Sponsored
researchers already have entered the conversation about spectrum policy with a
new objective of thwarting any effort to promote access by non-incumbents, or
at least any carrier other than AT&T and Verizon. These researchers will prove that denying
incumbents the opportunity to acquire even more spectrum will reduce the
government’s take. I agree and empirical
evidence supports this. When the FCC
imposed requirements of open access or sharing with first responders on a
spectrum block, the amount bid was lower than unencumbered spectrum.
But
of course sponsored researchers want to extrapolate from this truth to many conjectures
including the premise that any spectrum set aside would prevent the most
efficient providers from doing more with more.
Somehow if AT&T and Verizon do not capture the lion’s share of any
and all available spectrum, then both taxpayers and wireless consumers suffer.
This
premise does not pass a basic smell test.
We should appreciate that what the government takes now in spectrum auction
proceeds, it loses in future tax revenues, because carriers can use their
spectrum investments as offsets against income.
Perhaps
more importantly we should consider what the two incumbents with over 70%
market share can do with additional spectrum.
In the best case scenario they will put the spectrum to immediate use
and abate any real scarcity. In the
worst case access to more spectrum eliminates incentives to more efficient use including
the possibility of buying simply to deprive competitors of access and to
preempt market entry. Additionally
incumbents possibly can “warehouse” the spectrum by not using it, but
preventing other carriers from putting it to efficient and immediate use.
Consider
a commercial aviation analogy. Let’s
assume a highly congested airport can offer additional landing and takeoff slots,
a result when an additional runway gets constructed, or when regulators relax a
cap, or allow late night operations. In
this particular aviation market one carrier has a dominant market share,
something that regularly occurs when that market represents a carrier’s hub,
e.g., Washington Dulles for United;
Philadelphia for U.S. Airways, Detroit for Delta and Dallas Fort Worth for
American. Dominant carriers have market
power in their hub markets as evidenced by their ability to charge higher fares
than cities with competitive commercial aviation markets.
These
carriers will do anything to maintain their dominance including acquiring as
many new landing and takeoff slots as possible.
Of course they will frame their acquisitions as serving the public
interest and consumers, even if they have to use smaller aircraft—with less
seat capacity—to ensure that every slot gets used. With more available slots incumbent air
carriers might determine that they will oversupply seating capacity with large
planes. But rather than pass on the
opportunity to control even more access to the market, these carriers will
acquire new slots at any price simply to prevent existing or prospective
competition from flourishing.
In
the short run everything looks grand: the government accrues higher auction
revenues than contemplated, because of the market preemption benefits reflected
in a dominant carrier’s win at all costs bids.
But in the immediate term consumers suffer from higher rates available
to the fortress hub carrier. Recently
even corporate flyers have complained about the consequences of hub dominance
and the reduction of competition and flight options in non-hubs. In the longer term the tax benefits to
incumbents and the elimination of most competitive benefits weigh in.
Bottom
line: if the FCC seeks to maximize short term spectrum auction proceeds it will
guarantee that incumbents acquire most newly available spectrum further
concentrating the market and reducing the benefits of facilities-based competition.