January 2, 1996

Mr. Richard L. Vega, Sr.
RLV-PCS Partnership
235 Hunt Club Blvd.
Longwood, FL 32779

Dear Mr. Vega:

     In your letter dated December 12, 1995, you requested a waiver of the Commission's
rules to permit RLV-PCS Partnership ("RLV-PCS") to amend its short-form application to
participate in the Broadband PCS C block auction.  Specifically, RLV-PCS wishes to add
market B439 to its application.  You state that RLV-PCS omitted this market inadvertently
when it filed its original application electronically.  You further state that this omission went
unnoticed when RLV-PCS resubmitted its application.  You claim that the addition of market
B439 to the short-form application would be a minor amendment.

     RLV-PCS's request is denied.  The Supplemental Bidder Package indicates that a
change in market designation will be considered a "major amendment," and therefore
prohibited under the Commission's rules.  Supplemental Bidder Package, p. 30 (rel. October
11, 1995).  The rules make clear that applicants may make only minor amendments to their
applications after the filing deadline.  Specifically, Section 24.822 allows applicants "to amend
their Form 175 applications to make minor amendments to correct minor errors or defects
such as typographical errors."  47 C.F.R.  24.822(b).  In addition, Section 1.2105 states that
"Form 175 may be amended or modified to make minor changes or correct minor errors in the
application (such as typographical errors)" and specifies limited circumstances in which
applicants may modify their short-form applications to reflect formation of consortia or
changes in ownership.  47 C.F.R.  1.2105.  Because RLV-PCS's petition does not
demonstrate that the failure to include B439 in its original application was due to
"typographical errors" or similar clerical errors, we deny RLV-PCS's request.

     Finally, we note that the Commission's anti-collusion rules (47 C.F.R.  1.2105(c))
also bars RLV-PCS from adding an additional market to its 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 short-form filing deadline, applicants may not discuss the substance
of their bids or their 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).        
     


     For the reasons stated above, RLV-PCS's request IS HEREBY DENIED.


                         Sincerely,


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