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