WPCW 2BJZ Courier3|ox6X@KX@HP LaserJet 4 PostScriptitional)HPLA4POS.PRSx  @hhhh&:mX@2E6YFL Z3|oTimes RomanTimes Roman BoldTimes Roman ItalicHelvetica NarrowTimes Roman Bold Italic"S^*8DSS888S^*8*.SSSSSSSSSS..^^^Jxooxf]xx8Axfxx]xo]fxxxxf8.8NS8JSJSJ8SS..S.SSSS8A.SSxSSJP!PZ8*888888888888S.xJxJxJxJxJooJfJfJfJfJ8.8.8.8.xSxSxSxSxSxSxSxSxSxSxJxSxSxSxSxS]SxJxJoJoJoJoJxSfJfJfJfJxSxSxSxSxSxSxS8S8S888SA8xSf.f8f8f8f.xSxSxSxSxSxo8o8o8]A]A]A]Af8f8f8xSxSxSxSxxSfJfJN:*LS8JSSSSS.4}}S2S}2.JJS88SS]]8J2t^^\\^^ee*C^.wR)Ewn\1fy\r\Sxx\rHP LaserJet 4 PostScriptitional)HPLA4POS.PRSX\  P6G;hhhh&:mP2bwvpk I. A. 1. a.(1)(a) i) a) 1. 1. 1. a.(1)(a) i) a)a8DocumentgDocument Style StyleXX` `  ` a4DocumentgDocument Style Style . a6DocumentgDocument Style Style GX  2kvta5DocumentgDocument Style Style }X(# a2DocumentgDocument Style Style<o   ?  A.  a7DocumentgDocument Style StyleyXX` ` (#` BibliogrphyBibliography:X (# 2P  Z   a1Right ParRight-Aligned Paragraph Numbers:`S@ I.  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A. a.(1)(a) i) a)Documentg2{ e rPleadingHeader for Numbered Pleading PaperE!n    X X` hp x (#%'0*,.8135@8:485:6<7=index 2index 24` hp x (#4 4 ` hp x (#toatoa5` hp x (#` hp x (#captioncaption6;1#XP\  P6QXP##C\  P6QP#_Equation Caption_Equation Caption711#XP\  P6QXP##C\  P6QP#2PD8l>9,?L?LBendnote referenceendnote reference844#XP\  P6QXP##C\  P6QP#footnote referencefootnote reference94#XP\  P6QXP#"S^2CRddCCCdq2C28dddddddddd88qqqYzoCNzoozzC8C^dCYdYdYCdd88d8ddddCN8ddddY`(`lC2CC!CCCCCCCCCCd8YYYYYYzYzYzYzYC8C8C8C8ddddddddddYdddddodYYYYYYdzYzYzYzYdddddddCdCdCCCdNCdz8zCzCzCz8dddddCCCoNoNoNoNzCzCzCdddddzYzYNF2[dCYddddd7>d<d<$8YYdCCddooCYȾd<d<+8oodCCddddCoȾ -#D  P7jQP#э Authorization of Common Carrier Facilities to Provide Telecommunications Service off the Island of  {O -Puerto Rico, CC Docket No. 86309, Report and Order, 2 FCC Rcd 6600 (1987) ("OffIsland Order"), recon., 8  yO -FCC Rcd 63 (1992).  The OffIsland Order found that competition in the Puerto Rico offisland market was both feasible and desirable. While opening the door to granting  X -PRTC authority to provide offisland services, however, the OffIsland Order imposed a number of conditions designed to ensure fair competition. In particular, the Commission imposed requirements on PRTC concerning the provision of interim access to multiple offisland carriers and the implementation of full equal access comparable to that provided on the mainland. The Commission also found that rules then in effect classified PRTC as dominant for the provision of offisland domestic service and that PRTC should be treated as dominant for the provision of offisland international message telephone service (IMTS). In addition, the Commission imposed safeguards on PRTC related to disclosure of technical network information; customer proprietary network information (CPNI); information gleaned from competing offisland carriers; and aggregate customer information. Finally, the Commission required that PRTC make available to offisland carriers, on request, data for each end office or wire center on the past and projected number of business and residence telephone lines and average usage per line, updated on a semiannual basis.  X-x5. In the summer of 1988, AT&TPR and PRTC reached settlement on numerous  X-matters, including various Section 214 applications filed by PRTC.~8 yO-ԍ AT&T had purchased AAC&R, the traditional offisland carrier, forming AT&TPR, in June 1987. As part of this settlement agreement, PRTA created La Telefonica Larga Distancia de Puerto Rico (LTLD), a whollyowned separate corporate subsidiary for the provision of domestic and international offisland service, and substituted it for PRTC in various relevant applications. PRTA also asked for  XT-nondominant treatment of LTLD, which was granted."T8 yO$-#G= P1^QYP##D  P7jQP#э The Bureau found, in a declaratory ruling, that LTLD would qualify for treatment as a nondominant domestic interstate, interexchange affiliate of a LEC. PRTA assured the Commission that PRTC and LTLD would maintain separate books of account, would not jointly own transmission or switching facilities, and that  {Ok&-LTLD would take service from PRTC by tariff. The Bureau's Order, Puerto Rico Telephone Authority, 3 FCC  {O5'-Rcd 5675 (Com. Car. Bur. 1988) ("NonDominant Order") also determined that, with PRTC's establishment of a"5',N(N(j'" separate subsidiary, LTLD qualified for treatment as a nondominant provider of international message telephone  {OX-service (IMTS). Id. at 5677 ("since we find that LTLD will face existing competition and there is no evidence that it will control bottleneck local exchange facilities, we conclude that LTLD should be regulated as a nondominant IMTS provider"). Subsequent orders granted LTLD"T,N(N(ZZ"  X-Section 214 operating authority for earth station construction and operationT(8 {Oc-#D  P7jQP#э See La Telefonica Larga Distancia de Puerto Rico, Memorandum Opinion, Order and Authorization, 3  {O--FCC Rcd 5937 (Com. Car. Bur. 1988) ("LTLD 214 Grant Order"). This order noted the recent PRTC/AT&T  {O-settlement, and discussed the OffIsland Order, competition in the market, and the continuing conditions on  {O-PRTC (which the Order stated were "substantially met"). See id. at 593839. T and for operation  X-as an international resale and facilitiesbased carrier,\8 {O< -#D  P7jQP#э See, e.g., Telefonica Larga Distancia de Puerto Rico, Memorandum Opinion, Order, and Authorization, 4  {O -FCC Rcd 4496 (Intl. Fac. Div. 1989) ("LTLD Resale Grant Order"); Telefonica Larga Distancia de Puerto Rico, Order and Authorization, 7 FCC Rcd 4266 (Com. Car. Bur. 1992). while continuing the conditions imposed  X-in the OffIsland Order. x6. In 1992 the Commission authorized LTLD to assign its international Section 214 authorizations and cable landing license interests to LD Acquisition Corp. (LD), an affiliate of Telefonica de Espa9a, the monopoly provider of domestic and international communications services in Spain. Upon completion of the transaction, LD changed its name to Telefonica Larga Distancia de Puerto Rico, Inc. (TLD), which continues to provide offisland  X3-international services. l 3 8 {O-#D  P7jQP#э Telefonica Larga Distancia et al., Memorandum Opinion, Order, Authorization and Certificate, 8 FCC Rcd  {Ot-106 (1992) ("TLD Assignment Order"). A majority of the stock of TLD, 79 percent, was owned by Telefonica International Holding, B.V. ("TI Holding"). TI Holding was a Netherlands corporation which was a whollyowned subsidiary of T.I. Telefonica International de Espa9a, S.A. ("T.I."), a corporation organized under the laws of Spain. TI was a subsidiary of Telefonica de Espa9a. PRTA owned 19 percent of the stock of TLD, and  {O-the remaining 2 percent was held in an employee stock ownership plan. Id. at 107. In addition, to comply with Section 310 of the Communications Act of 1934, as amended, which restricts foreign ownership and control of  {O(-certain Title III licenses, the assets that required Title III radio licenses (i.e., international and domestic fixed earth stations and an international fixed public pointtopoint telegraph and telephone station) were transferred to a newlyformed corporation, Telecommunications Ultramarinas de Puerto Rico ("TUPR"), owned 85.1 percent by  {O-PRTA and 14.9 percent indirectly by Telefonica de Espa9a. The TLD Assignment Order continued the Off {OL-Island Order conditions imposed on PRTC. Also in 1992, the Commission reconsidered its OffIsland Order, affirming its main holdings but modifying its CPNI disclosure requirements in light of the  X -formation of LTLD as a separate subsidiary.s Z 8 {O!-#D  P7jQP#э OffIsland Reconsideration Order, 8 FCC Rcd 63 (1992). The Commission modified the CPNI disclosure requirements to permit PRTC to use CPNI requirements that applied to the Bell Operating Companies (BOCs) or to treat LTLD the same as other offisland interexchange carriers.s x7. It is in this context that, on February 15, 1996, PRTC applied for Section 214 authorization to reenter the offisland international services market. The arguments made by petitioners opposing the application fall into three main categories: (1) that PRTC has failed"  ,N(N(ZZ "  X-in various ways to meet the terms of existing conditions (imposed in the OffIsland Order and renewed multiple times since then) and compliance with these and other nondiscrimination  X-conditions is critical to any grant of authority to TPRI; 8 {OM- xԍ See Section A, infra. Both AT&T and Sprint argue that existing conditions must be met before the requested authorization can be granted, and Sprint argues that additional conditions should be imposed as well. (2) that PRTC's responses to requests for access to local network facilities and a submarine cable station have been  X-inadequate and unacceptable;K "8 {Oy-ԍ See Section B, infra.K and (3) that TPRI must be treated as a dominant carrier and any grant must be stringently conditioned to guard against anticompetitive behavior by  Xx-TPRI/PRTC.K x8 {O -ԍ See Section C, infra.K  XJ- %II. Discussion  X <xA. Conditions Imposed in the OffIsland Order ; Additional Conditions  X -x` ` 1. Positions of the Parties x8. AT&T and Sprint petition to deny or condition TPRI's application on the grounds that PRTC has failed to demonstrate that it has met or will adhere to the conditions prescribed  X-by the Commission in its OffIsland Order to preclude anticompetitive conduct by PRTC as a  X~-provider of offisland services.~F8 {Ou-#D  P7jQP#Ѝ See generally AT&T Petition To Deny Application; Sprint Petition To Deny or Condition Application. In that order, AT&T and Sprint argue, the Commission recognized that, because of its local service monopoly, its governmentowned status, and the  XP-absence of any local telecommunications regulatory authority,^ZP8 yO-#D  P7jQP#э Sprint argues that the only entity with any authority over TPRI is PRTA, PRTC's and TPRI's parent, and  {O-that PRTA's decisions are not even subject to legislative veto. Sprint Petition at 7, n.10.  See also Lambda Petition at 7 n.10. ^ PRTC had the ability and the  X9-incentive to engage in discrimination against other offisland carriers.9 8 {O-#D  P7jQP#э AT&T Petition at 2 (citing OffIsland Order, 2 FCC Rcd at 661112). They note that the  X"-Commission imposed a variety of safeguards on PRTC to guard against discrimination.H" 8 {O_!-ԍ See supra para. 4.H x9. Stating that TPRI's application makes no mention of these requirements and provides no demonstration of PRTC's compliance with them, AT&T and Sprint argue that the Commission should find that grant of the TPRI application would not serve the public  X-interest.|8 yO~'-#D  P7jQP#э AT&T Petition at 3; Sprint Petition at 45.| AT&T asserts that allowing PRTC to provide switched international services on a",N(N(ZZ" resale basis, as requested, would bring about the reentry of PRTA and the Puerto Rican government into the provision of international services, effectively reversing the trend toward privatization of international services formerly provided by PRTA, which was begun by the 1992 transfer of LTLD assets to Spain's Telefonica. x 10. Sprint also argues that if TPRI's application is granted, the Commission must  Xv-impose additional conditions on PRTC/TPRI.hv8 yO-#D  P7jQP#э Sprint Petition at 79.h Citing extensive delays and difficulties in getting PRTC to switch customers to Sprint as their primary interexchange carrier (PIC), Sprint urges the Commission to require PRTC to report quarterly and publicly to the Commission on the length of time PRTC takes to accomplish PIC changes for itself and for its competitors. In view of specific private line provisioning difficulties that Sprint alleges it has experienced with PRTC, Sprint requests a similar reporting requirement with respect to the timeliness of PRTC's private line provisioning process. Sprint asks that we make clear that continued delays, problems or discrimination in these areas will result in forfeitures or cancellation of TPRI's Section 214 authority. Finally, Sprint says, any grant of authority to TPRI should await Commission action to implement the new Section 222 provisions on customer information.  Xb-x 11. TPRI opposes both petitions and urges the Commission to grant its application expeditiously. TPRI asserts that PRTC is in compliance with the conditions imposed by the  X4-Commission in its OffIsland Order. It states that delays in private line provisioning and PIC changes are not the result of anticompetitive intent, but of supply shortages and operational difficulties. It argues that, in any event, none of the matters raised by petitioners are germane  X-to its application.CX8 yO-ԍ TPRI Opposition at 3, 12.C  X-x 12. AT&T replies that, despite TPRI's statement of PRTC compliance, PRTC is  X-seriously in default of several of the conditions imposed by the OffIsland Order, including notification to all authorized offisland carriers of new or modified network configurations at the "makebuy" stage of development, and provision to all offisland carriers, at least semiannually, of the past and projected numbers of business and residence telephone lines, as  XR-well as average usage per line, for each end office.R8 {O -#D  P7jQP#э AT&T Reply at 3 (citing OffIsland Order, 2 FCC Rcd at 661112). AT&T avers that PRTC "has been routinely reconfiguring its network, reducing the number of central office hosts while converting hosts into remote switches, without prior notification of the conversion schedule to  X -AT&T.": z8 yO8%-ԍ AT&T Reply at 3.: In response to AT&T's repeated requests for required information, AT&T argues,"  ,N(N(ZZ["  X-PRTC provided an incomplete response after six months' delay.b8 {Oy-#D  P7jQP#э Id. at 34.b According to AT&T, these examples of PRTC's lack of compliance with the Commission's requirements preclude the Commission's granting TPRI's application.  X-x` ` 2. Discussion  Xv-x 13. TPRI's initial pleadings did not specifically address the allegations that PRTC is  X_-not in compliance with the conditions imposed in the OffIsland Order, except to say that PRTC is in compliance. Accordingly, the Telecommunications Division (Division) of the International Bureau convened a status conference and requested submission by TPRI of the  X -required information. Z8 yO' -Ѝ The Division concluded that the pleadings in this case, including TPRI's reply, left open certain factual  {O -questions regarding PRTC's inability or refusal to comply with disclosure requirements of the Puerto Rico Order relating to technical network changes and aggregate line and usage information; and its inability or refusal to provide, or delay in providing, PIC changes, international cable access, and private lines to Lambda, Sprint, and possibly others. The Division accordingly determined that a status conference should be held so that these open questions could be responded to directly.   X -x 14. The Division held a status conference on May 1, 1997, to clarify the various allegations of PRTC noncompliance with Commission conditions, anticompetitive behavior, and failure to perform, and to give TPRI the opportunity to respond to these allegations. TPRI and all three opposing parties attended this conference. TPRI provided supplemental  X-information from PRTC on subjects in dispute.8 yO-Ѝ TPRI Supplemental Information for May 1, 1997 Status Conference, filed May 1, 1997 (TPRI Supplement). This information includes: Xx(1) Two representative letters of Network Change Notifications. (# Xx(2) Reports entitled "Aggregate Control Office Information for 1995 and 1996," showing, by central office, historic numbers of business and residential lines and annual minutes of use (MOU); and annual average MOU per line by cluster. (#  X-Xx(3) Reports on Average Time of PIC Change Completion for 1996 and the first three months of 1997. (#  X-Xx(4) Reports on Private Line Service Order Completions for 1995, 1996 and the first  X~-four months of 1997, providing monthly reporting on completions of private line orders. TPRI stated in the conference that PRTC would develop a report that provides the average interval for installation of private line facilities for all carriers and the average interval for PRTC, and that TPRI would submit this report semiannually to the Bureau and concurrently to all parties to this proceeding.(#"", ,N(N(ZZz"Ԍ  X-Xx(5) PRTC's CPNI Policy Practice Guide of 03/01/93.4X8 yOb-Ѝ The CPNI Policy Practice Guide "establishes safeguards to protect customer privacy and to prevent the dissemination of confidential information relating to a customer's network services and telecommunications usage." TPRI Supplement, Section 11.4 (# Xx(6) A copy of the March, 1997, Lambda/PRTC local interconnection agreement.(# x  X-x15. These documents and other submissions made by TPRI respond to the questions and allegations raised in this proceeding in each of several areas. Regarding PRTC's completion of private line orders, TPRI submitted a letter to the Commission and all parties of record on May 21, 1997. That letter includes a report on PRTC's private line installation completions for April 1997. This submission reflects an average installation interval of 170 days for PRTC orders, and an average installation interval of 95 days for orders for other  X -carriers. 8 yO- xԍ Letter of May 21, 1997, from Richard J. Arsenault, Attorney for TPRI, to Troy F. Tanner, Chief, Policy and Facilities Branch, Telecommunications Division, FCC. In a letter dated June 11, Sprint argues that PRTC's private line provisioning problems extend far beyond simple delays, including failure to respond to inquiries on the status of private line orders and failure by PRTC to meet service delivery dates established by  X -PRTC itself. @8 yO-Ѝ Letter of June 11, 1997, from Kent Y. Nakamura, Sprint, to William F. Caton, Acting Secretary, FCC (Sprint June 11 Letter). We find that TPRI has satisfactorily addressed Sprint's allegations and the Commission's questions. The May 21 letter outlines steps PRTC is taking to improve its provisioning intervals. On December 29, 1997 and January 28, 1998, TPRI submitted reports on private line installation for June through November, 1997 and for December, 1997, respectively. These reports continue to show significantly shorter times for completion of  XK-other carriers' orders than for PRTC's own orders. K8 yO- xKԍ Letter of December 29, 1997, from Richard J. Arsenault, Attorney for TPRI, to Jacqueline Spindler, Esq.,  x;FCC (noting that the intervals stated for PRTC customers are based on incomplete data due to computer difficulties  xthat PRTC has committed to resolve); Letter of January 28, 1998, from Richard J. Arsenault, Attorney for TPRI, to Jacqueline Spindler, Esq., FCC.  TPRI assures the Bureau that PRTC's  X4-servicing of private line orders will not advantage TPRI.Z4 8 {Oe - xhԍ See Letter of June 26, 1997, from Richard J. Arsenault, Attorney for TPRI, to Troy F. Tanner, Chief, Policy  xZand Facilities Branch, Telecommunications Division, FCC ("Private line orders will be filled, as they are now, on a firstcome, firstserved basis consistent with the availability of outside plant required to fill such orders."). In addition, TPRI has committed to submit to the Bureau, and serve on the parties to this proceeding, a semiannual report providing the average interval for installation of private line facilities for all carriers and the  X-average interval for PRTC.8 {OB&- xhԍ See Letter of May 5, 1997, from Richard J. Arsenault, Attorney for TPRI, to Troy F. Tanner, Chief, Policy and Facilities Branch, Telecommunications Division, FCC (TPRI May 5 Letter).  ",N(N(ZZ"Ԍ X-ԙ x16. With regard to Sprint's allegations of PIC change irregularities, TPRI stated in the status conference and in its May 21 letter that the PRTC PIC change process was automated in August 1996, and that this has improved the average PIC change time from 19.23 business  X-days in March 1996 to 3.72 business days in March 1997. 8 yO4-Ѝ PIC Change Reports for 1996 and 1997, provided in the TPRI Supplement, document the improvement in PIC change performance. While Sprint complains of other  X-irregularities,! 8 {Ou- xYԍ These complaints include allegedly disparaging remarks about Sprint service by PRTC employees. See Letter of May 1, 1997, from Kent Y. Nakamura, Sprint, to William F. Caton, Acting Secretary, FCC. we find that PRTC's implementation of an automated system satisfactorily addresses the PIC change issue raised in this proceeding and that our Section 208 procedures are the appropriate remedy for problems with PIC order completion and the other  X_-irregularities complained of by Sprint."^_z8 {O - xԍ See 47 U.S.C.  208; 47 C.F.R.  1.720736 (adopted in Implementation of the Telecommunications Act of  {OT- x1996 and Amendment of Rules Governing Procedures to Be Followed When Formal Complaints Are Filed Against  {O-Common Carriers, CC Docket No. 96238, Report and Order, 12 FCC Rcd 22497 (1997)).  X1-x17. In response to allegations that PRTC has failed to provide historic and projected  X -line and usage information to offisland carriers on request, as required by the OffIsland  X -Order, TPRI provided at the status conference PRTC's Aggregate Control Office Reports for  X -1995 and 1996.Z# 8 {OA-ԍ TPRI Supplement.  See also supra para. 14.Z On October 22, 1997, TPRI also filed with the Commission and all parties of record PRTC's Aggregate Control Office Report for the first half of 1997 and its projected Aggregate Control Office Report for yearend 1997. TPRI on March 3, 1998, filed its year X -end report for 1997, including projections for 1998.$ 2 8 yO-Ѝ Letter of October 22, 1997, from Richard J. Arsenault, Attorney for TPRI, to Jacqueline Spindler, Esq., Telecommunications Division, FCC. PRTC notes in its cover letter that it also disseminated these reports to AT&TPR, Broadcast Media Satellite, Caribe Communications, Inc., CARIBCOM, Cellular One, MCI International, Inc., Sprint Caribe, Sprint International Service Integration, Telefonica Larga Distancia, Trescom, TUPR, Worldcom, Inc., and Worldxchange; Letter of March 3, 1998, from Richard J. Arsenault, Attorney for TPRI, to Jacqueline Spindler, Esq., Telecommunications Division, FCC. TPRI has agreed to provide to the Bureau and offisland carriers an aggregate report showing, by end office, historic and projected numbers of business and residence lines and average usage per line semiannually  Xf-within 60 days from the end of each calendar half.T%f8 {O!-ԍ TPRI May 5 Letter, supra note 31. T We conclude that this commitment  XO-provides adequate assurance that PRTC will satisfy this aspect of the OffIsland Order, which appears to exceed the requirements recently adopted by the Commission generally for  X#-disclosure of aggregate customer information by telecommunications carriers.C&#<8 {O&-ԍ See infra para. 18.C " &,N(N(ZZ("Ԍ X-x18. We dismiss as moot Sprint's request that we delay a grant of authority to TPRI until the Commission adopts regulations to implement provisions of Section 222 of the  X-Communications Act.'8 {OK-ԍ 47 U.S.C.  222, as added by Telecommunications Act of 1996, Pub. L. No. 104104, 110 Stat. 56. The Commission on February 19, 1998 promulgated regulations to implement the statutory obligations of Section 222 relating to carrier use and disclosure of CPNI and other customer information obtained by carriers in their provision of  X-telecommunications service.3(Z8 {O-Ѝ See Implementation of the Telecommunications Act of 1996: Telecommunications Carriers' Use of Customer Proprietary Information and Other Customer Information and Implementation of the NonAccounting  {O* -Safeguards of Sections 271 and 272 of the Communications Act of 1934, as Amended, CC Docket Nos. 96115 and 96149, Second Report and Order and Further Notice of Proposed Rulemaking, FCC 9827 (rel. Feb. 26,  {O -1998) (Section 222 Order and Further Notice).3 We find that these rules supplant the CPNI requirements  Xv-applied to PRTC in the OffIsland Order. As discussed above, however, we will condition this authorization on TPRI's commitment to provide the Bureau and offisland carriers on a  XJ-semiannual basis the historical and projected traffic data which the OffIsland Order required PRTC to make available to carriers upon request. We also note that PRTC continues to be  X -subject to the OffIsland Order requirement that it ensure that information about other offisland carriers' customers is not made available to PRTC (or any affiliate's) offisland personnel. This obligation will continue in force at least until the Commission adopts new or  X -modified requirements on PRTC's use of such carrier information.) 8 {O- xԍ See Section 222 Further Notice,  206207 (requesting comment on protection for carrier information and enforcement mechanisms).  X - x  X -x19. AT&T challenged PRTC for having failed to provide network change notifications  X-as directed in the OffIsland Order.*|j 8 {O- x.ԍ The OffIsland Order generally requires PRTC to notify all authorized offisland carriers when new or  xmodified network configurations or services that affect interconnection with the island network are under  yOC- xdevelopment for any portion of its service area. Such information must be disclosed at the "make/buy point." 2 FCC  x,Rcd at 6612. The order also requires PRTC to disclose the technical network and market information to the public  xtwelve months prior to the introduction of the new or modified network configuration or service, by a means  {O- xadequate to communicate the information effectively and efficiently. Id. See also OffIsland Reconsideration Order, 8 FCC Rcd at 70 & n.64 (reaffirming the network information disclosure requirements).  In the status conference, TPRI tacitly acknowledged that PRTC may have made network changes or modifications without the required notification  Xj-to offisland carriers. In the supplement submitted at the conference, however, TPRI showed two sample notification letters (from June 1996 and February 1997) as evidence of PRTC's current commitment to compliance with this requirement. In a letter to the Commission dated May 5, 1997, counsel for TPRI and PRTC also represented that "PRTC presently provides advance notice of network changes to offisland carriers by fax and regular mail. PRTC is implementing procedures to ensure that future notifications of network changes comport with  X-applicable Commission rules."P+8 {O?'-ԍ TPRI May 5 Letter, supra note 31.P We find that these sample letters and representations of" @+,N(N(ZZ" compliance provide adequate assurance that PRTC will meet its network disclosure  X-obligations.},\8 yOb- xԍ We note that, as an incumbent local exchange carrier, PRTC is subject to the Part 51 network disclosure  {O*- xrequirements (47 C.F.R.  51.32551.335) adopted in the Local Competition Second Report and Order, 11 FCC  {O-Rcd 19392 (1996), recon. pending.} We encourage parties to inform the Commission of any demonstrated noncompliance by PRTC with its network disclosure obligations.  X-x20. While we do not take lightly any allegations of anticompetitive behavior, we find that TPRI has adequately addressed the allegations made here. TPRI and PRTC have provided the requested information regarding PIC changes, network notification, private line order completions, and aggregate customer information. TPRI and PRTC have also provided information regarding changes made recently, or currently underway, to improve PRTC's performance and responsiveness, including automation of the PIC change process and continuing improvement in private line provisioning. Further, TPRI has committed, and will be required, to file with the Bureau and serve concurrently on all parties to this proceeding semiannual reports from PRTC on private line provisioning, and to make available to the  X -Bureau and offisland carriers the aggregate customer information specified in the OffIsland  X -Order, until further ordered by the Commission. These requirements will facilitate monitoring and review, particularly of PRTC's private line provisioning. Any problems with order completions (for private lines, PIC changes, or other services) can appropriately be addressed in the context of the Section 208 complaint process. We find that these measures adequately address our concerns and the concerns raised by the parties to this proceeding. PRTC's or TPRI's failure to comply with the conditions of this authorization, or with any  X:-specific or general requirements imposed on either carrier by Commission rule or order, may result in monetary forfeiture or our revisiting this authorization, upon petition of a party or upon our own initiative.  X-x21. Finally, we disagree with AT&T that we should deny this application because it "bring[s] about the reentry of PRTA and the Puerto Rican government into the provision of  X-international services."?-8 yOM-ԍ AT&T Petition at 45.? In the OffIsland Order, the Commission determined that competition in the domestic and international offisland market is feasible and would promote the public interest. In making this determination, the Commission anticipated PRTC's  Xm-participation in the offisland market, and set forth guidelines covering such entry..m|8 {O!-#D  P7jQP#э See, e.g., LTLD Resale Grant Order, 4 FCC Rcd 4496 (Intl. Fac. Div. 1989) (citing OffIsland Order). We reject AT&T's suggestion that we should effectively reverse this decision. AT&T is correct  X?-that the TLD Assignment Order supported the privatization of PRTC's offisland operations. In stating that it has been Commission policy to favor private ownership of international facilities, the Commission noted that privatization would "encourage competition, lower rates," .,N(N(ZZ["  X-and bring better service to the public."W/8 {Oy-ԍ TLD Assignment Order, 8 FCC Rcd at 116.W The Commission also noted that the proceeds from  X-the sale would go towards education reform in Puerto Rico. The TLD Assignment Order, however, cannot be read to prohibit a PRTA subsidiary from reentering the offisland market.  X- x B. Assertions of Refusal to Provide Access to PRTC Facilities  Xx-x` ` 1. Positions of the Parties  XJ-x22. Lambda argues in its petition that extended delays in meeting Lambda's request for equipment space in PRTC's Isla Verde Cable Station warrant denial of TPRI's  X -application.0z Z8 yO' -Ѝ Lambda Petition at 46. Lambda states that interexchange carriers whose services TPRI proposes to resell have located their primary points of presence (POPs) at the Isla Verde Cable Station, which serves as the entry point in Puerto Rico of the Taino Carib Fiber Optic Cable System and the Antillas I system, where interexchange carriers deliver outbound and pick up inbound traffic. The Isla Verde Cable Station is owned by PRTC and operated by TUPR, another PRTAcontrolled company. PRTC network and dedicated line facilities are also  {O-located in the Isla Verde Cable Station, according to Lambda. See also Lambda Opposition to Pro Forma Amendment, filed Feb. 10, 1997, pp. 712 (Lambda Feb. 10 Opposition). Lambda avers that TUPR engaged in "obstructionist conduct" in refusing to execute a lease agreement allowing Lambda to locate its fiber optic facilities in the cable  X -station.1 8 yO;- xԍ Letter of April 14, 1997, from Richard Rubin, Attorney for Lambda, to Peter Cowhey, Acting Chief, International Bureau, FCC (Lambda Apr. 14 Letter). Lambda states that TUPR "continually refused Lambda's requests and requests by owners of the Taino Carib cable" for collocation by Lambda to provide a competitive switched transport and access service for the interexchange carriers' interstate and international traffic. According to Lambda, PRTA's actions, as owner of both TUPR and  X-PRTC, constitute "blatantly anticompetitive conduct"?2 8 yO7-ԍ Lambda Petition at 5.? and deny to Puerto Rico consumers the  X{-benefits of competition in the interstate switched transport and access market.M3{ 8 yO-ԍ Lambda Feb. 10 Opposition at 11. M Interexchange carriers that have Puerto Rico as an originating or terminating point are PRTC's "captive audience" for transport and access services, Lambda asserts, and it is with these carriers that  X6-PRTC now seeks to compete as a reseller.3468 {O!-ԍ Id.3  X-x23. Lambda asserts that other conduct by PRTC to keep Puerto Rico's intraisland and offisland telecommunications market closed to competition, combined with PRTC's status as an unregulated stateowned carrier, also constitute grounds for denial of the application. Sprint supports this argument and points to its own experience of lengthy delays in its dealings with PRTC, specifically with regard to PIC changes and private line" 4,N(N(ZZ"  X-provisioning orders (discussed in Section A supra).)58 yOy-#D  P7jQP#э Sprint Petition at 57. Sprint also informs the Commission of "the differing stances PRTC has taken on the question of competition" before the Commission and before courts in Puerto Rico. While it asserts in the instant proceeding that competition will soon come to Puerto Rico's local exchange market, Sprint notes, PRTC has filed suit in Puerto Rico seeking to retain its governmental monopoly over all telecommunication services in  yO-Puerto Rico. Sprint Reply at 911. Sprint refers to PRTC's filing for a declaratory ruling that the local exchange monopoly in Puerto Rico should be retained. We do not consider PRTC's filing for declaratory ruling to be relevant to the merits of TPRI's international Section 214 application. We do consider relevant, however, PRTC's compliance with legal and regulatory requirements in its provision of regulated activities that affect the provision of U.S. international telecommunications services. )  X-x24. Specifically, Lambda avers that there is no agency regulating PRTC's monopoly intraisland offerings and that the 1974 enabling statute makes clear that PRTC is self X-regulating.68 {O -#D  P7jQP#э Lambda Petition at 7 (citing Laws of Puerto Rico, Annotated, 27 L.P.R.A. 407(m)). ĺ Lambda states that, while it has received authorization from the Puerto Rico Public Service Commission to provide certain intraisland services, it has been unable to  Xx-obtain reasonable interconnection with PRTC's network.D7x* 8 yOS-ԍ Lambda Petition at 8 n.11.D As a member of the NECA pools, Lambda argues, PRTC offers only bundled, economically infeasible interconnection, and has  XJ-thus enjoyed a monopoly in interstate access services as well.`8J 8 {O-#D  P7jQP#э Id. at 8.` Sprint argues that regulation of telecommunications in Puerto Rico is still in an embryonic state, and that competitors still suffer significant disadvantages in Puerto Rico, such as the lack of equal access for intra X -island toll calling.49Z L 8 {O-Ѝ Sprint June 11 Letter, supra note 28. If PRTC receives the authority it seeks, Sprint argues, it would for some time be the only carrier able to offer 1+ dialing for all toll calls a situation that would exacerbate the current difficulties.4 Citing the Commission's Local Competition Notice,: n8 {O$-#D  P7jQP#э  Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, CC Docket  {O-No. 9698, Notice of Proposed Rulemaking, 11 FCC Rcd 14,171 (1996) (Local Competition Notice). See also  {O-First Report and Order, 11 FCC Rcd 15499 (1996), aff'd in part and vacated in part sub nom. Competitive  {O-Telecommunications Ass'n v. FCC, 117 F.3d 1068 (8th Cir. 1997), vacated in part on reh'g, Iowa Utilities Bd. v.  {OL-FCC, 120 F.3d 753, further vacated in part sub nom. California Public Utilities Comm'n v. FCC, 124 F.3d 934,  {O -writ of mandamus issued sub nom. Iowa Utilities Bd. v. FCC, No. 963321 (8th Cir. Jan. 22, 1998), pet. for cert.  {O -granted, Nos. 97826, 97829, 97830, 97831, 971075, 971087, 971099, and 971141 (U.S. Jan. 26, 1998), Order on Reconsideration, 11 FCC Rcd 13042 (1996), Second Order on Reconsideration, 11 FCC Rcd 19738 (1996), Third Order on Reconsideration and Further Notice of Proposed Rulemaking, 12 FCC Rcd 12453 (1997),  {O:#-further recon. pending. Sprint urges that the Commission make any grant of authority to TPRI "subject to the competitive checklist for " :,N(N(ZZ" "  X-incumbent LECs as ultimately implemented by the Commission.";8 yOy-Ѝ Though it is not clear from Sprint's pleading whether it refers to the "competitive checklist" imposed on Bell Operating Companies, or the more generic obligations imposed on independent local exchange carriers, the  {O -use of the phrase "competitive checklist," and the context, indicate that Sprint argues for the former. See Sprint Petition at 89. TPRI's opposition to the petitions refutes Sprint's suggestion with reference to the competitive  {O-checklist for BOCs; in its Reply, Sprint accepts this characterization. See Sprint Reply at 8.  X-x25. TPRI attacks Sprint's and Lambda's petitions as "inaccurate and frivolous," stating that neither PRTC's status as a stateowned entity, nor the regulatory status of PRTC's  X-intrastate service, is germane to the Commission's consideration of this application.f<|8 yO -#D  P7jQP#э TPRI Opposition at 7.f TPRI argues that Lambda's assertions regarding unavailability of equipment space at the Isla Verde Cable Station are inaccurate and inapposite to this case, and should, if valid, be brought as a Section 208 complaint. TPRI explains that Lambda's request for equipment space at Isla Verde could not be granted because the right to space in that cable station is reserved for the  X1-carrier/owners of the cables landing at the station. According to TPRI, these are the proper parties to whom Lambda should have addressed its request. In its reply, Lambda challenges PRTC's explanation regarding the Isla Verde Cable Station as lacking credibility because  X -PRTC, which is not a carrier/owner of the cables, maintains its network and transport  X -facilities in the cable station.t= 8 yO-#D  P7jQP#э Lambda Reply to Opposition at 910.t  X -x` ` 2. Discussion  Xy-x26. While we do not dismiss or disregard Lambda's assertions regarding its difficulty in locating fiber optic facilities in the Isla Verde Cable Station, we do not find them sufficient to warrant denial of TPRI's application. TUPR and Lambda executed a Sublease Agreement on February 21, 1997 albeit more than two years after Lambda first requested space from  X-TUPR.r>Z8 {Oj- xԍ See Letter of December 23, 1997, from Richard J. Arsenault, Attorney for TPRI, to Susan O'Connell, Esq.,  xTelecommunications Division, FCC (attaching Sublease Agreement, dated February 21, 1997, between Telecomunicaciones Ultramarinas de Puerto Rico, Inc. and Lambda Operations Corporation).r TPRI maintains, however, that Lambda itself could have taken on the necessary task of obtaining consent for the lease from the numerous carrier/owners of the cable, but chose to  X-rely on TUPR.? 8 yO^"- xԍ TPRI states that it was necessary to obtain the consent of thirtytwo parties located in nearly two dozen countries. TPRI Reply at 4 (February 20, 1997). It states that TUPR acted diligently in obtaining consent by November 16, 1996 and then began the process of working with Lambda on design and engineering matters, and then on final negotiation of the terms of the lease. TPRI represents that TUPR is "pleased to provide service to Lambda and to any other party that so requests, but in complying with such requests, TUPR will not violate any of its other obligations to other" ?,N(N(ZZQ"  X-parties.";@8 {Oy-ԍ Id. at 6. ; Given TPRI's representations, and the complexities involved in collocating multiple carriers' facilities at an international cable station, we do not find on this record that TUPR's or any affiliated company's conduct in this matter justifies denial of the requested international resale authorization. We note that Lambda also filed a petition requesting that the Commission modify the cable landing licenses for the Taino Carib and Antillas I cables to require that the Isla Verde station not be owned or controlled by PRTC and to order PRTC to lease the requested space to Lambda. Lambda did not provide any additional evidence in that  X_-proceeding that would cause us to reach a different conclusion.A_Z8 {Oj - xYԍ See Telefonica Larga Distancia de Puerto Rico, et al., File Nos. SCL95012(M), 95008(M) and 92002(M), Order, DA 98926 (Tel. Div. rel. May 19, 1998) (denying Lambda's petition). x27. We also reject as a basis for denial Sprint's and Lambda's other arguments related to the status of regulation in Puerto Rico and PRTC's alleged attempts to maintain a monopoly in intraisland service and interstate access service. We note that, while it was true at the time of the filing of this application that Puerto Rico had no independent regulator, that is no longer the case. In September 1996, the Puerto Rico Telecommunications Act of 1996 came into force, and the Telecommunications Regulatory Board of Puerto Rico was established. That board is an independent regulator with general and incidental powers and duties, and has actively pursued its mandate through arbitrating interconnection agreements, adjudicating disputes, and conducting proceedings in universal service and telecom relay services, among others. Indeed, Lambda and PRTC reached an interconnection agreement pursuant to Sections 251 and 252 of the Communications Act on March 18, 1997, albeit after two years of negotiation and after the Regulatory Board was formed and an arbitration  X-process had commenced.B8 {O-ԍ Lambda April 14 Letter, supra note 49. See also TPRI Supplement (attaching the interconnection agreement). We also note that PRTC filed its own interstate tariff for expanded interconnection on May 6, 1996. Further, in response to Sprint's concerns regarding equal access for intraisland toll calling, TPRI states that PRTC will comply with  X-relevant Commission requirements for equal access.RCF8 {O-ԍ TPRI June 26 Letter, supra note 30.R x28. Finally, we reject Sprint's assertion that any grant of authority to TPRI must be subject to PRTC meeting the competitive checklist imposed by Section 271 of the  X|-Communications Act on Bell Operating Companies (BOCs).D|8 {O#-ԍ 47 U.S.C.  271, as added by Telecommunications Act of 1996, Pub. L. No. 104104, 110 Stat. 56. Congress tailored the competitive checklist carefully, imposing it on these specified carriers only, and not on all local exchange carriers. PRTC is an independent local exchange carrier, not a BOC, and the checklist accordingly does not apply to PRTC. Absent any compelling argument why PRTC should be treated differently than Congress indicated, we decline to extend the BOC" j D,N(N(ZZ" competitive checklist to PRTC.  X- x C. Request for NonDominant Treatment  X-  X-x` ` 1. Positions of the Parties  Xv-x29. Lambda argues that PRTC's pro forma amendment to substitute TPRI as the applicant is a "ruse" to cover anticompetitive conduct by PRTC. It argues that the Commission should impose on PRTC more complete structural separation than the Commission required when PRTC originally entered the offisland telecommunications  X -market.KE 8 yO -ԍ Lambda Feb. 10 Opposition at 16.K Sprint challenges PRTC's pro forma amendment as insufficient to address concerns about anticompetitive behavior. According to Sprint, the amendment justifies, at most, a limited and conditioned grant subject to PRTC's demonstrated compliance with existing conditions, plus required reporting by PRTC of its speed of private line provisioning and PIC  X -changes for TPRI and TPRI's competitors.F X8 {O- xԍ See generally Section A, supra and Sprint Opposition to Pro Forma Amendment, filed Feb. 12, 1997 (Sprint Feb. 12 Opposition). Sprint also expresses concern that, through its control of the Isla Verde Cable Station, PRTC has the ability to delay offisland carrier  X-connections within the cable station cross connect facility.fG8 {O-ԍ See generally Sprint Reply (filed May 31, 1996).f  Xf-x30. TPRI responds that, as a separate corporate affiliate of PRTC, it qualifies for nondominant status in the provision of international resale service, despite these assertions to the  X8-contrary.wH8D8 yO--#D  P7jQP#Ѝ TPRI Reply at 13.w It also challenges Lambda's assertion that we cannot grant Section 214 authority to TPRI without it first filing for and obtaining specific approval to establish interlocking  X -directorates pursuant to Section 212 of the Act.=I 8 {O-ԍ Id. at 67. =  X-x` ` 2. Discussion  X-x31. With regard to the interlocking directorships of TPRI and PRTC, Section 62.12 of the rules requires that TPRI apply for a finding of common ownership in order to qualify for an exemption from the Section 212 requirement of prior authorization for interlocking  Xi-directorates. Based on the information contained in the pro forma amendment, we conclude that TPRI and PRTC are commonly owned within the meaning of Section 62.2 of the  X=-Commission's rules and that they therefore may establish interlocking directorates.RJ=f 8 {OT'-ԍ See 47 C.F.R.  62.2, 62.12.R Within"= J,N(N(ZZ" 30 days from the grant of the instant application, TPRI and PRTC shall file the information required by Section 62.26 of the rules. This submission should refer to File Number EID735 in the Common Carrier Bureau.  X-x32. Regarding the question of TPRI's regulatory classification, our regulations governing the U.S. international services market traditionally have distinguished between "dominant" and "nondominant" carriers. We have classified carriers operating in the U.S. market, whether U.S. or foreignowned, as dominant in their provision of U.S. international services on particular routes in two circumstances: (1) where we have determined that a U.S. carrier can exercise market power on the U.S. end of a particular route; and (2) where we have determined that a foreign carrier has market power on the foreign end of a particular  X -route that can adversely affect competition in the U.S. international services market.KJ 8 {O| -Ѝ See generally Rules and Policies on Foreign Participation in the U.S. Telecommunications Market and  {OF -Market Entry and Regulation of ForeignAffiliated Entities, Report and Order in IB Docket No. 97142 and  {O-Order on Reconsideration in IB Docket No. 9522, 12 FCC Rcd 23891, 2398788 (1997), recon. pending  {O-(Foreign Participation Order). As the Commission notes in the Foreign Participation Order, the regulations associated with dominant carrier classification due to the market power of a U.S. carrier on the U.S. end of a route include rate of return or price cap regulation to ensure that rates are just and reasonable, and more stringent requirements pursuant to Section 214 of the Act to prevent investment in unnecessary new plant and to bar  {O-service discontinuances in areas served by a single carrier. Id. n.434.   X -x 33. The Commission recently concluded in the LEC Regulatory Treatment Order that incumbent independent local exchange carriers' (ILECs') market power in local exchange and exchange access markets did not warrant imposing traditional dominant carrier safeguards on  X-their provision of inregion international services.L8 {O-Ѝ See Regulatory Treatment of LEC Provision of Interexchange Services Originating in the LEC's Local  {O-Exchange Area and Policy and Rules Concerning the Interstate, Interexchange Marketplace, Second Report and Order in CC Docket No. 96149 and Third Report and Order in CC Docket No. 9661, FCC 97142 (rel. Apr.  {Oy-18, 1997) (LEC Regulatory Treatment Order), Order on Reconsideration, FCC 97229 (rel. June 27, 1997),  {OC-Order, DA 98556 (Com. Car. Bur. rel. Mar. 24, 1998) (ordering partial stay), further recon. pending.  The Commission also concluded, however, that incumbent ILECs such as PRTC may provide inregion international services  Xd-only through an affiliate that fulfills the separation requirements of the Competitive Carrier  XO-Fifth Report and Order.MO 8 {O-Ѝ See LEC Regulatory Treatment Order,  188191 (citing Policy & Rules Concerning Rates for  {O\ -Competitive Common Carrier Services and Facilities Authorizations Therefor, Fifth Report & Order, 98 FCC 2d  {O&!-1191 (1984) (Competitive Carrier Fifth Report and Order). The separation requirements that the affiliate must meet are that it: (1) maintain separate books of account; (2) not jointly own transmission or switching facilities with its affiliated LEC; and (3) acquire any services from its affiliated LEC at tariffed rates, terms, and  {O#-conditions. See LEC Regulatory Treatment Order,  144. The LEC Regulatory Treatment Order modified the third separation requirement to permit the affiliate, in addition to taking exchange services by tariff, to take unbundled network elements or exchange services subject to the same terms and conditions as provided in an  {O%-agreement approved under Section 252 of the Act to which the independent LEC is a party. Id.  164.   ":lM,N(N(ZZ"Ԍx!34. In this case, PRTC has amended its application to substitute a separate corporate affiliate, TPRI, as the applicant. No persuasive evidence has been presented that the creation by PRTC of TPRI to provide the requested offisland international services is anything less than credible. TPRI states for the record that it will comply with the separation requirements  X-adopted in the LEC Regulatory Treatment Order.hN8 yO-ԍxThese requirements are codified at 64 C.F.R.  1903.h Further, no party has presented evidence  X-that, contrary to the findings of the Commission in the LEC Regulatory Treatment Order, TPRI will have, upon entry or soon thereafter, the ability to raise the price of offisland international service by restricting its output of such services. We therefore find no basis to regulate TPRI as dominant in its provision of international offisland service due to its market  X5-power in the provision of local exchange and exchange access facilities and services.WO5X8 {O> -  ԍxThe Commission concluded in the LEC Regulatory Treatment Order that incumbent independent LECs  xshould be classified as dominant in the provision of domestic and international long distance services only if they  {O - xhave the ability to raise prices of those services by restricting their own output of those services. Id.  156, 197.  x,Sprint has not demonstrated that TPRI has such ability by virtue of PRTC's control of the Isla Verde Cable Station. W We also find no basis in this record to impose separation requirements on TPRI that are stricter  X -than those the Commission adopted in the LEC Regulatory Treatment Order for ILEC provision of inregion international services. The reporting requirements that we adopt as conditions of this order respond to specific concerns raised by the parties about prior conduct by PRTC. Further, we have stated that PRTC's or TPRI's failure to comply with the conditions of this authorization, or with any specific or general requirements imposed on  X-either carrier by Commission rule or order, may result in monetary forfeiture or our revisiting this authorization, upon petition of a party or our own initiative.  XQ-=" III. Conclusion ă x"35. We conclude that grant of TPRI's application to resell the switched services of other U.S. international common carriers is in the public interest. We find that TPRI has satisfactorily addressed the concerns raised by the parties to this proceeding and that the reporting requirements imposed here as conditions of TPRI's authorization will facilitate monitoring and review, particularly of PRTC's provisioning of private lines to other offisland carriers. As we have also made clear, PRTC's or TPRI's failure to comply with the conditions of this authorization, or with any specific or general requirements imposed on either carrier by Commission rule or order, may result in monetary forfeiture or our revisiting  Xk-this authorization, upon petition of a party or our own initiative.     XT-  X=-' IV. Ordering Clauses ă x#36. Accordingly, IT IS HEREBY CERTIFIED that the present and future public interest, convenience and necessity require a grant of the present application, and IT IS ORDERED that application File No. ITC96214 IS GRANTED and Telefonica de Puerto" O,N(N(ZZ" Rico, Inc. (TPRI) is authorized to resell the international switched services of authorized U.S. common carriers between the United States and all international points, subject to the Commission's exclusion list and all current and future Commission regulations, including those specifically listed below, as well as the conditions set out below. x$37. IT IS FURTHER ORDERED that the petitions to deny or deny or condition, filed by AT&T Corp. (AT&T), Lambda Communications, Inc. (Lambda), and Sprint Communications Company, L.P. (Sprint) ARE GRANTED IN PART AND ARE OTHERWISE DENIED. x%38. IT IS FURTHER ORDERED that TPRI shall file Aggregate Control Office Information showing, by central office, numbers of business and residential lines and annual and average minutes of use (MOU) per line. This report is to be filed with the Chief, International Bureau and provided to all offisland carriers semiannually, showing both historic and projected numbers, within 60 days from the end of each calendar half, effective January 1, 1998. x&39. IT IS FURTHER ORDERED that TPRI shall file Reports on Private Line Service  Xb-Order Completions providing monthly data on completions of private line orders. This report shall provide the average interval for installation of private line facilities for all offisland carriers and the average interval for PRTC. This report is to be filed with the Chief, International Bureau and served on all parties to this proceeding semiannually, within 60 days from the end of each calendar half, effective January 1, 1998. x'40. IT IS FURTHER ORDERED, pursuant to 47 C.F.R.  62.12, that Telefonica de Puerto Rico, Inc. and the Puerto Rico Telephone Company ARE COMMONLY OWNED by the Puerto Rico Telephone Authority and ARE EXEMPT from the prior authorization of interlocking directorates required by Section 212 of the Act. x(41. IT IS FURTHER ORDERED that TPRI SHALL FILE within 30 days of the grant of this application the information required by Section 62.26 of the Commission's rules, 47 C.F.R.  62.26. x)42. IT IS FURTHER ORDERED that TPRI shall comply with the requirements of Sections 63.19 and 63.21 of the Commission's rules, 47 C.F.R.  63.19 & 63.21. "O,N(N(ZZ" x*43. This Order is issued under Section 0.261 of the Commission's rules and is effective upon adoption. Petitions for reconsideration under Section 1.106, or applications for review under Section 1.115 of the Commission's rules, may be filed within 30 days after the  X-date of public notice of this Order (see Section 1.4(b)(2)). x` `  hh@FEDERAL COMMUNICATIONS COMMISSION x` `  hh@Regina M. Keeney x` `  hh@Chief, International Bureau