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Complexity in spectrum auctions: how much is too much? 6th Annual Americas Spectrum Management Conference Richard Marsden Managing Director, NERA Economic Consulting New York City NERA Recent experience Incentive Auction Other recent


  1. Complexity in spectrum auctions: how much is too much? 6th Annual Americas Spectrum Management Conference Richard Marsden Managing Director, NERA Economic Consulting New York City

  2. NERA – Recent experience Incentive Auction Other recent projects   Simulation software for broadcasters Design and implementation of who together accounted for >15% of spectrum auctions in Mexico, nationwide revenues (US$1.5bn+) Singapore & Saudi Arabia  Bid strategy support for mobile  Four firewalled groups providing operators in awards around the support to participants in the forward & world (Canada, Costa Rica, reverse auctions Germany, Ireland, Myanmar …)  Analysis of auction rules and channel  Reports on effective spectrum share arrangements for broadcasters pricing for GSMA:  Support to rural mobile operators www.gsma.com/spectrum/effective- lobbying FCC regarding geographic spectrum-pricing license size 1

  3. What do w e mean by “complexity” in auction design?  Common perspective is that spectrum auctions are becoming increasingly complex – In fact, many new features have simplified the bidding process – Main area of controversy is use of package bidding and optimization techniques  Important distinction between implementation complexity (for auctioneer) and bidding complexity (for bidders) Predictability of outcomes Number of lots Aggregation and and categories substitution risk Auction software Vulnerability to Bidding Implementation specification gaming Ability to Use of optimization techniques understand rules Ease of bid Auction duration submission and management  Design auctions to be as simple as possible without sacrificing core policy goals Best  If complex situations, it is preferable for auctioneer to take on greater Practice implementation complexity if this can reduce bidding complexity 2

  4. “New features” in auction design • Simplify bidding process North American regulators have embraced “new features” in • Reduce risk for bidders auction design designed to: • Eliminate gaming options Recent North Optimization / Generic lots Clock pricing Limited American auctions Package bidding for cellular spectrum information for each band or category With non-discretionary bid increments 2500 MHz AWS 600 MHz Reverse 600 MHz Forward 3

  5. How do these features impact complexity?  Many of these new features are (relatively) uncontroversial and likely to be common to many auctions going forward: In many situations, • promotes contiguous assignment, simplifies Generic lots bidding these features are easy to implement • simplifies bidding, eliminates price signaling Clock prices and tend to make bidding easier and bid strategy more • maintains scope for price discovery while Limited straightforward making gaming more risky information  The impact of package bidding and optimization is more complicated to assess: • Highly flexible tools for achieving policy goals These tools are (e.g. US repack or Mexico AWS band Optimization & much more defragmentation) package complex to • In complex settings, bidders struggle to bidding implement and their understand rules and dislike outcome uncertainty impact on bidding is • Practitioners still in learning phase regarding ambiguous impact of these tools on bidder behavior 4

  6. Case study: US Reverse Auction for broadcasters  Key features of Reverse Auction design – Maximum implementation complexity: repacking algorithm Optimization is a – Very simple bidding rules: accept / reject price powerful tool that  could have many Efficient repack would not have been possible without optimization algorithm future applications  However, this approach also had downsides: – Very challenging for bidders to comprehend broader process – Huge asymmetry in understanding of auction process across broadcasters But challenges  Unclear whether these issues had any impact on bid behavior for bidders in auction, but they certainly affected the secondary market created by lack – Few broadcasters had good tools for estimating auction revenues and those of transparency that did had to grapple with uncertainty over clearing scenario should not be – Impossible to estimate value of high-VHF stations with any certainty under-estimated  Very challenging to agree channel share deals  Many station sales were likely mis-valued, some grossly so 5

  7. Case study: Combinatorial clock auction (CCA)  Full package bidding eliminates  Functional package bid auction that has been used to aggregation risk sell spectrum in Canada, Mexico and elsewhere  Optimization can facilitate – Uses optimization to allocate spectrum in packages defragmentation (e.g. Mexico AWS) – Uses “opportunity cost” based pricing rules (winners pay price based on denying spectrum to rivals)  CCAs are disproportionately associated with high prices and  Originally promoted to regulators on basis that it: asymmetric allocations  Growing academic literature questioning efficiency of CCAs 1 Eliminates aggregation risk owing to:  Missing bids  Budget constraints 2  Supports fully efficient auction outcomes Spiteful bidding  CCA linked to “aggressive” and Promotes straightforward bidding & “spiteful” bidding 3 eliminates gaming options  Both theory and practice have shown that straightforward bidding often not a good tactic 6

  8. CCA is linked to high and asymmetric price outcomes Dutch 4G Canada 700 MHz Combination of CCA and Amongst OCED countries, the four entrant set aside resulted in countries with the highest spend exceptionally high and per capita on spectrum since 2008 asymmetric prices all used the CCA format Austria 4G Combination of CCA and restricted information led to exceptionally high prices despite only the three incumbents bidding UK 4G Prices were relatively low but allocation outcome was highly asymmetric – a key bidder later revealed it was Source: NERA Economic Consulting, report for GSMA on effective spectrum pricing budget constrained 7

  9. “Gaming” behavior in CCAs   Typical characteristics of CCAs where “gaming” NERA colleagues have been involved in every CCA behavior was advantageous: since 2010, either working for bidders or regulators – Multi-band or multi region  We reviewed all 17 auctions and concluded that – Lax spectrum caps and/or set asides “straightforward valuation-based bidding” would only have been a good unilateral strategy for a plurality – Predictable asymmetries between bidders of bidders in 5 cases – Significant excess demand at reserve price UK Canada Denmark (x2) Ireland Netherlands (x2) (x2) Slovakia Austria (x2) Mexico Slovenia Switzerland Montenegro Straightforward bidding likely to produce acceptable or best outcome Better outcomes available Australia to bidders that deviated from value-based bidding Note: 2 colors indicates one example of each type 8

  10. What next?  Regulators appear to be following different paths with respect to implementation complexity in auction design … Less implementation complexity More implementation complexity Mexico 2.5 GHz – Proposes to use clock Austria 3.6 GHz – Consulting on using auction with no package bidding for award CMRA instead of CCA for award that may with simple lot structure than previous feature regional licenses auctions Canada 600 MHz – Consulting on new UK 2.3 & 3.4 GHz – Ofcom pioneered the versions of CCA with more complex activity CCA format but plans to switch to hybrid SMRA and pricing rules, despite simpler band plan format for dual band award than previous awards USA C-band – Despite complex shared use Denmark 1800 MHz – Implemented new setting, CBRS proposals lend themselves to “CMRA” format (first price package bid auction) clock auction with no package bidding for award with coverage obligation opt-outs  But all these auctions will likely share other features that reduce bidding complexity: generic lots, (quasi) clock bidding and limited information  Open question: Is the greater complexity that some regulators are embracing really needed and how will this impact bidders? 9

  11. Contact NERA’s spectrum & auctions team Richard Marsden Dr Soren Sorensen Hans-Martin Ihle Managing Director Associate Director Senior Consultant NERA New York City NERA London NERA Tokyo +1 212 345 2981 +44 207 659 8808 +81 3 3500 3784 Richard.Marsden@nera.com Soren.Sorensen@nera.com Hans.Ihle@nera.com

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