Expert Reports, Affidavits, And Testimony
“Affidavit of Peter Cramton on Behalf of PJM Interconnection LLC,” before the Federal Energy Regulatory Commission, Docket No. ER21, 30 July 2021. Comment on PJM’s proposed minimum offer price rule. [PJM MOPR filing 30 July 2021]
“Auction Model for the 3500 MHz Band,” prepared for the Ministry of Economic Affairs, Government of the Netherlands, December 2020. [Dotecon recommendation]
“Comment on ‘FirstNet: An Economic Analysis of Opting In vs. Opting Out’” (with Linda Doyle), University of Maryland, 8 June 2017.
“Design of the Reverse Auction in the Broadcast Incentive Auction” (with Hector Lopez, David Malec and Pacharasut Sujarittanonta), Working Paper, University of Maryland, 12 March 2015; Appendix. Filed by EOBC at the FCC. [See also FCC Comment Public Notice; EOBC Comment; EOBC Reply Comment; 3 July Filing Cramton,EOBC; Kagan Comment]
“Bidding and Prices in the AWS-3 Auction” (with Pacharasut Sujarittanonta), Working Paper, University of Maryland, May 2015. Filed by the Competitive Carriers Association. [Cover letter]
ISO New England, Docket Nos. ER14-1050-000, -001, Federal Energy Regulatory Commission, “Prepared Testimony of Peter Cramton on Behalf of ISO New England,” January 2014. Comments on ISO New England’s proposed Pay For Performance reforms to the Forward Capacity Market. [Complete ISO-NE Filing]
ISO New England, Docket Nos. ER14-1050-000, -001, Federal Energy Regulatory Commission, “Supplemental Prepared Testimony of Peter Cramton on Behalf of ISO New England,” February 2014. Comments on NEPOOL’s alternative proposal and critique of ISO New England’s proposed Pay For Performance reforms to the Forward Capacity Market.
“The Revenue Impact of Competition Policy in the FCC Incentive Auction,” December 2013. Comments on the revenue impact of spectrum-aggregation limits in the FCC’s incentive auction. On behalf of T-Mobile USA.
“The Rationale for Spectrum Limits and Their Impact on Auction Outcomes,” August 2013. Argues that well-crafted spectrum aggregation limits can increase competition both in the market for mobile broadband services and in the spectrum auctions in which they apply. On behalf of T-Mobile USA.
ISO New England and New England Power Pool, Docket No. ER12, Federal Energy Regulatory Commission, “Testimony of Peter Cramton,” April 2012. Examines the New England regulation market and proposes an alternative market design. For ISO New England. [Complete ISO-NE Filing]
Verizon Wireless spectrum transaction with SpectrumCo and Cox, Federal Communications Commission, WT Docket No. 12-4, “Supplemental Declaration of Peter Cramton.” March 2012. Supplemental declaration on the FCC’s spectrum screen used to evaluate spectrum transactions. On behalf of T-Mobile USA.
Verizon Wireless spectrum transaction with SpectrumCo and Cox, Federal Communications Commission, WT Docket No. 12-4, “Declaration of Peter Cramton.” February 2012. Declaration on the FCC’s spectrum screen used to evaluate spectrum transactions. On behalf of T-Mobile USA.
“700 MHz Device Flexibility Promotes Competition,” July 2010. Argues that the carrier-specific band plans proposed by AT&T and Verizon Wireless for the 700 MHz paired spectrum will undermine competition. On behalf of the Rural Cellular Association.
“Foreword to Ross Baldick’s ‘Single Clearing Price in Electricity Markets’,” Compete Coalition, www.competecoalition.com, February 2009. Argues that consumers and suppliers are better off with the clearing-price auction in electricity markets.
“Report on Key Design Elements of Auctions Under Australia’s Carbon Pollution Reduction Scheme,” Tradeslot Report to Australian Department of Climate Change, 26 October 2008. [Ch. 9 Auction Design, Australian White Paper] [Entire White Paper]
DC Energy, LLC v. HQ Energy Services (US) Inc., Docket No. EL07-67-000, Federal Energy Regulatory Commission, “Affidavit of Peter Cramton.” August 2007. Affidavit arguing that HQ manipulated the NYISO TCC and day-ahead energy markets. On behalf of DC Energy, LLC.
The People of the State of Illinois, et al., Docket No. EL07-47-000, Federal Energy Regulatory Commission, “Affidavit of Peter Cramton.” June 2007. Affidavit arguing that the Illinois auction for energy for small customers was a competitive auction. On behalf of J. Aron & Company and Morgan Stanley Capital Group Inc.
Australia National Emissions Trading Taskforce, “Possible Design for a Greenhouse Gas Emissions Trading System,” August 2007. [NETT Report]
700 MHz Auction, Federal Communications Commission, “Why Large Licenses are Best for the 700 MHz Spectrum Auction.” April 2007. On behalf of Verizon Wireless.
New York Independent System Operator, Docket No. ER07-360-000, Federal Energy Regulatory Commission, “Affidavit of Peter Cramton.” February 2007. Affidavit identifying manipulation of New York’s capacity market by KeySpan and the need for market monitoring and mitigation. On behalf of Consolidated Edison Company of New York.
United States vs. Mario Gabelli. Expert report showing the damages caused by Gabelli’s false claims in FCC spectrum auctions. The case was settled in June 2006. Gabelli paid $130 million in damages. On behalf of the United States.
Devon Power LLC, et al., Docket No. ER03-563-030, Federal Energy Regulatory Commission, “Affidavit of Peter Cramton,” March 2006. Affidavit in support of the settlement agreement defining the New England Forward Capacity Market. For ISO New England.
AWS Auction, Federal Communications Commission, “Declaration of Peter Cramton.” February 2006. Declaration on various auction rules for the AWS auction. On behalf of T-Mobile US.
AWS Auction, Federal Communications Commission, “Reply Declaration of Peter Cramton.” February 2006. Reply declaration on various auction rules for the AWS auction. On behalf of T-Mobile US.
AWS Auction, Federal Communications Commission, “Ex Parte of Peter Cramton.” March 2006. Ex parte communication on various auction rules for the AWS auction. On behalf of T-Mobile US.
MDI retained as Auction Manager for virtual divestiture of 2,600 MW of nuclear energy as part of the proposed merger between Exelon and PSEG. August 2005.
US-Canada Softwood Lumber Trade Dispute, “Competitive Auction Markets in British Columbia” (with Susan Athey). December 2005. White Paper, Market Design Inc. On behalf of British Columbia Ministry of Forests.
US-Canada Softwood Lumber Trade Dispute, “Comments on DOC Notice of Preliminary Results of Countervailing Duty Review” (with Susan Athey). July 2005. White Paper, Market Design Inc. On behalf of British Columbia Ministry of Forests.
US-Canada Softwood Lumber Trade Dispute, “Competitive Auction Markets in British Columbia” (with Susan Athey). February 2004. White Paper, Market Design Inc. On behalf of British Columbia Ministry of Forests.
US-Canada Softwood Lumber Trade Dispute, “Upset Pricing in Auction Markets: An Overview” (with Susan Athey and Allan Ingraham). March 2003. White Paper, Market Design Inc. On behalf of British Columbia Ministry of Forests.
US-Canada Softwood Lumber Trade Dispute, “An Analysis of Auction Volume and Market Competition for the Coastal Forest Regions in British Columbia” (with Susan Athey and Allan Ingraham). September 2002. White Paper, Market Design Inc. On behalf of British Columbia Ministry of Forests.
US-Canada Softwood Lumber Trade Dispute, “Reserve Prices, Stumpage Fees, and Efficiency” (with Susan Athey and Allan Ingraham). September 2002. White Paper, Market Design Inc. On behalf of British Columbia Ministry of Forests.
US-Canada Softwood Lumber Trade Dispute, “Auction-Based Timber Pricing and Complementary Market Reforms in British Columbia” (with Susan Athey and Allan Ingraham). March 2002. White Paper, Market Design Inc. On behalf of British Columbia Ministry of Forests.
US-Canada Softwood Lumber Trade Dispute, “Setting the Upset Price in British Columbia Timber Auctions” (with Susan Athey and Allan Ingraham). September 2002. White Paper, Market Design Inc. On behalf of British Columbia Ministry of Forests.
US-Canada Softwood Lumber Trade Dispute, “Auctioning Timber to Maximize Revenues in British Columbia” (with Susan Athey and Allan Ingraham). June 2002. White Paper, Market Design Inc. On behalf of British Columbia Ministry of Forests.
US-Canada Softwood Lumber Trade Dispute, “A Comparison of Equation-Based and Parity Pricing of Stumpage Fees for British Columbia Timber Under Long-Term Tenures” (with Susan Athey and Allan Ingraham). April 2002. White Paper, Market Design Inc. On behalf of British Columbia Ministry of Forests.
US-Canada Softwood Lumber Trade Dispute, “Testing for Anti-Competitive Bidding in Auction Markets” (with Susan Athey and Allan Ingraham). March 2002. White Paper, Market Design Inc. On behalf of British Columbia Ministry of Forests.
New England Power Pool, Federal Energy Regulatory Commission, “Review of the Proposed Reserve Markets in New England,” (with Hung-po Chao and Robert Wilson) Market Design Inc., January 2005.
U.S. Department of Defense, “Estimating Auction Revenues for the Proposed FCC Sale of 3G Spectrum for Broadband and Advanced Wireless Services,” Criterion Auctions, December 2003.
Expert Report of Peter Cramton, D. Lamar Deloach, et al. v. Philip Morris, Inc., et al., Civil Action No. 00-CV-1253, United States District Court, Middle District of North Carolina. October 2003. For R.J. Reynolds. Concluded that R.J. Reynolds did not collude in U.S. tobacco auctions during the class period.
Supplier Behavior in California Energy Crisis, Federal Energy Regulatory Commission, Docket Nos. EL00-95-075 and EL00-98-063, “Competitive Bidding Behavior in Uniform-Price Auction Markets,” March 2003. For Duke Energy.
Supplier Behavior in California Energy Crisis, Federal Energy Regulatory Commission, Docket Nos. EL00-95-075 and EL00-98-063, “Rebuttal Addendum: Assessment of Submissions of the California Parties,” March 2003. For Duke Energy.
U.S. Department of Transportation, Docket Nos. FAA–2001–9852, FAA–2001–9854, “Comments on Alternative Policy Options for Managing Capacity and Mitigating Congestion and Delay at LaGuardia Airport,” June 2002. Recommending auctions to manage congestion at LaGuardia.
Verizon Wireless Petition for Permanent Forbearance from CMRS Number Portability, Federal Communications Commission, WT Docket No. 01-184, “Declaration of Peter Cramton,” February 2002. Comments in support of wireless number portability. For Leap Wireless.
ISO New England, Docket No. ER02, Federal Energy Regulatory Commission, “Affidavit of Peter Cramton,” February 2002. Comments on proposed changes to how the energy clearing price is calculated. For ISO New England.
2000 Biennial Regulatory Review Spectrum Aggregation Limits For Commercial Mobile Radio Services, WT Docket No. 01-14, Federal Communications Commission, “Ex Parte Declaration of Peter Cramton,” October 2001. Further comments on the CMRS spectrum cap. For Leap Wireless.
ISO New England, Docket No. EL00-62-015, Federal Energy Regulatory Commission, “Affidavit of Peter Cramton,” June 2001. Comment on modifications to installed capability market. For ISO New England.
2000 Biennial Regulatory Review Spectrum Aggregation Limits For Commercial Mobile Radio Services, WT Docket No. 01-14, Federal Communications Commission, “Declaration of Peter Cramton,” April 2001. Comments on the CMRS spectrum cap. For Leap Wireless.
C and F Block Broadband PCS Auction, Federal Communications Commission, “Declaration of Peter Cramton,” March 2001. Comments on the impact of fronts in the C and F Block Broadband PCS auction.
“Lessons Learned from the UK 3G Spectrum Auction,” May 2001. An export report on the UK 3G Spectrum Auction. For UK National Audit Office.
“Market Effectiveness Assessment,” (with Jeffrey Lien) May 2001. An expert report assessing the effectiveness of the electricity restructuring plan in Ontario. For Transcanada.
First Millennium Communications, Inc. and Barbara Laurence vs. Entravision Communications Company, No. 1420009074, “Expert Report of Peter Cramton,” May 2001. Comment on the value of clearing rights for broadcast television stations 59 to 69. For First Millennium Communications and Barbara Laurence.
Pacific Communications vs. American Wireless, Superior Court of Fulton County, Georgia, No. 2000CV20099, “Reply Declaration of Peter Cramton,” April 2001. Further comments on the impact of a delayed sale of spectrum license by Pacific Communication. For American Wireless.
Pacific Communications vs. American Wireless, Superior Court of Fulton County, Georgia, No. 2000CV20099, “Expert Affidavit of Peter Cramton,” February 2001. Comments on the impact of a delayed sale of spectrum license by Pacific Communication. For American Wireless.
“Lessons from the United States Spectrum Auctions,” Prepared Testimony of Peter Cramton before the United States Senate Budget Committee, February 2000.
New England Power Pool, Docket No. EL00-83-000, Federal Energy Regulatory Commission, “Affidavit of Peter Cramton,” July 2000. Comment on deficiency charge in installed capability market. For ISO New England.
NSTAR Services Company vs. New England Power Pool, Docket No. EL00-83-000, Federal Energy Regulatory Commission, “Affidavit of Peter Cramton,” June 2000. Further comments on energy price cap as a response to design flaws. For ISO New England.
NSTAR Services Company vs. New England Power Pool, Docket No. EL00-83-000, Federal Energy Regulatory Commission, “Affidavit of Peter Cramton,” June 2000. Comments on energy price cap as a response to design flaws. For ISO New England.
New England Power Pool, Docket No. EL00-62-000; ER00-2052-000, Federal Energy Regulatory Commission, “Affidavit of Peter Cramton,” May 2000. Comments on installed capability market. For ISO New England.
New England Power Pool, Docket No. ER00-2016-000, Federal Energy Regulatory Commission, “Affidavit of Peter Cramton,” April 2000. Comments on one-part vs. three-part bidding in energy market. For ISO New England.
New England Power Pool, Docket No. ER99-4536-000, Federal Energy Regulatory Commission, “Affidavit of Peter Cramton,” October 1999. Summary of review of reserves and operable capability markets. For ISO New England.
New England Power Pool, Docket No. OA97-237-000, Federal Energy Regulatory Commission, “Affidavit of Peter Cramton,” October 1998. Reply to comments on review of rules. For ISO New England.
New England Power Pool, Docket No. OA97-237-000, Federal Energy Regulatory Commission, “A Review of ISO New England’s Proposed Market Rules,” (with Robert Wilson), September 1998. For ISO New England.
Best Digital vs. U.S. West, American Arbitration Association, Denver Office, No. 77 181 00204 97, “Expert Report of Peter C. Cramton,” September 1998. Determine the value of spectrum licenses won by Best Digital in the C-block Broadband PCS auction. For Best Digital.
NextWave vs. Antigone and Devco, Petition to Deny License Proceedings, Federal Communications Commission, “Statement on the Effect of NextWave’s Participation in the C-block Auction on Antigone and Devco,” March 1997. For Antigone and Devco.
NextWave vs. Antigone and Devco, Petition to Deny License Proceedings, Federal Communications Commission, “Reply Statement on the Effect of NextWave’s Participation in the C-block Auction on Antigone and Devco,” April 1997. For Antigone and Devco.