Plum makes the case that it is the public interest for the 3G spectrum licences at 2.1 GHz to be reassigned to the incumbent operators.  Plum argues that the alternative policy of taking back and re-auctioning some of the 3G spectrum will result in substantial disruption costs, reduce service quality and have no offsetting benefit.

Plum also argues that the proposed spectrum utilisation fees are too high.

The link to the document can be found here.