The Rural Wireless Association applauds Commissioner Michael O’Rielly and Federal Communications Commission for considering county-based licenses for the Priority Access Licenses in the 3.5 GHz Citizens Broadband Radio Service. The choice of counties plus the inclusion of a rural service provider bidding credit acknowledges the needs and realities of wireless broadband customers in rural America and will ensure that PALs remain affordable and accessible to the small, rural providers that directly serve these customers. Throughout this complex proceeding, RWA has consistently voiced support for small license areas including counties, and it proudly joined forces with the broad-based CBRS Coalition to ensure that CBRS PALs are sufficiently right-sized so that all Americans can benefit from the innovations that band users will offer. Allowing the more urban counties to be aggregated in package bids only within Metropolitan Statistical Areas should strike an appropriate balance between nationwide and small, rural providers. RWA looks forward to working with FCC commissioners and staff on the implementation of these and other CBRS changes that the FCC will take up later this month.