Thailand’s Upcoming Telecom Auction – Consultants Out of Touch with Realities
- December 18, 2024
- Posted by: Allan Rasmussen
- Categories: MVNA-MVNE-MVNO, Thai Telecom

Presentation of Thailand’s Multiband Auction Design by Cramton Associates LLC.
A presentation by Cramton Associates LLC, led by Peter Cramton, was meant to shed light on Thailand’s upcoming telecom auction. However, it raised more questions than it answered.
While the consulting firm showcased expertise in auction mechanics and mathematical modelling, their understanding of Thailand’s telecom sector was naive and alarmingly superficial, undermining the credibility of their approach.
A Misaligned Expertise
The team from Forward Market Design LLC or Cramton Associates LLC — not sure which company it is, as two slides appears with two different names — appeared well-versed in auction design principles within the energy sector.
However, their lack of experience in telecommunications was evident. The only individual with relevant telecom expertise, Erik Bohlin, was not present and therefore raised the question, if he is merely serving as a nominal advisor to satisfy academic requirements in NBTC’s procurement process.
The reliance on an unproven, cross-sectoral application of auction theory raises significant concerns about using Thailand and the future of its telecom market, as a lab-rat.
The Thailand Multiband Auction Design presentation (PDF)
Video from the “workshop” and the presentation above (YouTube) – You can also see the video below this article.
Fundamental Gaps in Local Knowledge
Throughout the presentation, it became clear that the team in charge of Thailand’s upcoming 850MHz, 2100MHz and 2300MHz spectrum auction, lacked an understanding of the Thai telecom market’s complexities.
For example, when questioned about specific examples or case studies where their proposed theory had been successfully implemented in telecommunications, the responses were vague and unconvincing.
References to energy sector examples, such as demand-side management strategies, only highlighted their disconnect from the realities of telecom operations in Thailand. This lack of contextual knowledge undermines confidence in their ability to address the country’s specific challenges.
Cramton further contended that Universal Service Obligations (USO) should not be incorporated into spectrum licenses or fees. He argued that USO was a waste of money and a relic of the past, suited to an era with landline telephones and elderly users. This assertion, also highlights another significant misunderstanding of the Thai telecommunications landscape.
A substantial portion of the Thai population, approximately one-third, still lacks access to or cannot afford mobile telephony. In fact, USO projects are playing a crucial role in expanding internet connectivity to rural areas and just last month, providing SIM cards to individuals with disabilities for a specific period. Interestingly, using the spectrum of NT which is the one they have to give back now to this auction!
These initiatives underscore the ongoing relevance of USO in addressing the digital divide and promoting inclusive access to telecommunications services in Thailand.
A glaring omission with Cramton’s announcement that the auction would be restricted to AIS and TRUE only, with no room for new mobile operators, was when Cramton emphasized “we do want competition on the margin from sources like satellite, fixed broadband and Wi-Fi“, conveniently overlooking the fact that these “competitors” are subsidiaries of AIS and TRUE Corp.
The TIMO Theory: Unproven and Impractical
One of the most controversial aspects of the proposal was the suggestion of introducing TIMO (Thailand Independent Market Operator) an organisation conducting forward and spot markets for wholesale communications, regulated by the NBTC with a board by the NBTC and representatives of the operators. (See the info about TIMO from page 96 in the presentation)
While the likes of TIMO might have relevance in energy markets, its applicability to telecommunications remains untested. In energy markets, consumers may adjust their usage based on real-time pricing—such as waiting until off-peak hours to run their laundry in their washing machine. However, this approach does not translate well to telecom markets in 2024, where competition and resource allocation are driven by entirely different dynamics.
As this will end up at the end-users, I don’t see the idea of asking Telemedicine users postpone their illness —or ask enterprise customers to postpone answering emails and work — until the same time they put clothes in their washing machine at 03:00 night.
The claim that TIMO would foster competition in Thailand’s telecom sector is highly dubious. Implementing such a system would require substantial regulatory and operational changes, potentially leading to years of stagnation before its ineffectiveness becomes evident.
Given Thailand’s already prolonged delay in establishing a viable MVNO (Mobile Virtual Network Operator) ecosystem, introducing TIMO risks further regression rather than progress.
It is evident that TIMO remains a theoretical concept in telecommunications.

Another red flag is raised when Peter Cramton tries to validate and endorse “TIMO” by writing: “The independent market operator [TIMO] is well thought out. Our paper recently appeared in Telecommunication Policy”
What he does not mention, is that the Editor in Chief at the Telecommunication Policy, is part of the Cramton Associates/ Forward Market Design LLC group, that is proposing TIMO = Eric Bohlin.
TIMO: A Trojan Horse Designed to Delay, Not Solve, Thailand's Telecom Crisis
The NBTC has failed to enforce existing MVNO rules and policies for over a decade. Cramton Associates/Forward Market Design’s solution, establishing a new bureaucratic entity, ironically (or purposely?) relies on the very enforcement mechanism the NBTC has consistently neglected.
Cramton’s proposal of introducing an entity called TIMO (“Thailand Independent Market Operator”), is a classic case of kicking the can down the road. It provides the NBTC and the telecom operators AIS and TRUE exactly what they are looking for right now—a way to further extend their negligence of duty, because their option to continue to neglect enforcement on the existing policies was running out. i.e.:
- The MVNOs on NT have to get access at AIS or TRUE, as the remaining 700MHz spectrum capacity at NT is not enough.
- TRUE has been talking with MVNA and MVNOs over the last four months, anticipating that NBTC would require contracts with X MVNAs/MVNOs before TRUE could join the auction.
- Several MVNA/MVNOs have requested the NBTC to intervene, as AIS/TRUE has not replied to their Request for Access.
- MVNA/MVNOs are ready to file dispute cases against AIS/TRUE, due to AIS/TRUE not adhering to the Request for Access.
- MVNA/MVNOs are also ready to petition the NBTC for negligence of duty if they fail to comply.
- The Senate ICT Committee has openly criticized NBTC’s lack of enforcement and are seeking to remove its Chair.
- Consumer organizations have filed petitions at the Courts accusing NBTC of neglecting its duties.
- Thailand’s international commitments, including FTA negotiations and its pursuit of OECD membership, demand a telecom sector characterized by open market competition. The OECD explicitly supports a competitive landscape where MVNOs can thrive, while expressing concern over excessive market consolidation
- The NBTC “Superboard” which is monitoring NBTC’s work (or lack of) has deemed the agency’s performance a failure.
- Public frustration is escalating with the lack of competition and increased pricing in the telecom sector, flooding social media with demands to disband the NBTC board. Some are even threatening extreme actions, including “hanging themselves” in front of the operator’s headquarters.
TIMO – A get-out-of-jail-free card
Instead of holding AIS, TRUE and the NBTC accountable, Cramton is handing them a get-out-of-jail-free card. TIMO is a bureaucratic monstrosity designed to consume years with internal deliberations and endless committee meetings.
In the comments field to the video from the NBTC workshop, Cramton himself writes: “TIMO will take time to establish. It can be designed and implemented in Thailand in two years”
This deliberate delay allows the NBTC and the telecom giants to maintain the status quo while evading their responsibilities.
That way the NBTC can say continue to say “but we are actively working on… “, as they done for a decade already, and AIS/TRUE can say… “we are always open for opportunities and supporting the country but we have to wait for the NBTC”.
You just have to ask yourself the simple question; Why the heck is TIMO part of a consultation proposal for a spectrum auction?
TIMO is a distraction, a Trojan horse designed to delay, deceive, and ultimately preserve the stranglehold of AIS and TRUE.
Overlooking Regulatory Realities in Thailand
A key point of contention was the assertion that existing regulations — such as requiring major operators like AIS and TRUE to allocate a percentage of their capacity to MVNOs — were sufficient to foster competition. History suggests otherwise. For over a decade, such regulations have been in place without yielding any single results.
Without proactive enforcement and pre-auction agreements ensuring MVNO participation, these measures will not succeed.
When pressed on the TIMO theory, Cramton’s responses were unconvincing. Statements like “this has worked in the US” were not backed by concrete examples.
His suggestion that NBTC and major operators could quickly gain the necessary expertise in MVNO operations was equally unpersuasive, given their track record of inaction for more than a decade.
Questionable Transparency and Intent
Cramton’s reluctance to mandate MVNO agreements before the auction and his dismissal of opening the auction to new entrants raise eyebrows. These omissions seem counterproductive to fostering competition and suggest a lack of alignment with Thailand’s long-term telecom objectives.
Additionally, speculation this morning among some analysts was about potential conflicts of interest — given the NBTC’s selection of an energy-focused consulting team and the ownership ties of AIS (Gulf Energy) — only adds to controversy, in a time where TRUE has to start showing better results almost two years after the merger, and its recent letter to the NBTC asking the regulator to lift some of the merger conditions (it still hasn’t lived up to).
Adding to the concerns was Cramton’s suggestion that Thailand should allow the auction to be conducted online so that executives could participate remotely instead of being confined to a controlled environment.
He remarked that only Germany and Thailand still used such “old-fashioned” measures. His rationale — that regulations against collusion would prevent AIS and TRUE from coordinating unfairly — was unconvincing, given the historical lack of enforcement in the sector.
Similarly, his argument that requiring AIS and TRUE to allocate 15% of their capacity to MVNOs as a license condition would ensure compliance seemed disconnected from reality. This provision has been part of their license terms for over a decade, yet no MVNO presence has emerged on the two.
When questioned about this contradiction, Cramton deflected, reiterating that adherence to the law would resolve the issue. This response failed to address the systemic regulatory failures that have plagued Thailand’s telecom market for years.
Cramton also argued that close ties between telecom operators and regulators are not unique to Thailand, stating that such relationships exist in almost every market. He maintained that regulations are in place globally to prevent monopolistic behavior. However, the setting of his remarks — a hotel owned by a company holding a monopoly on tax-free duty sales in Thailand — seemed ironic.
This juxtaposition only served to highlight the challenges of implementing effective regulatory measures in environments with entrenched monopolies.

NBTC board members and high-ranking officials, such as Saran Boonbaichaipruk, Sompop Phuriwikraipong, Thanapan Harijaroen, and Suttisak Tantayothin, were in attendance at the Spectrum Auction Workshop.
However, when the agenda and discussion shifted to “Competition policy” and introducing competition to the Thai telecom market, a notable absence of these high-ranking officials was observed at the “Chef’s table”.
Lack of Private Networks Highlights Bias Toward AIS and TRUE's Dominance
Adding further to concerns was the noticeable omission of any mention of Private Networks both at the workshop and on the presentation slides.
This omission is particularly striking, as it highlights how narrowly focused the consultancy firm’s approach is, seemingly prioritizing the interests of Thailand’s two largest telecom players, AIS and TRUE, while disregarding the evolving importance of private networks in modern telecom markets.
Private networks, which are becoming a critical component of telecom discussions globally, were conspicuously absent from the presentation, despite their growing relevance in areas like enterprise connectivity, 5G deployment, and security.
By overlooking this key aspect, the consultancy’s approach appears to be overly skewed toward preserving the existing duopoly, rather than fostering a more diverse and competitive market. This omission further emphasizes the lack of balance and comprehensiveness in the consultancy’s analysis, raising serious questions about its ability to offer a truly forward-thinking, inclusive strategy for Thailand’s telecom sector.
Conclusion: A Misstep in Telecom Strategy
Cramton Associates LLC’s presentation exposed significant shortcomings in their approach to Thailand’s telecom auction.
Their reliance on unproven theories, lack of local market knowledge, and failure to address regulatory enforcement highlight the risks of adopting their recommendations. For Thailand to advance its telecom sector, a more grounded, context-specific strategy is needed—one that prioritizes practical solutions over theoretical experimentation.
If you are looking to solve the problems, the right solution is crystal clear: enforce the existing rules. Hold AIS, TRUE and NBTC accountable. Break the duopoly that has suffocated innovation, the economy and exploited consumers for far too long. The next 15 years of Thailand’s digital economy depends on it.
Video: A Study on Designing Thailand's IMT Multiband Auction
Invitation to Public Hearing
The NBTC Office would like to invite stakeholders and the general public to express their opinions and suggestions on the NBTC (draft) announcements for the criteria and methods for granting permission to use frequencies for mobile telecommunications services on 850 MHz, 1500 MHz, 1800 MHz, 2100 MHz, 2300 MHz and 26 GHz, as well as the proposal of TIMO (Thailand Independent Market Operator)
The opinion forms can be submitted from 20 January 2025 until 20 February 2025 by 16:30 p.m. through the following channels:
1) via e-mail: telecompolicy@nbtc.go.th
2) in person or by registered mail at the NBTC Office (Office of Academic and Telecommunications Resource Management)
The meeting to listen to public opinions on the (draft) announcements mentioned above is scheduled for Thursday, February 6, 2025, from 9:00 a.m. to 17:00 p.m., at the Phra Phrom Meeting Room, 3rd Floor, Aswin Grand Convention Hotel, Bangkok.
You can register to attend the public opinions meeting via the website by February 4, 2025.
10 Examples of Problems with Cramton's Auction Recommendations
All slides from Cramton Associates LLC / Forward Market Design LLC recommendations for “Thailand Multiband Auction Design” to the NBTC.
1. Cramton says the NBTC shall hold the spectrum auction online so AIS and TRUE executives can sit in their HQs instead of on-site, in a controlled environment. No need to worry about AIS/TRUE coordinating he said, because there are already regulations against collusion.
After the merger of TRUE/DTAC both AIS and TRUE has somehow magically changed their packages and pricing to be the same. The also stopped providing “unlimited” offers at the same time.
Neither AIS, DTAC or TRUE has ever accepted any MVNOs on to their network.
2. Cramton argues: “AIS and TRUE cannot communicate with each other about its bidding strategy …from the initial application deadline to the end of the assignment stage”. However, they can now and all the way up until the application deadline.
In Thailand’s first auction in 2012, Advanced Info Service (AIS) made a bid of THB 14.63 billion in total, giving it first pick of the spectrum offered, while Total Access (DTAC) and TRUE both offered cumulative bids of THB 13.5 billion, the minimum price. The license prices at close to the minimum level demonstrated there was absolutely no competition in the auction process.
The spectrum in 2012 was divided into nine slots. The nine slots were split into three sets and three suppliers joined the bidding.
3. Cramton does not mention that TRUE will have an advantage in securing the 2300MHz, as DTAC (now TRUE), is the one who rolled out the base stations and radios on the 2300 MHz for National Telecom (NT) which is the spectrum being auctioned. TRUE has also been in control of NT’s 850MHz.
Likewise, Cramton Associates does not mention that AIS will have a similar advantage in securing the 2100MHz, as AIS is the one who has provided base stations and radios on the 2100 MHz for NT.
The starting bid is expected to be around only THB 16 billion for the 30 MHz 2100 MHz spectrum – only 3 billion more than it was sold for in 2012 – and 30 THB billion for the 60 MHz slot on the 2300 MHz spectrum.
According to Kasikorn Securities, the auction will not result in new investments but will instead reduce AIS and TRUE’s operating costs, resulting in higher earnings per share in 2025. The cost savings are driven by;
1. AIS and TRUE will bid only for the spectrum they need,
2. There will be less competition,
3. The final auction price will be close to the reserve price.
In addition, as mentioned above – Both AIS and TRUE already have the infrastructure in place for 2100 and 2300 MHz.
4. Cramton tells NBTC, it is undesirable to attempt to introduce a third network operator, besides AIS and TRUE in Thailand. So no chance of competition in Thailand the next 15 years. It will only be two networks = AIS and TRUE.
Single Point of Failure: Relying solely on AIS and TRUE as the only two network providers in Thailand means that any significant issue, affecting either network (such as technical failures, natural disasters, or cyberattacks) will have widespread consequences and affect millions of users. Businesses, hospitals, emergency services, public services, law enforcement and other organizations across the country, will face disruptions.
Case in point: The outage at Australia’s telecom operator Optus (Singtel) in November 2023, which left 10 million Australians (40% of the population), without internet or phone services. The outage impacted business, payment, logistic and health systems and raised questions about the country’s core infrastructure.
5. For more than a decade, AIS and TRUE has had to provide minimum 10% capacity their capacity on all spectra to MVNOs – They haven’t done so.
Making it 15% or even 99% does not help. Instead the NBTC should say AIS/TRUE can only take part in the auction, if they have signed wholesale contracts with X numbers of MVNA/MVNO first.
6. Cramton says “Stringent buildout and coverage requirements are not included” which means urban and rural areas in Thailand will become second class citizens, as neither AIS or TRUE will care about those areas to make fast return of investment.
Any MVNOs will also not be able to service those areas because of that. This conflicts with the NBTC’s policies about “One Region one MVNO”
7. Cramton theory about adding, yet another unproven bureaucratic unit (TIMO), which first has to be approved, regulated, set up, funded, and organized – will further delay the introduction of competition in the Thai mobile service market by years.
8. Thailand Independent Market Operator (TIMO) – When a national regulatory authority is no longer a regulator but a player.
TIMO will be regulated and operated by the NBTC, a government agency that lacks the knowledge on MVNA, MVNE, MVNO, and hasn’t been able to create an environment for such in more than a decade.
The same agency giving total duopoly power to AIS and TRUE. The same agency who can’t make decision because of internal conflicts in their board and with the NBTC office. The same agency that has between 40-70 outstanding agenda items that they keep postponing because the NBTC board can’t cooperate.
9. Forward and spot markets is not suitable at all for telecommunications. There has been trials but non of them has moved into commercial launch, as there is neither demand nor use for it. Using it for wholesale makes it even worse.
10. The example on pricing / time / location from Cramton shows just how much they lack knowledge about telecom and the Thai market.