X. Schedule

In accordance with Rule 6(c)(2), we adopt the following preliminary schedule for the filing of opening and reply comments in this rulemaking. We see no need for evidentiary hearings. Any interested party who believes that hearings are required shall request hearings in their opening comments and indicate the nature of any evidence they would present were hearings to be held. Failure to make such a request in opening comments will be deemed a waiver of any request for hearings.

Objections to the preliminary categorization of this rulemaking or to the preliminary schedule shall be filed no later than 10 days after the issuance of this rulemaking and a courtesy copy shall be provided to the assigned ALJ by e-mail.

Date	# of Days from Issuance of OIR	# of Days (from Commission Decision)	Events
12/2/2004	0		Commission issues OIR
1/14/2005	43		Parties file comments
1/28/2005	57		Parties file reply comments
3/22/2005	110		Draft decision mailed for comment
4/21/2005	140		Commission adopts decision
5/5/2005	154	14	TD conducts working group revising/updating GO 153 consistent with Commission orders.
5/19/2005	168	28	TD issues Request for Proposal or Invitation for Bid for the role of certifying agent.
8/23/2005	264	124	TD issues draft resolution adopting revised GO 153 and approving certifying agent contract.
9/22/2005	294	154	Commission adopts TD resolution.
10/28/2005	330	190	Contract approved by the Department of General Services
11/16/2005	349	209	Certifying Agent contract begins
5/1/2006	515	375	Kickoff of the new certification/verification process by all parties including the certifying agent, carriers and consumers.

The above schedule also includes timeline and administrative tasks that must be completed before the implementation of the new certification/verification process. Pursuant to the Lifeline/Link-Up Order,²¹ states that operate their own income-based program are required to implement measures to certify income of consumers and measures to verify consumers' continued eligibility within one year from its publication in the Federal Register. The Lifeline/Link-Up Order was published in the Federal Register on June 22, 2004. Thus, the deadline for the commencement of our new certification/verification process is June 22, 2005. However, if we designate a certifying agent in lieu of having carriers certify and verify customers' eligibility for ULTS, we will not be able to meet the FCC's deadline because the state's contracting process requires until May 1, 2006 to get the certifying process in place. Therefore, if we do determine that it is preferable to use an outside certifying agent, we will direct the Legal Division to petition the FCC to request an extension of time to implement the Lifeline/Link-Up Order.