Exhibit 18
                                                                 ----------

                             PREFERABILITY LETTER 
                      ON DISCRETIONARY ACCOUNTING CHANGE


Pacific Bell
140 New Montgomery
San Francisco, CA 94105

We are  providing this letter for  inclusion as an  exhibit to your  Form 10-K
filing pursuant to Item 601 of Regulation S-K.

We  have read  management's justification  for change  in accounting  from the
"amortization" revenue recognition method to the "point of publication" method
contained in  Pacific Bell's Form 10-K  for the year ended  December 31, 1996.
Based on our reading of the data and discussions with the Company officials of
the business judgment and business planning factors relating to the change, we
believe management's justification is reasonable.  Accordingly (in reliance on
management's  determination  regarding  elements  of  business  judgment   and
business  planning),  we concur  that  the  new  adopted accounting  principle
described  above is preferable in  Pacific Bell's circumstances  to the method
previously applied.


/s/ COOPERS & LYBRAND L.L.P.
San Francisco, California
February 27, 1997