Are carriers required to have their communications plan and routing contact phone number in place during the phase-in period after 1/1/05 but before they file the MCS-150B?

No. Carriers are not required to comply with the permitting requirements before they apply for their Hazardous Materials Safety Permit during the phase-in period. FMCSA recommends companies set up these systems ahead of applying for their HM Safety Permit to make sure they work and will be in compliance once the permit is issued.