D. Request

CALTEL seeks two modifications to the current procedure governing Commission approval of §§ 851 through 854 transactions for NDIECs and CLECs. The first modification seeks to permit these competitive telecommunications carriers to use the advice letter procedure instead of the application process for "all" prospective transactions subject to these code sections. The second modification seeks to permit the use of an advice letter procedure instead of the application process for the transfer of certificated entities' control or assets to subsidiaries. Both of these changes would enable NDIECs and CLECs to complete transactions subject to §§ 851 through 854 expeditiously and utilize less Commission staff time. CALTEL's application focuses on making the advice letter procedure applicable to mergers of certificated entities and to internal corporate reorganizations.