​NRECA and the National Rural Telecommunications Cooperative (NRTC) filed joint reply comments in the Federal Communications Commission's (FCC) proceeding on the Citizens Broadband Radio Service (CBRS or 3.5 GHz band) spectrum. NRTC and NRECA support rule changes that would encourage innovation and incentivize service in rural America. In particular, the comments support smaller geographic areas for Priority Access Licenses (PALs), recommending a mix of county boundaries for five PALs and census tract boundaries for two PALs. Auctioning the spectrum by licenses any larger would discourage participation by smaller entities and would not promote service in rural areas. FULL COMMENTS