January 2, 1995

Jack E. Robinson
Chief Executive Officer
National Telecom PCS, Inc.
Clearwater House
2187 Atlantic Street
Stamford, CT 06902

Dear Mr. Robinson:

     National Telecom PCS, Inc., ("NatTel") filed a petition for waiver of the
Commission's rules, dated December 9, 1995, seeking permission to amend its short-form
application to participate in the Broadband PCS "C block" auction.  Specifically, NatTel would
like to reduce the markets it is eligible to bid on from "all" to two just markets, BTA 491 and
BTA 388.   NatTel filed a petition for waiver dated December 4, 1995, seeking to increase the
size of its upfront payment after the upfront payment deadline had expired.  NatTel's earlier
waiver request was denied by the Auctions Division of the Wireless Telecommunications
Bureau on December 8, 1995.  As a result of that action, NatTel states that it is now eligible
to bid on only a fraction of the markets for which it originally applied.  Consequently, NatTel
would like to amend its application to reflect its current eligibility.

     NatTel's request is denied.  Changes in market designations after the short-form filing
deadline has expired are considered "major" amendments.  As such, they are prohibited under
the Commission's rules.  See, 47 C.F.R.  1.2105 and 24.822.  NatTel claims that because
the Commission allowed three applicants to make changes to their market designations after
the short-form filing deadline (see, "Qualified Bidders and Bidding Instructions for December
18, 1995 Broadband PCS C Block Auction", fn. 1, Public Notice (rel. December 8, 1995)),
NatTel should be given the same opportunity to amend.  However, NatTel's situation is in no
way similar to that of the three applicants who were granted waivers.  Two of the applicants,
Antigone Communications Limited and Magnacom Wireless, L.L.C., were permitted to delete
markets from their short-form applications because the markets at issue were originally listed
due to typographical errors.  Their requests were therefore considered to be minor
amendments.  See, Letter to Gene DeJordy, Esq., December 8, 1995; Letter to David J.
Kaufman, Esq., December 8, 1995.  The third applicant, SJI, Inc., was permitted to add a
market as a result of the Sixth Circuit's decision in Cincinnati Bell Tel. Co. v. FCC, No. 94-3701 (6th Cir. Nov 9, 1995) and the Commission's action in its November 13, 1995 Public
Notice ("FCC will Proceed with C Block Auction on Schedule", Public Notice ).  See, Letter
to Sara F. Seidman, Esq., December 11, 1995.  Because changes to market designations are
generally considered major amendments and therefore prohibited under the Commission's
rules, and because NatTel's request does not conform to Commission precedent, NatTel's
request must be denied.

     Finally, we note that the Commission's anti-collusion rules (47 C.F.R.  1.2105(c))
also acts as a bar to NatTel's request to delete markets from its short-form application.  The
anti-collusion rules require an applicant to identify on its short-form application all parties with
whom it has entered into a bidding consortium or other joint bidding arrangement as of the
short-form filing deadline.  After the deadline, applicants may not discuss the substance of
their bids or bidding strategies with other applicants (other than those identified on the short-form application) that are bidding in the same geographical license areas.  47 C.F.R. 
1.2105(c)(1); Fourth Memorandum Opinion and Order in PP Docket No. 93-253, 9 FCC Rcd
6858, 6868 (1994).  Because NatTel listed that it wished to be eligible to bid on "all" licenses
in the C block auction, it is prohibited from discussing the substance of its bids or bidding
strategies with all other applicants except those that it may have identified on its short-form
application.

     For the reasons stated above, NatTel's request IS HEREBY DENIED.


                         Sincerely,


                         Kathleen O'Brien Ham
                         Chief, Auctions Division
                         Wireless Telecommunications Bureau