EWA has filed Reply Comments in the proceeding on Partitioning, Disaggregation, and Leasing of Spectrum that endorse both the demand-based (zones) and the use or share buildout alternatives proposed by the Federal Communications Commission (FCC) with a provision for returning licensed areas outside the zones to the FCC without penalty. EWA reaffirmed its position that the FCC should not define the core usage or expansion zones or specify a minimum signal level for the core usage area and refuted the Rural Wireless Association’s (RWA) recommendation that the FCC do so. RWA’s position assumes that all geographic licenses could be used for broadband, which is not the case, and would prescribe requirements that this proceeding is intended to reject for private enterprise entities. EWA also disagreed with CTIA’s recommendation that the alternative criteria should be available automatically for all wireless licensees, and that network slicing provides identical capabilities to those of a private wireless network.