; constitutionally vested congressional authority to regulate commerce and govern activities with Indian Tribes, which is distinct and separate from executive and judicial branch powers. (8) The Federal Government’s trust responsibility with Indian Tribes extends to all governmental branches requiring the United States to uphold its fiduciary duties of care and loyalty, to make trust property income productive, to enforce reasonable claims on behalf of Native Americans, and to take affirmative action to preserve trust property, for the benefit of American Indians and Alaska Natives, and Native Hawaiians as part of this Federal-Tribal relationship and Tribal self-governance. (9) The Federal Communications Commission (FCC) has acknowledged this fiduciary responsibility to Native nations and has further recognized the Commission’s own responsibility to promote their self-sufficiency and economic development on Tribal lands. (10) In 2018, a Government Accountability Office (GAO) report noted that numerous Tribal entities, associations, and academic groups consider spectrum as a natural resource that should be managed by Tribes. FCC officials responded that, spectrum is not considered a reserved right under treaties with Indian tribes, as it is not explicitly stated . (11) The first United States treaty with an American Indian Tribe was ratified in 1778, over 240 years ago, and Indian treaty-making ended in 1871, prior to the development of spectrum, and adoption of the existing regime for licensing and regulating spectrum access. (12) Further, a 2020 GAO report repeatedly stated that spectrum is a finite natural resource used to provide a variety of communication services to governmental entities. (13) However, with the exception of the FCC’s efforts to allocate a severely limited bandwidth of temporary spectrum authority to select Tribal applicants during the COVID–19 crisis, it failed to grant numerous emergency requests from Congress, Indian Tribes, and Native Hawaiian organizations to extend the 2.5 GHz Rural