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English During the last two decades there has been an increasing amount of attention within policy studies to ‘lesson-drawing’ – a process through which governmental jurisdictions formulate policy by learning from the experiences of political actors in other times and places. While a substantial body of theoretical literature has been generated on the topic, insufficient attention has been paid to issues of ‘fungibility’ or adaptability of lessons from one context to another. The purpose of this article is to begin to fill in this gap in the literature by adapting and testing several fungibility hypotheses posited by Rose (1993) against a case study of US telephone rate regulation.

In 1993, Congress authorized the FCC to use competitive bid auctions for the licensing of electromagnetic spectrum. To many members of the communications policy community, this policy change was decades overdue. Why did it take Congress so long to authorize spectrum auctions? Economist Thomas Hazlett has argued that policy gridlock resulting from an enduring political bargain between Congress and the broadcast industry prevented spectrum auctions from being seriously considered for decades. In this article, however, it is argued that the decision to authorize spectrum auctions is best understood when viewed through the literature on policy learning and epistemic communities. An explanation based in this body of literature posits that policy change becomes possible when a new worldview or ''policy epistemology'' frames the terms of debate in a manner that causes political actors to consider new alternatives.