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                        February 5, 1997
                                                        DA 97-268

                                      Released:  February 5, 1997

Peter H. Feinberg, Esquire
Dow, Lohnes & Albertson, PLLC
1200 New Hampshire Avenue, N.W.
Washington, D.C. 20036


Dear Mr. Feinberg:

     This letter is in response to your letter of December 3, 1996 on behalf of your client Comcast
Cable Communications, Inc. ("Comcast").  You request that the Commission recognize as
reasonable and consistent with Commission regulations Comcast's inflation adjustment factor
calculations on its August 1, 1996 FCC Form 1240 rate filings.

     You state that in an attempt to comply with pending Form 1240 deadlines and absent a
Commission-prescribed rate at the time of filing, Comcast calculated an inflation adjustment factor,
consistent with the Commission's rules, based on data from the Bureau of Economic Analysis
(BEA).  The inflation adjustment factor calculated by Comcast, 2.61%, differed from the factor
subsequently released by the Commission, 2.39%, because Comcast's calculations were based on a
ratio of Gross National Product Price Indexes (GNP-PI) rounded to the nearest tenth, as published by
BEA.  The GNP-PI used in the Commission's calculations, however, were rounded to the nearest
thousandth.  You explain that Comcast did not perceive its method to be improper because the
Commission previously had used BEA data to one decimal place (i.e. to the nearest tenth) to
calculate inflation adjustment factors, and Comcast's use of BEA-published data was consistent with
the rules.  Considering that Comcast used BEA-published data and calculated its adjustment factor
using this data in a manner previously employed by the Commission, you request that we find
Comcast's use of the 2.61% inflation adjustment factor to be consistent with Commission
regulations.

     Based on the information presented by Comcast, we believe that Comcast made a good faith
mistake in the calculation of the inflation factor for the FCC Form 1240's dated August 1, 1996. 
Because we believe that this mistake was made in good faith, and because the FCC Form 1240
permits the correction of an overstatement such as the one made here, we will allow

Peter H. Feinberg, Esquire                                  Page 2
February 5, 1997



Comcast to correct its excess inflation during the true-up process of its next 1240 filing.  This waiver
applies to Comcast's FCC Form 1240 filings for August 1, 1996 only.

                              Sincerely,



                              Meredith J. Jones
                              Chief
                              Cable Services Bureau