On October 28 the Rural Wireless Association filed comments in the 3.5 GHz band auction proceeding. In its comments, RWA notes that since its adoption of county-based bidding, the Commission, in an attempt to benefit large nationwide carriers seeking to aggregate counties in large metropolitan areas, has proposed to allow package bidding at the Cellular Market Area level for the top 172 CMAs that are (1) classified as Metropolitan Statistical Areas and (2) include multiple counties. Though this proposal may appear to limit package bidding to large metropolitan areas, a closer examination of the 172 CMAs classified as MSAs reveals that numerous rural counties—including counties that RWA members serve—would be tied to pricier metropolitan package bid areas for which large and nationwide carriers would be competing, and therefore effectively unavailable to small and rural bidders. To avoid this outcome, which would not be consistent with Section 309(j) of the Act whereby licenses are disseminated among a “wide variety of applicants, including small businesses [and] rural telephone companies,” the Commission should prohibit package bidding. If, however, the Commission remains determined to accommodate bidders that are more inclined to bid on aggregated county groupings than a single county, then RWA believes the Commission’s current proposal of permitting package bidding on the top 172 CMAs that include more than one county should not be adopted as is and rural counties should be carved out of the top 172 CMAs. RWA lists numerous examples of rural counties that would be packaged with large urban areas if the proposal is adopted. If allowed to be packaged with the urban areas, history has shown these rural areas will go unserved as the secondary market does not work for low population counties to be later carved out and sold to those rural providers interested in serving them.