This Commission remains committed to completing the work on GO 96-B, which will be a total revision and updating of the procedures for tariff filing and advice letter review. The last major hurdle is the Telecommunications Industry Rules, on which we have received four rounds of comments since issuing the ALJ Draft last February. In a nutshell, those Industry Rules pull together a vast number of procedures developed serially by the Commission (but not reflected in GO 96-A) as competition in the telecommunications industry expanded since the mid-1980s. In many cases, GO 96-B would simply codify those procedures, but in many other cases, the procedures would be modified.
The record shows that some of the proposed modifications are controversial, and that some confusion exists over which existing procedures would, in fact, be modified. At a minimum, we will need to clarify some of the Telecommunications Industry Rules, and may need to make related clarifications to some of the General Rules.11
In a project of this size, and an industry as divergent as telecommunications, we cannot realistically hope to achieve total consensus. Some honest differences in principle are likely to persist. Nevertheless, those differences that exist because of misunderstandings should be resolved. To that end, we expect to make several substantial changes to the ALJ's February 2001 version of GO 96-B, drawing on the four rounds of comments that version elicited. Our changes will be subject to a further comment cycle before final adoption, and the implementation schedule for GO 96-B will be adjusted as appropriate.
11 In considering the need for these clarifications, we have been greatly assisted by comments submitted on June 29, 2001, by various parties in response to an ALJ request for rule-by-rule analysis of the proposed telecommunications procedures. At a time when all parties' resources are stretched, we acknowledge and appreciate their efforts.