Implementation Schedule

Any rule that would necessitate a computer system change is a complex, multi-step process that requires built-in time for testing before being implemented. Changes to both software and hardware systems may be required, technology platforms must be integrated (for example a change in billing system or disclosures in contracts might also require changes in web-pages and customer service operations) and employees must be trained. Although we attempted to carefully draft these rules to be as minimally disruptive as possible, many carriers will likely need to make changes to their systems, including those mentioned above. There is no compelling reason not to give carriers the time they indicated is necessary to make these changes with minimal interruption to service or confusion for customers. Therefore, Commission-regulated telecommunications carriers of all classes shall bring their operations into full compliance G.O ____ and this interim order not later than 18 months after the date of enactment. Any carrier unable to meet this schedule for compliance shall file an advice letter with the Commission's Telecommunications Division explaining the reasons for its inability to meet the 18 month deadline and stating a date certain by which it will be in compliance, which shall in no event be more than 24 months from the effective date of this interim order.