riding the us wave: spectrum auctions in the digital age

Telecommunications Policy 25 (2001) 719–728

Riding the US wave: spectrum auctions in the digital age$

Andreas Gr .unwald

Institute for Information, Telecommunications and Media Law, University of M .unster, Germany

Abstract

Given its significant technological advantages compared to analog broadcasting, digital television (DTV)will be the television system of the future. However, it requires a full replacement of analog television setsby digital receivers, as DTV can only be watched with special equipment. In order to make this transitionhappen smoothly without losing the analog television audience, both signals have to be simulcasted until asubstantial coverage with DTV broadcasting has been achieved. Australia and the US meanwhile haveestablished a regulatory framework to lead this transition towards the end of analog broadcasting, the so-called analog switch-off. Part of the US regime is the FCC’s obligation to reassign analog frequencies afterthe switch-off has taken place by means of auction. Spectrum auctions, however, originate not from the USbut from New Zealand, where they have been used since the end of 1989 and ever since been subject to legaland political criticism. The article outlines the principles of both the DTV and spectrum auctions regulationand shows the links between both areas of telecommunications regulation. It concludes by suggesting thatthe analog switch-off is a unique opportunity to reconsider current spectrum policies, as it frees largeamounts of the radio spectrum that are today occupied by analog broadcasting and will soon be subjectto one of the biggest frequency reassignment processes in the history of telecommunications regulation.r 2001 Elsevier Science Ltd. All rights reserved.

Keywords: Analog switch-off; Digital television; Spectrum auctions; Radio spectrum management; Media regulation;Convergence

1. Introduction

The advent of digital technologies will significantly change television as we know it today,providing new interactive services that integrate features from both the broadcasting and theInternet world. Viewers will not only receive live and on-demand television programming, they

$Based on a previous version of this paper, the author gave a presentation at the Pacific TelecommunicationsCouncil’s 23rd Annual Conference, held during January 14–18, 2001, in Honolulu, Hawaii (http://www.ptc.org/ptc2001/).

E-mail address: [email protected] (A. Gr .unwald).

0308-5961/01/$ - see front matter r 2001 Elsevier Science Ltd. All rights reserved.

PII: S 0 3 0 8 - 5 9 6 1 ( 0 1 ) 0 0 0 4 1 - 6

will also be able to access their e-mail accounts, web-based e-commerce sites and new e-government services via their television sets. Although its introduction will not be without a costto programmers, broadcasters and consumers, digital television (DTV) clearly is the medium ofthe future. Eventually, it will replace analog broadcasting.An analog switch-off in broadcasting will take place, fundamentally changing the television

landscape, not only from a consumer’s, but also from a regulatory point of view. This paperexamines the relevant regulatory challenges by looking at the experiences of Australia and NewZealand. Both countries can serve as role models not only for the Pacific region, but in a globalcontext: While Australia has already presented a precise timeline for the conversion from analogto digital television, New Zealand became the first country in the world to use auctions to assignbroadcasting frequencies. Before turning to these regulatory approaches, however, a brieftechnological overview of DTV is given in order to highlight its advantages and potentialcompared to an analog broadcasting system.

2. Bit by bitFtelevision’s turn to digital

Bringing information handling to a new level of ease and efficiency, digitization underlies all thecoming changes in the communications infrastructure, including television. It allows thetransformation of diverse original materials, such as sound, still images and moving imageFallrepresented in a numerical formatFinto a universal, compact and transportable data stream thatcan be delivered via the Internet as well as by traditional broadcasting technology. (On DTVtechnologies, see Blair, 1999; de Bruin & Smits, 1999; van Tassel, 1996.)Compared to analog, there are many advantages to digital television. Compression reduces the

information in the signal; so more signals can fit into the same bandwidth. Given that theelectromagnetic spectrum is a scarce and valuable good, this brings down the high cost ofbandwidth for every kind of over-the-air delivery of televisionFbroadcasting, satellite direct-to-home and cellular. Digital technology also features CD-quality sound and clearer images andenables the wide-screen 16 : 9-format. Finally, it enables convergence on the hardware level, thecoming together of computer, telephone, and broadcast equipment.However, there are a few disadvantages to DTV as well, at least at the current stage of its

development. Most of all, setting standards has proven to be problematic (see Brinkley, 1998;Flaherty, 1994). Currently, there are two different, non-compatible modes in existence: The USstandard, ATSC,1 and DVB,2 which originates from Europe but has been adopted by countrieslike Australia, New Zealand and India, too. As a result, two separate markets for relevantconsumer electronics will evolve. Also, the high cost of replacing the installed base of analogequipment for production, transmission and reception is a significant barrier to the fullimplementation of DTV. And finally, the economics of DTV are vague and risky. Especially whenit comes to DTV in a high definition format (HDTV), the development of a market remainsdoubtful, as consumers will probably not be willing to pay extra fees just to receive a televisionpicture of enhanced quality.

1See http://www.atsc.org/.2See http://www.dvb.org/.

A. Gr .unwald / Telecommunications Policy 25 (2001) 719–728720

Thus, considering the enormous technological potential of DTV networks as a platform forhome-shopping and other interactive electronic commerce activities, as well as for a variety of paytelevision services such as video-on-demand and pay-per-view, the future of television will bedigital.

3. From analog to digitalFmaking the transition

3.1. The need for regulation

As seen above, the digitization of broadcasting creates the necessary preconditions for thefurther development of broadcasting and the integration of information, communications andbroadcasting technologies. It thereby opens up markets for new digital applications and adiversity of innovative processes. Specifically, the digitization of broadcasting provides the basicinfrastructure for the market launch of new, digital products and services both in traditionalbroadcasting and in the field of new multimedia services, such as electronic commerce and homeshopping applications or video on demand services.The faster the digitization takes place, the greater the market opportunities will be for these new

technologies and products. Especially when it comes to the digitization of terrestrial broadcasting,where transmission capacities are especially scarce and therefore economically valuable, thisrequires appropriate regulatory efforts to facilitate the transition. These efforts have to deal withtwo main challenges. First, because the current analog radio spectrum is a scarce public good thatby means of digital broadcasting technology can be used far more efficiently, the regulation of theanalog switch-off has to deal with frequency management before, during, and after theconversion. Second, the analog switch-off requires the use of new or additional receptionequipment. From a consumer’s perspective, this means that new devices such as set-top-boxesmust be purchased, leased or rented. Regulators and policy makers, though, have to keep in mindthat without suitable consumer devices, no one will be able to actually receive DTV. After all, afull switch-off of analog television is only feasible when, at the same time, a complete coverage bydigital signals is guaranteed.

3.2. The Australian scenario

In Australia, the Television Broadcasting Services (Digital Conversion) Act of 19983 introduceda new schedule to the Broadcasting Services Act of 1992.4 It provides for the conversion oftransmission of broadcasting services from analog to digital and requires the AustralianBroadcasting Authority (ABA) to develop legislative schemes for the analog switch-off. The ABAfollowed this provision in March 1999 and released the Commercial and Draft NationalTelevision Conversion Scheme. The new law also empowered the ABA to set up Digital ChannelPlans (DCPs) to determine which channels are to be allotted in each area and assigned to eachbroadcaster, and which are the technical limitations and characteristics of those channels. So far,

3Available at http://scaletext.law.gov.au/html/comact/10/5878/top.htm.4Available at http://scaletext.law.gov.au/html/comact/8/4013/top.htm.

A. Gr .unwald / Telecommunications Policy 25 (2001) 719–728 721

the ABA has released DCPs for several metropolitan markets such as Canberra, Brisbane,Adelaide and Melbourne, as well as a regional DCP. (On Australian DTV regulation, see ABA,1999.)The basic principles and policy objectives for the analog switch-off in Australia are outlined in

Schedule 4 to the Broadcasting Services Act. Thereafter, each holder of a television broadcastinglicense in a metropolitan area is required to commence digital transmissions from January 2001.For regional broadcasters, a similar obligation has to be fulfilled by January 2004. Furthermore,broadcasters have to transmit their programs in both analog and digital mode during a simulcastperiod of at least eight years. In order to do so, they shall be authorized to use one or moreadditional channels for their digital transmissions which shall occupy the same amount ofbandwidth as the channels used for analog broadcasting (7MHz). During the simulcast period,the digital transmissions are required to achieve the same level of coverage and potential receptionas soon as is practicable. Also, beginning in January 2003, networks in metropolitan areas arerequired to broadcast at least 20 h of high definition programming per week.At the end of the simulcast period, currently planned for 2008, analog transmissions are to

cease. Broadcasters are then required to return the frequencies they no longer need for analogtransmissions to the ABA, in order to allow for newFdigitalFtelevision broadcasting licenses tobe issued. Under this regime, however, it is up to the broadcasters which one of their two channelsthey want to keep for their future digital transmissions and which one they want to return to theABA for redistribution.

3.3. The US scenario

The US route towards digital terrestrial began in 1997, when every existing analog broadcasterwas assigned an additional 6MHz frequency to allow additional digital transmissions (FCC, FifthReport and Order, FCC 97-116. On US DTV regulation, see also Geller, 1998; Wiley, 1997).Raising many concerns especially from the Republican side, who strongly disagreed with theFCC’s ‘‘spectrum giveaway’’ policy, this assignment happened for free. Also, broadcasters wereawarded a large amount of ‘‘spectrum flexibility’’, as there were only very limited simulcastrequirements established.5 Essentially, it is not mandatory for US stations to broadcast HDTVprogramming over their digital frequencies. They only have to make sure that a certain amount ofDTV programming is available for free, while at the same time they are allowed to use their newtransmission capacities to offer additional and ancillary services such as Pay TV or datacasting. Ifthey do so, however, the FCC shall establish a program to assess and collect an annual fee fromthe broadcasters that reflects the revenues they are generating from their additional freespectrum.6 This happened in late 1998 when the FCC issued a Report and Order in this matterthat defined the annual fee at a rate of 5 percent of the broadcasters gross income from anyadditional service that requires a subscription fee to be received.7

As laid out in the US Communications Act, terrestrial transmissions of analog televisionbroadcasting shall be determined in the US by December 31, 2006, if at this time at least 85% of

5See 47 USC Section 336 (b)(2).6See 47 USC Section 336 (e)(1).7FCC, Report and Order, FCC 98-303.


US households have gone digital.8 In order to achieve this aim, the FCC has set up a DTV roll-outplan.9 First, it focused on the major television markets, but eventually required that by May 2003,all stations must have started their digital transmissions. As for the additional frequencies, theyhave to be returned to the FCC once the analog signal has been switched off in 2006. Thesefrequencies will then be assigned to new usersFadditional DTV broadcasters as well as otherwireless servicesFby auction. However, this auction was originally scheduled to happen as earlyas March 2001, although the spectrum in question will not be freed by its current users for at leastanother five years. Apparently, the FCC realized this dilemma in the meantime, too, andpostponed the auction.10

4. Dividing the radio spectrumFthe case of auctions

Efficiently managing the radio spectrum is a key to success for the analog switch-off to happensmoothly and for DTV regulation as a whole. Assigning additional channels to existingbroadcasters for digital simulcasting purposes is an issue that has to be confronted today. Still,because it is more of a technical than a regulatory problem, it should be solved by broadcastengineers rather than by policy makers. The latter, however, will then have to decide how to dealwith today’s broadcasting channels once they are no longer needed for analog transmissions. InAustralia, broadcasters eventually have to return these channels to the ABA, which will then usethem to authorize new DTV services. This regime, though, does not yet require the ABA to utilizea particular licensing procedure for the reassignment. In this regard, the US scenario fortelevision’s conversion to digital took another step by making it mandatory for the FCC toauction off the additional channels after they have been returned in 2006. Regarding thesignificant amount of spectrum that is currently used for analog broadcasting and that willaccordingly be returned in 2006, this auction will probably be the largest in the history of theregulation of the electromagnetic spectrum.From an academic, but also from a policy-making point of view, this raises the general question

if spectrum auctions are a suitable way to regulate the electromagnetic spectrum. New Zealandwas the first country in the world to utilize auctions for allocating spectrum. The New Zealandexperience became a role model. Throughout the 1990s, numerous jurisdictions worldwideadopted the auctioning system to regulate the commercial use of their radio frequencies. One ofthese successors is the US, where since 1994, spectrum auctions have generated over 20 billiondollars for the federal budget. However, while the New Zealand model incorporates a trueprivatization of spectrum, the US approach is a regulatory one.

4.1. PrivatizationFthe New Zealand experience

Prior to 1987, the New Zealand government maintained a virtual monopoly in the provisionand regulation of telecommunications services. Under this regime, the management of the radio

8See 47 USC Section 309 (j)(14)(A).9See 47 CFR Section 73.624 (d).10FCC, Public Notice, DA 01-266.


spectrum was handled by the post office. By the mid-1980s, however, the New Zealand economywas suffering from severe inflation and unemployment rates, because, according to some analysts(see NERA, 1988), heavy-handed regulation, cross-subsidies and protectionism had led tomisallocation of resourcesFnot only in the telecommunications sector, but in numerous otherareas of the country’s economy as well, such as the railroads, ports and hospitals. Against thisbackground, New Zealand passed the Telecommunications Act of 1987 and opened up thetelecommunications market. The goal of this initiative was to improve the efficiency with whichnew services were provided to the public (see Crandall, 1998; Pritchard-Kelly, 1996).The Telecommunications Act of 1987 was followed by the Radiocommunications Act in 1989.

The new law established a market-based system to allocate electromagnetic spectrum andcompleted the reform of the New Zealand telecommunications sector. As a core element, theRadiocommunications Act of 1989 introduced the use of auctions to allocate spectrum. For that,it established property rights in the radio spectrum of two different kinds: management rights andlicenses (see Spiller & Cardilli, 1999). Compared to a license, a management right is superior. Itsowner has broad control over a certain frequency band and determines the use to which the bandis to be put by granting licenses. For the most part, management rights are owned by thegovernment, although at the time of privatization some management rights were owned byincumbent license holders, who would continue to hold them until the expiration of their license.Both kinds of property rights, management rights and licenses last for a period of 20 years and onexpiry automatically revert to the government (see pritchard-Kelly, 1996).For the government, the radio spectrum is managed not by a special agency or authority, but by

the Ministry of Commerce. Under the Radiocommunications Act of 1989, it has broad powers todecide which frequency bands shall be transferred to private management. However, the Ministryof Commerce still manages most of the spectrum in the traditional manner, keeping themanagement rights to itself and awarding licenses for special uses to individual licensees who arethen not allowed to use this spectrum for other purposes. Thus far, only very few frequency bandshave been transferred to private management authorities, and even these bands were initiallydesigned for specific uses. All these transfers, though, were executed by way of auctioning.Interested bidders were invited into competitive ‘‘bid tenders’’, with equal information availableto all bidders at each stage. A short list of bidders eligible to make a final bid for the spectrum wasmade on the basis of their initial bids. The spectrum was auctioned only if there was more thanone expression of interest; otherwise the license was allocated for free on a first-come/first-servedbasis to the only applicant.The New Zealand auctions themselves followed the sealed-bid, second-price ‘‘Vickery’’ method

(fundamentally Vickery, 1961), meaning that the bidder submitting the second highest bid wouldtake precedence over the bidder submitting the highest bid (see Schroepfer, 1992). This modelraised a great deal of criticism. Indeed, looking at the results of the first New Zealand auctions,the Vickery model proved to be unsuitable for such a small telecommunications market. Forinstance, there were only two participants in the mobile telephony auctionFNew ZealandTelecom and Bell South. As a consequence, the second price strategy caused the New Zealandgovernment to lose hundreds of thousands of dollars in a handful of cases where the second-highest bids were frivolously lowFas little as a few dollars. Eventually, this distortion in pricemoved the country to switch to a simple highest-bidder system. (For the results of the NewZealand auction see Pritchard-Kelly, 1996; Mueller, 1993).


4.2. RegulationFthe US experience

Since 1993, the FCC has had the authority to use auctions to assign licenses if mutuallyexclusive applications to operate a telecommunications service are filed. As part of his budgetsubmitted to Congress, President Clinton proposed competitive bidding as a revenue source andas a means of improving the FCC’s licensing method. At this time, however, a number ofexceptions from a pure auctioning scheme were made. First, broadcast services were exceptedfrom the new law, as comparative hearings were continued to be used for radio and TV. Second,there were special rules for ‘‘designated entities’’, by which Congress directed the FCC tohandicap certain license auctions so that particular licenses would be won by members of a certaingroup of ethnic minorities. Eventually, both factors helped to overcome the substantial criticismof those members of Congress who traditionally opposed any market-based spectrum policy. (Onthe 1993 legislation, see Allard, 1993; Hook, 1993; Kummel, 1996.)Only four years later, though, the FCC’s new auctioning power was already widened, as

Congress passed the Balanced Budget Act of 1997. Under the new law, the FCC was nowauthorized to auction any kind of license including those for radio and television services.However, the overwhelming proportion of broadcast licensesFmeasured in economic valueFareunaffected by this provision, because DTV services are explicitly excepted from auctions, as are alllicense renewals. In practice, this leaves only very marginal AM or FM radio station servicelicenses to be subject of the FCC’s current auctioning authority. (On the 1997 legislation, seeO’Brien Ham & Buchanan, 1998.)With digital broadcasting, the US decided to give an additional frequency to every

existing broadcaster of analog television in 1997. This frequency was assigned free ofcharge and is to be used to simulcast the analog programming in digital format duringthe time of transition to a fully digital broadcasting system. After the switch-off of analogtelevision, however, which is scheduled for the end of 2006, these additional frequencies are to bereturned to the FCC which then will hold an auction to reallocate them, too. Therefore, althoughat the moment, the FCC’s auctioning authority does only affect a minority of US broadcastingservices, this situation will change dramatically as soon as the analog switch-off has happened andvast portions of the electromagnetic spectrum that is currently used for analog broadcasting willbe auctioned to new users. (On US DTV regulation and spectrum auctions, see Goodman, 1997.)

5. Spectrum auctionsFthe future?

Following the example of New Zealand, auctions are increasingly becoming the primeadministrative method to allocate radio frequencies. As the US situation shows, they will sooneror later strongly affect the regulation of broadcast media as well. Given this background, a closerlook at their advantages and disadvantages should be worth taking.

5.1. Advantages

Auctions are a fast way to assign authorizations to use the electromagnetic spectrum.Compared to the so-called beauty contests, they minimize regulatory delay and inefficiency.


Studies from the US show that in the case of Personal Communications Services (PCS), assigningthose licenses by comparative hearing took at least three times longer as auctioning the same kindof licenses.11 Secondly, auctions are transparent, with clearly established rules and definiteoutcomes. They avoid potential and actual government decisions that are biased towards oragainst individual industry players, providing a basis that allows any potential licensee todetermine the licensing decision. Thirdly, auctions help to avoid a wasteful use of scarce spectrumresources, as they ensure that spectrum ends up in the hands of those who value it the most. This,in turn, ensures that services and technologies are made available more rapidly because thespectrum has been assigned at a cost that is based on the expected return for its use. Accordingly,by getting radio licenses into the hands of those who value them the most, the public gets a chanceto recover their full value. (As advocates of market-based spectrum assignments methods, seeCramton (1998), de Vany (1998), Hazlett (1998), and the classic critique of the FCC’s comparativehearings by Coase, 1959; based on Herzel, 1951.)

5.2. Disadvantages

Despite the advantages of spectrum auctions, they may not be appropriate under allcircumstances. First, there may be issues such as public safety and national defense wherefundamental public policy goals might not be well served by using a competitive biddingmechanism. Furthermore, an auctioning system creates additional entry barriers to thetelecommunications market. Auctions might help to put telecommunications licenses in thehands of those who value them the most, but this valuation is one based purely on financialgrounds. Given the fact that under an auctioning regime, the assignment criteria are limited to thehighest financial bid, auctions may prove to be inefficient in terms of failing to reflect the fullpotential of an applicant. Especially when it comes to auctioning broadcast licenses, this impliesthe risk that an applicant who offers a high quality programming concept that might serve thepublic interest, does not get a chance to broadcast this program simply because he is outbid byanother applicant with greater financial standing. Especially with smaller and minority-ownedbusinesses, auctions can therefore turn out to limit access to the radio market and thereby toseriously restrict the freedom of broadcasting. (For a critique of the US spectrum auctions regime,see also Benkler (1998) and Noam (1998). Both authors argue in favor of an open access model toradio waves.)

6. Conclusion

The digitization of broadcast television requires a number of regulatory efforts especially in thefield of spectrum management. In order to provide for a smooth and fast transition from analogto digital transmissions, regulators are asked to set out a precise timeline offering a considerableamount of planning certainty to both consumer and industry groups. The Australian exampleillustrates how such a timeline can be designed. Additionally, it has to be taken into account thatafter the analog switch-off has eventually happened, significant amounts of the radio

11See FCC, Report to Congress on Spectrum Auctions, FCC 97-353.


spectrumFthe same frequencies that today are used for analog transmissionsFwill be availablefor reassignment to new services.Regarding the licensing process, however, the use of auctions should be critically evaluated.

Not only the New Zealand experience, but also the examples of the US and the ongoing3G/UMTS licensing procedures in Europe indicate that there is a strong movement incommunications (and budget) politics towards this kind of regulation. Nevertheless, competitivebidding standards may prove to be inappropriate to meet the actual needs of the communicationsand especially the broadcasting industry, in particular when it comes to safeguarding the publicinterest in the use of radio frequencies.On the other hand, auctions may help to facilitate the analog switch-off: Spectrum no longer

required for analog terrestrial broadcasting could be auctioned, either before or after the actualclosure of the analog transmission network. The proceeds from such an auction could then beused to subsidize the supply of digital reception equipment in areas that may not have had thebenefit of a number of years of analog and digital simulcasting of the qualifying services.

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riding the us wave: spectrum auctions in the digital age

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