On October 28, 2019 NRECA filed comments opposing the Commission's proposal to allow bidders to use large Cellular Market Area (CMA) level licenses in some areas rather than the smaller county level bidding as the FCC originally proposed nationwide.  NRECA believes moving to larger bidding areas in some areas will result in reduced opportunities for entities, especially small electric cooperatives, seeking to serve counties in exurban areas at the edge of many CMAs and may prejudice the participation of certain parties in the auction.