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IP: Comment on Big Bang Auction and reply by Faulhaber for the authors


From: David Farber <dave () farber net>
Date: Wed, 19 Jun 2002 11:20:23 -0400


From: Jock Gill <jock () jockgill com>
Date: Tue, 18 Jun 2002 19:36:37
To: Dave Farber <farber () cis upenn edu>
Subject: Big Bang Auction

Dave,

I have the greatest respect for you and Gerry but I also have a few questions about your proposed Big Bang Auction proposal.

While an auction might be appropriate if spectrum were a scarce resource, it may be the case that so called spectrum scarcity is simply an illusion produced by the state of technology in the 1930s when the foundations of the FCC regulatorium were established. Reed, as you know, argues this in his web page on Open Spectrum <http://www.reed.com/OpenSpectrum/>. If capacity is what we should be measuring, then the property model of spectrum may be ill advised and counter productive. Should we not resolve this question before we go for a Big Bang which might be next to impossible to undo? Should we not at least preserve an option for choice and innovation, as Reed says, in order to escape from the obligation and coercion of old style regulations?

Further, it is possible that an auction approach violates a lesson learned from the Internet's success and the severe business problems currently being faced by the cable and cell phone business model. Namely, what is the source of capital to finance the next technology wave of wireless device to device communications? The success of the Internet appears to be related in no small part to the fact that it was financed to a large degree by end user capital. At the same time, the problems in the cell phone and cable business appear to be related to their reliance on very large scale, centralized, financing from VCs and banks. Who owns the set top box in your home? Who paid for the PC you are reading this on? Where is the next wave of capital going to come from?

As Reed and Lipmann point out: We need to further the idea of networks that are

         a) largely user-financed,
         b) undifferentiating between producer and consumer,
         c) architected so that cooperation gain creates most of the value.

Unlike the broadcasters and the telecom (telephony) networks, we need an approach which promotes edge-based value creation. These are key lessons learned from the Internet experience.

It would seem that a Big Bang Auction approach may well make the above goals more difficult to reach. Can you argue that a Big Bang approach makes these goals easier to obtain?

Lastly, what is the metric we should use to evaluate our communications regime today and going forward? I would argue that there are a number of issues that a metric for 2002, a metric which takes every bit of technology we have on hand today into account, must address: technological, economic and political at the least. It must also allow for our imperfect knowledge, the we don't know factor, and permit evolutionary change as the state of knowledge and technology changes as we know it will.

It is not clear that the Big Bang approach you propose escapes the limits of what we knew in 1930, before we had radar, Shannon, computers, micro chips or GPS. For example, Dewayne Hendricks argues that current FCC regulations make little or no use of the time dimension. Now why is that? Would a Big Bang approach promote modernizations to over come these deficits? Or would a Big Bang merely entrench the incumbents even deeper, making change even more difficult?

Perhaps, before we engage in any hard to reverse Big Bangs, we ought to look at the basis of current regulations to make sure they are sound and NOT unintended consequences of the state of affairs before 1940. For example, is interference an engineering truth or an artifact of conditions in 1930s? Reed made a compelling argument to the TAC in May that loss of information happens because of bad architecture and poor technology at the receiver side, NOT because signals interfere with one another in the 'ether'. Before we close the door on the option for a Spectrums Commons based upon Open Spectrum, we ought to take a time out to evaluate the possible existence of other engineering truths that are not truths except in artificially constrained situations.

We should not accept a regulatorium and its derivative policies if they are, in fact, based upon the self referential arguments based upon unintended consequences. Until we resolve these issues, I suggest it is premature to consider a Big Bang approach. In any case we should only support a solution which maximizes our chices going forward. It is not clear to me that a Big Bang passes that test.

 Regards,

 Jock
 Jock Gill
 <www.jockgill.com>
 Autographic Portraits
 The image of who you are


reply

From: "Faulhaber, Gerald" <faulhabe () wharton upenn edu>
To: 'David Farber' <dave () farber net>
Subject: RE: Big Bang Auction

A very thoughtful response, Jock; thanks. One small but very important point: this is not our idea, although we like it a lot. It was invented by Evan Kwerel and John Williams at the FCC.

Dave and I agree that the current spectrum "shortage" is based on regulation not on science. As our presentation to the FCC made clear, the Big Bang auction is designed to free up that spectrum and get it into use. We expect that when all the spectrum is in the market, the shortage will disappear. Prices for certain parts of the spectrum will remain fairly high, such as wireless-friendly frequencies and legacy broadcasting. But in the relatively short run, spectrum will be available (we believe) rather cheaply. When any commodity is abundant, its price is low, and that's what we expect.

I don't really think it's the job of public policy to determine how advances are to be financed. It is the job of public policy to make sure there's a business there. The US has the deepest and richest capital markets in the world and in history; we are fully confident that sensible business plans will find financing, as they do today. Are the crazy days of 1999 over? Of course; investors are being cautious. But I think asking us to solve the "problem" of capital markets (if there is one, which I don't believe) is going a bit far.

I understand the popularity of edge-based systems among those familiar with the growth of the Internet (Larry Lessig, etc.). I am less than theological about this; I would suggest reading the Dave Clark/Marjorie Blumenthal piece "Rethinking the Design of the Internet: The End-to-end Arguments vs. the Brave New World". And it is not at all obvious this is the optimal design for wireless markets. So, no, I don't buy the argument that we have to make the case that the Big Band will result in edge-based systems. It may, and it may not, but we are not willing to accept that it *must*.

I'm not sure I understand what Jock has in mind by "metric." Usually, economists use the idea of economic efficiency, which includes not only technical efficiency (are the resources being used most effectively?) but allocational efficiency (are they getting to those who value them most?); a good microeconomics textbook should cover this in Chapter 1. That's why we want to move toward markets; when they work, they tend toward efficiency (which is why economists like them). By that standard, it is pretty obvious that spectrum use is very inefficient; examples abound.

A related issue: we understand that the US is linked to the rest of the world through various agreements and an ITU standard. We have no simple fix for this; but we note that when the US deregulated its airlines, it was similarly linked to the rest of the world through a variety of bilateral and multilateral agreements, all of which required renegotiation. Similarly when the US deregulated international telephony. It is no doubt difficult and complicated, but we've dealt with this type of problem before. We don't have to be locked into a system that is obviously failing simply because the rest of the world is locked into it.

Professor Gerald R. Faulhaber
Business and Public Policy Department
Wharton School, University of Pennsylvania
Philadelphia, PA 19104
215-898-7860

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