The Commission's Rules of Practice and Procedure require that an OIR preliminarily determine the category of the proceeding and the need for hearing.16 As a preliminary matter, we determine that this proceeding is quasi-legislative and because the issues presented are largely policy, that evidentiary hearings (EH) may not be necessary. As with earlier procurement proceedings, many issues may lend themselves to resolution through a combination of workshops and formal comments.
16 Rule 6(c)(2).