EWA filed Comments on February 28, 2022, in response to the Federal Communications Commission's (FCC) Notice of Proposed Rulemaking intended to “further Congressional goals of diversifying access to spectrum and promoting service to rural areas…” In its comments, EWA supported proposals to provide incentives for licensees to partition, disaggregate, and/or lease unused spectrum to small carriers, rural carriers, and Tribal Nations. Incentives could include license term and construction extensions as well as alternate benchmarks for rural-focused transactions. EWA also urged the FCC to adopt a different standard for private enterprise entities as these companies are responsible for most of the economic activity in the nation. They rely on private wireless networks that may be in areas or have restrictions that make commercial service not a viable option. In addition, EWA requested that the FCC to modify its rules to permit leasing of exclusive-use Part 90 UHF and VHF licenses, just as exclusive T-Band channels are available for lease.