FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011 Page: 5,208
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News Media Information 202 /418-0500
Federal Communications Commission Fax-On-Demand 202/418-2830
445 12h St., S.W. TTY 202 /418-2555
Washington D.C. 20554 Intemet http://www.fcc.gov
Washington, D.C. 20554 afn frr. nrw
April 8, 2011
COMMENT SOUGHT ON PUERTO RICO TELEPHONE COMPANY'S
SUPPLEMENTAL FILING IN CONNECTION WITH PETITION FOR
WAIVER OF STRUCTURAL SEPARATION REQUIREMENTS
PLEADING CYCLE ESTABLISHED
WC Docket No. 10-52
Comments: May 6, 2011
Reply Comments: May 23. 2011
On March 23, 2011, Puerto Rico Telephone Company, Inc. (PRT) submitted a supplemental
filing in connection with its January 26, 2010 petition for waiver of the structural separation requirements
for long distance services in section 64.1903 of the Commission's rules.' That rule requires independent
incumbent local exchange carriers (LECs) that provide in-region, interstate, interexchange
telecommunications services or in-region, international interexchange services, other than through resale,
to do so through separate affiliates that meet certain requirements.
PRT's March 23 filing was in response to the Wireline Competition Bureau's December 23, 2010
Order conditionally granting, in part, PRT's waiver petition.3 Among other actions, the PRT Waiver
Order deferred temporarily application of dominant carrier regulation to any in-region, interstate and
international, long distance services PRT provides other than through a rule 64.1903 separate affiliate.
This temporary deferral was conditioned upon PRT filing, within 90 days of the Order's effective date
(i.e., by March 23, 201 1), "evidence intended to show that PRT lacks classical market power in relation to
' Letter from Bennett L. Ross, Counsel for PRT, to Marlene H. Dortch, Secretary. FCC, WC Docket No. 10-52
(filed Mar. 23, 2011) (PRT March 23 Filing); Petition of Puerto Rico Telephone Company, Inc. and Puerto Rico
Telephone Larga Distancia, Inc. for Waiver of Section 64.1903 of the Commission's Rules, WC Docket No. 10-52
(filed Jan. 26, 2010) (Petition).
2 47 C.F.R. 64.1903. Specifically, the separate affiliate must maintain books of account separate from those
maintained by the independent incumbent LEC, purchase tariffed services from the independent incumbent LEC
pursuant to the incumbent LEC's tariffs, and not jointly own transmission or switching facilities with the
independent incumbent LEC. 47 C.F.R. 64.1903(a).
"Petition of Puerto Rico Telephone Company, Inc. and Puerto Rico Telephone Lorga Distancia, Inc. for Waiver of
Section 64. 1903 of the Commission 's Rules, Memorandum Opinion and Order, WC Docket No. 10-52, DA 10-241 8
(WCB rel. Dec. 23, 2010) (PRT Waiver Order).
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United States. Federal Communications Commission. FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011, book, April 2011; Washington D.C.. (digital.library.unt.edu/ark:/67531/metadc52169/m1/380/: accessed April 30, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.