We get it. The Pai Commission does not like determining spectrum policy through waivers. So, it comes as no surprise to the Enterprise Wireless Alliance (EWA) when we attempt to accom-modate business enterprise spectrum needs by accessing channels that have remained unassigned for years or decades through waiver requests, that our efforts are denied and are accompanied with the hopeful suggestion that we should seek a solution through formal rule making pro-ceedings. We understand the wisdom of adopting policy through formal processes, but that recommendation contradicts Chairman Pai’s other goal to have the Commission conform with Section 7 of the Communications Act, which mandates that the Federal Communications Commission (FCC) will determine within one year whether proposals for new technologies or services are in the public interest. One year? Imagine the possibilities.  

Both waiver requests and formal rulemakings should have their place, and both are viable al-ternatives for EWA as it pursues spectrum solutions for business enterprises. Waivers provide relief in special circumstances and are not intended to establish policy. Changes in the rules through formal petitions for rule making should be considered when advancements in tech-nology and spectrum efficiency will result. EWA will still pursue waivers if that is the only rea-sonable course of action available to us on behalf of its customers.