EWA filed Comments in response to a Notice of Inquiry (NOI) “designed to advance its understanding of non-federal spectrum usage and take advantage of new data sources, methods, and technologies to do so in a cost-effective, accurate, scalable, and actionable manner.” EWA’s comments focused on the fact that all private systems, not just public safety, and utilities, have very different operating characteristics than commercial, consumer-oriented networks and that the same metrics cannot be used when evaluating spectrum utilization. EWA also noted that commercial wireless networks meet the communications needs of consumers and certain internal business requirements.  Virtually every worker in the nation has a cellphone and likely uses it for some business as well as personal purposes.  It may be appropriate to focus on factors such as throughput, servable population, density of end-user devices and/or the capacity of the system to accommodate dense usage when evaluating spectrum utilization on commercial networks. But public safety, utility, and myriad other business enterprises also invest in the deployment and maintenance of private, internal systems designed and built to their specifications and operated under their exclusive control. They make these investments for security, reliability, privacy, employee safety, operational effectiveness, competitive goals, and other critical objectives.