PUBLIC NOTICE
FEDERAL COMMUNICATIONS COMMISSION
1919 M STREET, N.W.
WASHINGTON, D.C. 20554                                             DA 98-42

News media information 202/418-0500     Fax-On-Demand  202/418-2830     Internet:  http://www.fcc.gov    ftp.fcc.gov


                                                  Released: January 9, 1998


               Puerto Rico Telco Petitions the Commission 
                 for Clarification of 1997 Access Order 
                          CC Docket No. 97-149
                                    
                       Pleading Cycle Established

Comments:  January 25, 1998

Reply Comments:  February 1, 1998

        On December 31, 1997, Puerto Rico Telephone Company (PRTC), filed a petition with the
Commission to clarify the future applicability of Section 65.820(d), 47 C.F.R.  65.820(d) of  the
Commission's Rules.
        PRTC states that carriers have a number of options for determining cash working capital (CWC). 
Class A carriers may use their actual net lag period, based on a full lead-lag study or the simplified
formula method. Class B carriers may calculate the CWC allowance using the standard allowance
prescribed by the Chief of the Common Carrier Bureau. PRTC asserts that since it is a Class A carrier
and it elected to calculate CWC using the simplified formula method.  PRTC state that it elected to
calculate CWC using the simplified formula method to determine net-lag days.  In its Order in the 1997
Annual Access Tariff Filing the Commission rejected PRTC's lead-lag study and imposed a fifteen day
standard allowance, a standard it has previously recognized as an appropriate standard allowance for Class
B carriers.

        Section 65.820(d) provides that once a carrier has selected a method of determining its CWC
allowance, it may not change to another optional method from year to year without Commission approval. 
PRTC states that the intended effect of the provision is to prevent carriers from strategically selecting
among the available options from year to year in an effort to maximize the CWC result.  PRTC argues
that Section 65.820(d) only prevents carriers from changing from one optional method to another, but
does not apply when the Commission imposes an option as it did in its Order.  PRTC asserts that it could
develop its future CWC allowance using the simplified formula method without prior Commission
approval and would have continued to utilize the simplified method in the absence of the Commission's
directive to use the fifteen day standard allowance for future tariff filings.  PRTC aargues, therefore, that
the Commission should clarify that this prohibition does not apply to PRTC in the instant case.   

        Interested parties may file comments on  Puerto Rico Telephone Company petition    no later than
January 25, 1998. Replies must be filed by February 1, 1998. When filing comments and/or replies,
please reference the internal file number: CPD/CPD 98-3.




        An original and four copies of all comments and replies must be filed in accordance with Section
1.51(c) of the Commission's Rules, 47 C.F.R.  1.51(c).  In addition, one copy of  each pleading must
be
filed with International Transcription Services (ITS), the Commission's duplicating contractor, at its office
at 1231 - 20th Street, N.W., Washington, D.C. 20036 and one copy with the Chief, Competitive Pricing
Division, Room 518, 1919 M Street, N.W.,Washington, D.C. 20554.

           For further information contact, Wanda M. Harris, Competitive Pricing Division, Common
Carrier
Bureau, (202) 418-1530.
                             
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