"It is submitted that any SUC which is higher than existing rates will not allow the government to move to a uniform rate regime as there will be no incentive for existing spectrum holders to "migrate" to a higher rate regime. Differential SUC for different quanta/bands of spectrum will give rise to arbitrage opportunities and also result in a regime that is impossible to monitor and enforce," said Rajan S Mathews, director general of COAI, in the letter.
COAI has said that the government should reduce overall reserve price. Telecom regulatory authority of India (TRAI) has recommended a reserve price of R18,000 cr for 5 Mhz of spectrum in the 1800 MHz band.