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                                               FEDERAL COMMUNICATIONS COMMISSION
                      WASHINGTON D C 20554
                                
                       December 23, 1987
                                
                                             In reply refer to:
                                                  RAO Letter 10
                                                               
Responsible Accounting Officer

Part 32 - Uniform System of Accounts for Class A and Class B Carriers -- 
List of Retirement Units

     Section 31.8 of Part 31 of the Commission's accounting rules prescribes the list of
retirement units that should be used by the carriers. Any carrier with annual operating revenues
in excess of $1 million may use smaller units which are subdivisions of the units prescribed in this
section provided its practice in this respect is consistent and it notifies the Commission 90 days
before (1) commencing such use, (2) making any change therein, or (3) discontinuing such use.
(See Section 31.8 of the Commission's rules).

     In lieu of the retirement units prescribed in Section 31.8 with respect to a particular
account, a carrier may, after obtaining specific approval by the Commission, establish and
maintain its own list of retirement units for a portion or all of the plant in any such account. The
considerations underlying the selection of items as retirement units shall be submitted for
Commission approval. An up-to-date list of such retirement units shall be maintained for each
accounting area.  The list shall be available for inspection at any time.

     When Part 32, Uniform System of Accounts for Telecommunications Companies, was
adopted in May 1986, no list of retirement units was included. The Commission decided the
retirement units list, as a part of the regulation, was not necessary because as a matter of actual
practice at the Federal level, companies had been submitting and justifying their own asset
groupings for depreciation purposes and had not been constrained by a uniform list. The
Commission stated, however, that the requirement for submitting retirement units lists to the
Commission for approval was still necessary.

     Accordingly, we are requiring Class A carriers, as defined in Part 32 of the rules, to
submit an updated list of retirement units by Part 32 accounts. It is requested that lists be
submitted by January 30, 1988 to the Chief, Accounting and Audits Division, Common Carrier
Bureau, 2000 L Street, N. W., Suite 812, Washington, D. C. 20554.









     This letter is issued under Section 0.291 of the Commission's rules. Applications for
review under Section 1.115 of the Commission's rules must be filed within 30 days from the date
indicated above. (See Section 1.4(b)(4) of the Commission's rules) .

     If you have any questions contact the Chief of the Accounting Systems Branch at 
(202) 418-0810.

                                        Sincerely,

                                        Kenneth P. Moran
                                        Chief, Accounting and Audits Division