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                           Before the
                Federal Communications Commission
                     Washington, D.C. 20554

In the Matter of                )  
                                )  File No. EB-02-TC-037
Time Warner Entertainment Company, LP   )    
                                )  CUID No.WI0265 (West Allis)
Complaint Regarding             )  
Cable Programming Services Tier )            
                                
                              ORDER

     Adopted:  May 6, 2002              Released:  May 8, 2002

By the Chief, Enforcement Bureau:1

     1.    In this  Order we  consider  a 
complaint2 against  the  rates charged  by  the  above-referenced 
operator ("Operator")3 for  its cable  programming services  tier 
("CPST") in the community referenced above.4  The Cable  Services 
Bureau has already issued an  order in which it found  Operator's 
CPST rates  in effect  through May  14, 1994  to be  unreasonable 
("Prior Order").5  In the Prior Order, the Cable Services  Bureau 
stated that  its  findings  "do  not  in  any  way  prejudge  the 
reasonableness of the prices for  CPS service after May 14,  1994 
under our new rate regulations."6  This Order addresses only  the 
reasonableness of Operator's CPST  rates in effect beginning  May 
15, 1994. 

     2.   Under the provisions  of the  Communications Act7  that 
were in effect at the time the referenced complaints were  filed, 
the  Federal   Communications   Commission   ("Commission")   was 
authorized to review the CPST rates of cable systems not  subject 
to effective competition  to ensure  that rates  charged are  not 
unreasonable.   The  Cable  Television  Consumer  Protection  and 
Competition  Act  of  19928  ("1992  Cable  Act")  required   the 
Commission to  review  CPST rates  upon  the filing  of  a  valid 
complaint by a subscriber or local franchising authority ("LFA").  
The filing  of  a  complete  and  timely  complaint  triggers  an 
obligation upon the cable operator to file a justification of its 
CPST rates.9  The Operator has  the burden of demonstrating  that 
the  CPST  rates  complained  about  are  reasonable.10   If  the 
Commission finds a  rate to be  unreasonable, it shall  determine 
the correct rate and any refund liability.11
     
     3.   Operators must use the FCC Form 1200 series to  justify 
rates for the  period beginning  May 15,  1994.12  Operators  may 
file an FCC Form 1210  to justify quarterly rate increases  based 
on the  addition and  deletion of  channels, changes  in  certain 
external costs  and  inflation.13  Operators  may  justify  their 
rates on  an annual  basis  using an  FCC  Form 1240  to  reflect 
reasonably certain and  quantifiable changes  in external  costs, 
inflation,  and  the  number  of  regulated  channels  that   are 
projected for the twelve months following the rate change.14  Any 
incurred cost that is not projected may be accrued with  interest 
and added to rates at a later time.15  Additionally, an  Operator 
may file an FCC Form 1235 (Abbreviated Cost of Service Filing for 
Cable  Network  Upgrades).   The  FCC  Form  1235  allows   cable 
operators  to  justify  rate  increases  related  to  significant 
capital expenditures  used  to improve  rate-regulated  services.  
This option is  extended only  in cases  of significant  upgrades 
requiring added capital  investment, such  as bandwidth  capacity 
and conversion to fiber optics, and for system rebuilds.   Normal 
improvements and  expansions of  service  remain subject  to  the 
usual rate adjustments  allowed by filing  FCC Form 1210s,  1220s 
and 1240s.   Cable operators  that incur  increases in  operating 
costs associated  with  a  significant network  upgrade  will  be 
permitted to charge  additional rates as  justified by their  FCC 
Form 1235 filing.         

     4.   Upon review of  Operator's FCC Form  1200, we  adjusted 
Line A6 (Monthly  Charge per  Tier as  of 3/31/94)  to $10.01  to 
conform to  the maximum  permitted rate  ("MPR") from  Operator's 
revised FCC Form  393 as adjusted  in our Prior  Order.  Line  A1 
(Channels per Tier as of 3/31/94) and Line C1 (Channels per  Tier 
as of  3/31/94) were  adjusted to  23 channels  for the  CPST  to 
reflect Operator's actual channel line-up, in accordance with the 
channel line-up card provided by Operator.  We also adjusted Line 
C2 (Number of  Regulated Non-Broadcast Channels  per Tier) to  23 
for the  CPST  for  the same  reason.   Our  adjustments  reduced 
Operator's MPR  from $10.55  to  $9.36.  The  Commission's  rules 
provide  for  a  refund  liability  deferral  period,  if  timely 
requested by Operator, beginning May 15, 1994 and ending July 14, 
1994, for any overcharges  resulting from Operator's  calculation 
of a new MPR on the  FCC Form 1200.16  Operator elected to  defer 
refund liability  for overcharges  associated with  its FCC  Form 
1200 pursuant  to the  Commission's rules.17   However,  Operator 
will incur refund liability  from May 15,  1994 through July  14, 
1994 for  any CPST  rates  charged above  the  FCC Form  393  MPR 
approved by  the Commission.18   In the  Prior Order,  the  Cable 
Services Bureau found that Operator justified an FCC Form 393 MPR 
of $10.01.   Because  Operator's  actual  CPST  rate  of  $10.27, 
effective May 15,  1994 through  July 14, 1994,  exceeds its  FCC 
Form 393 MPR of  $10.01, we find Operator's  actual CPST rate  of 
$10.27, effective  May 15,  1994  through July  14, 1994,  to  be 
unreasonable.  

     5.   Upon review of  Operator's FCC Form  1210 covering  the 
period April 1, 1994 through June  30, 1994, we adjusted Line  A2 
(Full Reduction Rate per Tier) to reflect Operator's revised  FCC 
Form 1200 Line  K1 (Maximum  Permitted Rate) of  $9.36.  Line  C1 
(Previous Number  of Regulated  Channels per  Tier) and  Line  C2 
(Current Number of Regulated Channels per Tier) were adjusted  to 
23 channels  for  the CPST  as  noted above.   These  adjustments 
reduced Operator's MPR  from $11.15 to  $9.96, effective July  1, 
1994.  Because Operator's actual  CPST rate of $10.27,  effective 
July 15, 1994 through July 31,  1994, exceeds its revised MPR  of 
$9.96, we find Operator's actual  CPST rate of $10.27,  effective 
July 15, 1994 through July 31, 1994, to be unreasonable.  Because 
Operator's actual CPST rate of  $10.55, effective August 1,  1994 
through September 30, 1994, exceeds its revised MPR of $9.96,  we 
find Operator's actual CPST rate  of $10.55, effective August  1, 
1994 through September 30, 1994, to be unreasonable. 

     6.   Upon review of  Operator's FCC Form  1210 covering  the 
period July 1, 1994 though  September 30, 1994, we adjusted  Line 
A2 to reflect Operator's prior FCC Form 1210 MPR of $9.96.   Line 
C1 and Line C2 were adjusted to 23 channels for the CPST.   These 
adjustments  reduced  Operator's  MPR  from  $11.35  to   $10.14, 
effective October 1, 1994.   Because Operator's actual CPST  rate 
of $10.55, effective  October 1, 1994  through October 31,  1994, 
exceeds its revised MPR of $9.96, we find Operator's actual  CPST 
rate of $10.55,  effective October  1, 1994  through October  31, 
1994, to be unreasonable. Because Operator's actual CPST rate  of 
$11.35, effective  November 1,  1994 through  December 31,  1994, 
exceeds its revised MPR of $10.14, we find Operator's actual CPST 
rate of $11.35, effective November  1, 1994 through December  31, 
1994, to be unreasonable.

     7.   Upon review of  Operator's FCC Form  1210 covering  the 
period October 1,  1994 through  December 31,  1994, we  adjusted 
Operator's Line A2 to reflect Operator's prior FCC Form 1210  MPR 
of $10.14. Line C1 and Line  C2 were adjusted to 23 channels  for 
the CPST.  These adjustments  reduced Operator's MPR from  $11.56 
to $10.34, effective January 1, 1995.  Because Operator's  actual 
CPST rate of $11.35, effective January 1, 1995 through March  31, 
1995, exceeds its revised MPR  $10.34, we find Operator's  actual 
CPST rate of $11.35, effective January 1, 1995 through March  31, 
1995, to be unreasonable. 

     8.   Upon review of  Operator's FCC Form  1210 covering  the 
period January  1,  1995  through March  31,  1995,  we  adjusted 
Operator's Line A2 to reflect Operator's prior FCC Form 1210  MPR 
of $10.34.  Line C1 and Line C2 were adjusted to 23 channels  for 
the CPST.  These adjustments  reduced Operator's MPR from  $11.48 
to $10.27, effective  April 1, 1995.   Because Operator's  actual 
CPST rate  of $11.35,  effective April  1, 1995  through May  31, 
1995, exceeds  its  revised MPR  of  $10.27, we  find  Operator's 
actual CPST rate of $11.35,  effective April 1, 1995 through  May 
31, 1995, to be unreasonable. Because Operator's actual CPST rate 
of $11.48, effective June 1,  1995 through May 31, 1996,  exceeds 
its revised MPR of $10.27, we find Operator's actual CPST rate of 
$11.48, effective  June  1, 1995  through  May 31,  1996,  to  be 
unreasonable.19
     9.   Upon  review  of  Operator's  FCC  Form  1240  for  the 
projected period June 1, 1996  through May 31, 1997, we  adjusted 
Operator's Line  A1  (Current  Maximum  Permitted  Rate)  and  D2 
(Current External  Costs  Segment)  to  conform  with  Operator's 
previous revised FCC Form 1210.  We revised Worksheet 1  (True-Up 
Period Inflation) which  adjusted Line C3  (Inflation Factor  for 
the True-Up  Period  1)  to  1.0151  and  Line  C5  (Current  FCC 
Inflation Factor) was  adjusted to  1.0222.20  These  adjustments 
resulted in  a  revised  MPR  of  $9.33  rather  than  Operator's 
calculated MPR of $11.88.  Because Operator's actual CPST rate of 
$11.88, effective June 1, 1996 through May 31, 1997, exceeds  its 
revised MPR  of $9.33,  we find  Operator's actual  CPST rate  of 
$11.88, effective  June  1, 1996  through  May 31,  1997,  to  be 
unreasonable.

     10.  Upon  review  of  Operator's  FCC  Form  1240  for  the 
projected period June 1, 1997  through May 31, 1998, we  adjusted 
Operator's Line A1 to reflect the MPR of $9.33 from its  previous 
revised FCC Form  1240.  We revised  Worksheet 1, which  adjusted 
Line C3  to 1.0221  and  we adjusted  Line  C5 to  1.0177.21   We 
adjusted Line  D6 (Current  True-Up  Segment), Line  D7  (Current 
Inflation Segment)  and  Line  F8 (True-Up  Segment  for  True-Up 
Period 1)  to conform  to Operator's  previous revised  FCC  Form 
1240. Also,  Operator made  true-up  adjustments through  to  the 
effective date of the projected period and those adjustments  did 
not include actual  data.22 Consequently,  we reduced  Operator's 
true-up period  by  one  month and  adjusted  Operator's  MPR  in 
accordance with our rules and  the FCC Form 1240  instructions.23 
This resulted in an  adjustment to Line E2  (Number of Months  in 
the True-up Period 1) to 12 months and Line E4 (Number of  Months 
in True-Up Period 2 Eligible for Interest) to 2 months.  Line  G5 
(Inflation Segment for True-Up Period 2) was adjusted to  $0.0254 
and Line G8 (True-Up Segment  Period 2) was adjusted to  $0.8739.  
These adjustments resulted in a revised MPR of $9.79 rather  than 
Operator's calculated  MPR $14.31.24   Because Operator's  actual 
CPST rate of $14.31, effective June 1, 1997 through September 30, 
1997, exceeds its revised MPR of $9.79, we find Operator's actual 
CPST rate of $14.31, effective June 1, 1997 through September 30, 
1997, to be unreasonable.     

     11.  Operator filed an FCC Form 1235 to justify its  October 
1, 1997  CPST rate  increase  to $16.58.   Operator  subsequently 
reduced its CPST rate  on December 1, 1997  to $16.30 and gave  a 
credit to its subscribers for $0.28 for the months of October and 
November.25  Upon review of Operator's  FCC Form 1235, we  accept 
Operator's calculated MPR of $1.99.   This results in a  combined 
CPST  MPR  of  $11.78,   effective  October  1,  1997.    Because 
Operator's actual  CPST rate  of $16.30,26  effective October  1, 
1997 through  December  31,  1998, exceeds  its  revised  MPR  of 
$11.78, we find Operator's actual CPST rate of $16.30,  effective 
October 1, 1997 through December 31, 1998, to be unreasonable.

     12.  On November 30,  1995, the Commission  issued an  Order 
approving a Social Contract that  Operator entered into with  the 
Commission  ("Social  Contract").27   Among   its  terms  was   a 
provision by which Time Warner would be permitted to increase the 
monthly CPST rate by one dollar during each year of the contract, 
but would waive the right to make any other increase in  rates.28  
Operator  was  given  permission  by  Commission  staff  to  file 
bifurcated FCC Form 1240s.   In these bifurcated forms,  Operator 
calculates the  $1.00 annual  increase  permitted by  the  Social 
Contract and its true-up on a  separate FCC Form 1240 ("SCD  Form 
1240").  On the  SCD Form 1240,  Operator calculates its  true-up 
adjustment through to  the effective date  of the rate  increase.  
On its  other  FCC  Form  1240,  Operator  calculates  the  other 
adjustments to its CPST  rate in conformance  with FCC Form  1240 
Instructions for  the true-up  period.29   As noted  above,  Time 
Warner Cable purchased this system in December 1997.  Upon filing 
its first FCC Form  1240 for this cable  system, which we  review 
below, Time Warner  Cable elected  to include the  system in  its 
Social Contract, thus  taking the annual  Social Contract  Dollar 
for its upgrade and  rejecting the FCC  Form 1235 upgrade  add-on 
amount.

     13.  Upon review of Operator's non-SCD FCC Form 1240 for the 
projected period January  1, 1999 through  December 31, 1999,  we 
adjusted Operator's Line A1, Line D6, Line D7, Line F8, and G8 to 
conform to Operator's  previous revised FCC  Form 1240.  We  also 
added back the month that we  removed from the true-up period  of 
the previous FCC Form 1240.   Consequently, Line E2 was  adjusted 
to  12  months  and  Line  E4  was  adjusted  to  7  months.  Our 
adjustments reduced  Operator's MPR  from $15.50  to $8.18.  Upon 
review of  Operator's  SCD Form  1240  for the  projected  period 
January 1, 1999 through December  31, 1999, we accept  Operator's 
calculated MPR  of $3.14  for a  total MPR  of $11.32,  effective 
January 1, 1999.  Because Operator's actual CPST rate of  $18.28, 
effective January 1,  1999 through  March 31,  1999, exceeds  its 
revised MPR of  $11.32, we  find Operator's actual  CPST rate  of 
$18.28, effective January 1, 1999  through March 31, 1999, to  be 
unreasonable.30 
 
     14.  Accordingly, IT IS ORDERED, pursuant to Sections  0.111 
and 0.311  of the  Commission's  rules, 47  C.F.R.   0.111  and 
0.311, that the CPST rates, charged by Operator in the  community 
referenced above, effective May 15, 1994 through March 31,  1999, 
ARE UNREASONABLE.

     15.  IT IS FURTHER  ORDERED, pursuant to  Section 76.961  of 
the Commission's rules, 47 C.F.R.   76.961, that Operator  shall 
refund to subscribers that portion  of the amount paid in  excess 
of the  maximum permitted  CPST rate  of $10.01  per month  (plus 
franchise fees), plus interest to the date of the refund, for the 
period May 15, 1994 through July 14, 1994.
 
     16.  IT IS FURTHER  ORDERED, pursuant to  Section 76.961  of 
the Commission's rules, 47 C.F.R.   76.961, that Operator  shall 
refund to subscribers that portion  of the amount paid in  excess 
of the  maximum permitted  CPST  rate of  $9.96 per  month  (plus 
franchise fees), plus interest to the date of the refund, for the 
period July 15, 1994 through September 30, 1994.

     17.  IT IS FURTHER  ORDERED, pursuant to  Section 76.961  of 
the Commission's rules, 47 C.F.R.   76.961, that Operator  shall 
refund to subscribers that portion  of the amount paid in  excess 
of the  maximum permitted  CPST rate  of $10.14  per month  (plus 
franchise fees), plus interest to the date of the refund, for the 
period October 1, 1994 through December 31, 1994.

     18.  IT IS FURTHER  ORDERED, pursuant to  Section 76.961  of 
the Commission's rules, 47 C.F.R.   76.961, that Operator  shall 
refund to subscribers that portion  of the amount paid in  excess 
of the  maximum permitted  CPST rate  of $10.34  per month  (plus 
franchise fees), plus interest to the date of the refund, for the 
period January 1, 1995 through March 31, 1995.

     19.  IT IS FURTHER  ORDERED, pursuant to  Section 76.961  of 
the Commission's rules,  47 C.F.R. 76.961,  that Operator  shall 
refund to subscribers that portion  of the amount paid in  excess 
of the  maximum permitted  CPST rate  of $10.27  per month  (plus 
franchise fees), plus interest to the date of the refund, for the 
period April 1, 1995 through June 30, 1995. 

     20.  IT IS FURTHER  ORDERED, pursuant to  Section 76.961  of 
the Commission's rules,  47 C.F.R. 76.961,  that Operator  shall 
refund to subscribers that portion  of the amount paid in  excess 
of the  maximum permitted  CPST rate  of $11.78  per month  (plus 
franchise fees), plus interest to the date of the refund, for the 
period from December 1, 1998 through December 31, 1998.
 
     21.  IT IS FURTHER  ORDERED, pursuant to  Section 76.961  of 
the Commission's rules,  47 C.F.R. 76.961,  that Operator  shall 
refund to subscribers that portion  of the amount paid in  excess 
of the  maximum permitted  CPST rate  of $11.32  per month  (plus 
franchise fees), plus interest to the date of the refund, for the 
period from January 1, 1999 through March 31, 1999.    

     22.  IT IS  FURTHER  ORDERED that  Operator  shall  promptly 
determine the  overcharges to  CPST  subscribers for  the  stated 
periods, and shall within 30 days  of the release of this  Order, 
file a report  with the  Chief, Enforcement  Bureau, stating  the 
cumulative refund amount so determined (including franchise  fees 
and interest), describing the calculation thereof, and describing 
its plan to  implement the  refund within 60  days of  Commission 
approval of the plan.

     23.  IT IS FURTHER ORDERED,  pursuant to Sections 0.111  and 
0.311 of the Commission's  rules, 47 C.F.R.   0.111 and  0.311, 
that the complaint referenced herein against the rates charged by 
Operator in the community referenced above IS GRANTED.

                              FEDERAL COMMUNICATIONS COMMISSION 


                              

                              David H. Solomon
                              Chief, Enforcement Bureau
_________________________

1  Effective   March  25,   2002,  the   Commission   transferred 
responsibility for resolving cable programming services tier rate 
complaints  from  the  former   Cable  Services  Bureau  to   the 
Enforcement Bureau.  See Establishment  of the Media Bureau,  the 
Wireline Competition  Bureau and  the Consumer  and  Governmental 
Affairs Bureau, Reorganization  of the  International Bureau  and 
Other Organizational Changes, FCC 02-10, 17 FCC Rcd 4672 (2002).
2 The first valid complaint  against Operator's CPST rate in  the 
community referenced above was filed on February 28, 1994.  There 
are no subsequent complaints on file.
3  The  term  "Operator"  includes  Operator's  predecessors  and 
successors in interest.
4 On  December 3,  1997,  the Federal  Communications  Commission 
received notification,  pursuant  to 47  C.F.R.   76.400,  of  a 
change of ownership from Marcus Cable Partners, LP to Time Warner 
Entertainment Company, LP.
5 See In the Matter of Crown Cable Wisconsin, Inc., DA 95-680, 10 
FCC Rcd 7923  (CSB 1995); refund  plan denied, In  the Matter  of 
Marcus Cable  Partners, LP,  DA 98-2442,  13 FCC  Rcd 23411  (CSB 
1998).
6 Prior Order at n. 2.
7 Communications  Act,  Section  623(c), as  amended,  47  U.S.C. 
543(c) (1996).
8 Pub. L. No. 102-385, 106 Stat. 1460 (1992).
9 See  Section 76.956  of  the Commission's  rules, 47  C.F.R.   
76.956.
10 Id.
11 See  Section 76.957  of the  Commission's rules,  47 C.F.R.   
76.957. 
12 See  Section  76.922  of the  Commission's  rules,  47  C.F.R. 
76.922.
13 Id.
14 Id.
15 Id.
16 See  Section 76.922(b)(6)(ii)  of the  Commission's rules,  47 
C.F.R. Section 76.922(b)(6)(ii).
17 See Letter dated August 12, 1994 to the Federal Communications 
Commission from  Trudi McCollum  Foushee, Vice  President,  Crown 
Cable Law and Regulatory Affairs.
18 See  Section 76.922(b)(6)(ii)  of the  Commission's rules,  47 
C.F.R.  76.922 (b)(6)(ii).
19 Because Operator's  refund liability  for the  period July  1, 
1995 through November 30,  1998, was trued  up in subsequent  FCC 
Form 1240s, which we review  herein, Operator is not required  to 
separately calculate that  refund liability and  submit a  refund 
plan for those time periods.
20 In accordance with the FCC Form 1240 Instructions, we used the 
most recent Inflation  Adjustment Factors released  by the  Cable 
Services Bureau  for  the  relevant  time  periods.   See  Public 
Notice, DA 02?791 (CSB released April 9, 2002).
21 Id. 
22 Operator signed its FCC Form 1240 on April 30, 1997, one month 
prior to the ending date of its true-up period.
23 Operator's  true-up  period, which  began  March 1,  1996  and 
originally ended on May  31, 1997, was adjusted  to end on  April 
30, 1997.  The annual adjustment afforded by FCC Form 1240 allows 
operators to project changes in external cost, inflation, and the 
number of regulated  channels.  This structure  avoids the  delay 
some operators experienced  in recouping  costs through  multiple 
rate adjustments throughout the  year.  Because projections  will 
not  reflect  the  costs  that  actually  occur,  the  Commission 
provided, as part of the annual adjustment, a "true-up" mechanism 
to correct projected cost changes  with the actual cost  changes.  
However, the Commission has noted that, as FCC Form 1240 must  be 
filed 90 days before  an increase is to  take effect, the  period 
for the  true-up  will  not coincide  with  the  previous  year's 
projections.  See In the Matter of Implementation of Sections  of 
the Cable Television Consumer  Protection and Competition Act  of 
1992: Rate Regulation, MM Docket No. 92-266, Thirteenth Order  on 
Reconsideration ("Thirteenth Reconsideration Order"), 11 FCC  Rcd 
388, 420  at  n.151 (1995).   The  true-up data  is  intended  to 
indicate real, not projected data.  Id.  This policy is reflected 
in the instructions  accompanying FCC  Form 1240.   See FCC  Form 
1240 Instructions, "Timing" at pp. 3-4.
24 We allowed Operator to  claim $0.14 for increases in  external 
costs between September 30, 1992  and the earlier of the  initial 
date of regulation or February 28, 1994.
25 See Letter dated November 30, 1997, with attached bill, to the 
Honorable Jeanette Bell, Mayor, City of West Allis, WI from Marty 
Robinson, District Manager, Marcus Cable.
26 The  actual  CPST  rate of  $16.30  reflects  Operator's  rate 
reduction and refund for October and November.
27 See In the Matter of  Social Contract for Time Warner, 11  FCC 
Rcd 2788 (1996).
28 Id. at 2798.
29 The true-up data is  intended to indicate real, not  projected 
data.  See In  the Matter  of Implementation of  Sections of  the 
Cable Television Consumer Protection and Competition Act of 1992:  
Rate Regulation,  MM  Docket  No.  92-266,  Thirteenth  Order  on 
Reconsideration ("Thirteenth Reconsideration Order"), 11 FCC  Rcd 
388, 420 at n.151  (1996).  The period for  the true-up will  not 
coincide with the previous year's projections.  Id.  This  policy 
is reflected in the instructions accompanying FCC Form 1240.  See 
FCC Form 1240 Instructions, "Timing" at pp. 3-4.
30 These  findings are  based solely  on the  representations  of 
Operator.  Should information  come to our  attention that  these 
representations were materially inaccurate, we reserve the  right 
to take appropriate action.  This Order is not to be construed as 
a finding that we  have accepted as  correct any specific  entry, 
explanation or argument made by any party to this proceeding  not 
specifically  addressed  herein.     Information  regarding   the 
specific adjustments made to Operator's FCC Forms can be found in 
the public  files for  the above-referenced  community which  are 
available in the  FCC Reference Information  Center, Portals  II, 
445 12th Street, SW, Room  CY-A257, Washington, DC, 20554.   This 
document may also be purchased from the Commission's  duplicating 
contractor, Qualex International,  Portals II,  445 12th  Street, 
SW, Room CY-B402, Washington, DC, 20554, telephone  202-863-2893, 
facsimile 202-863-2898, or via e-mail qualexint@aol.com.