In joint comments, NTCA proposed county-by-county licensing for 3.45 GHz in order to allow small businesses the opportunity to acquire licenses in this auction. NTCA highlighted the significant number of winning bidders in the Citizens Band Radio Service (CBRS) Priority Access License (PAL) auction, which awarded licenses on a county-by-county basis.
Facilitating Shared Use in the 3100-3550 MHz Band, WT Docket No. 19-348