Unfortunately, the State of Washington has specifically stated in WAC
480-90-228 that the NARUC retention periods be used.  The Utility Commission
have adopted in code, WAC 480-90-999, that the 1985 version of the NARUC is
the one to be used by gas, electric and water companies in the State of
Washington.  

I really have a difficult time understanding how you can use a 1985 version
of a NARUC document that has been updated by NARUC, with the latest dated
Oct 2007.  

If you go to the NARUC Website (http://www.naruc.org/Store/) and view their
publications the only one offered is dated Oct 2007 and costs $24.00.  Could
have sworn it was $21.00 last week and I think we purchased a couple of
months ago for $20.00.  

Here's two example of differences in the old/new version:

Time Sheets 
  . 1985 Version:  6 years, however, records relating to a plant shall be
retained a minimum of 25 years 
  . 2007 Version:  6 years after plant is retired or sold. 

Note:  Some of the plants in this state are over 100 years old.

I'd personally love to see the justification and legal citation requiring
this retention period.

Environmental area (three new items requiring retention of life of
corporation.  One example:
  .Contracts, permits, and authorizations pertaining to the disposal of
water matter.
    .  1985 Version:  None
    .  2007 Version:  Life of Corporation 

Interesting:  State doesn't require it since they adopted an earlier
version. 

Someone, other than an archivist, give me a valid reason why:
  . You would need to retain time sheets for that long of period or, 
  . Why a state commission would adopt the retention established by a
Private entity and continue to use older versions of the publication. 

NOTE:  I personally like the publication as it does provide guidance on what
records you should see in a public/private utility with guidance on
retention.  However, I do take issue on many of the retention periods in the
NARUC publication and would have preferred that it used or followed more of
the FERC retention requirements in 18 CFR 125.3/18 CFR 225.3.

While NARUC and may be seen as protecting the consumer, I find it extremely
hard to believe they can justify the adoption/establishment of retention
periods that are excessive and on the long term cost consumer money in the
for management of records on their utility rates.  Maintenance costs have to
be passed on to someone.  


Robert W. Dalton, CRM
Dalton Consulting
1-253-229-4555
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-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf
Of Johnsen, Maggi A.
Sent: Wednesday, May 06, 2009 09:07
To: [log in to unmask]
Subject: Re: [RM] Subject: Taxonomy/Classification for Digital Archives
(FERC Retention Schedules)

Once upon a time FERC issued retention requirements as 18 CFR 125.3 and
NARUC (National Association of Regulated Utility Commissioners) adopted
those requirements under their own banner. As NARUC is not a
governmental agency, but rather a "trade association" for public service
commission members, the NARUC retention schedule does not carry the
weight of law or regulation. In fact, many states explicitly state they
do not follow NARUC.

FERC has taken several actions in the past several years:
1.  deleted many of the items that were covered by 17 CFR 257.3(which
applied to utility holding companies) and renumbered the remaining
entries;
2.  reduced the retention periods of several items such as general
ledgers (going from 50 years to 10 years); and
3.  converted 17 CERF 257.3 to 18 CFR 368.3 with the repeal of the
Public Utility Holding Company Act.

NARUC in many cases has not adopted the changes that FERC has made.
NARUC sees their charge as protecting the ratepayers of their particular
state, so any FERC items that have financial implications for
determining rates generally will not be reduced in terms of retention
period.

Hope this helps.

Maggi
_________________ 
Maggi Johnsen, CRM | Georgia Power Company | Supervisor, Business
Information Services
241 Ralph McGill Boulevard NE,  BIN 10050| Atlanta, GA 30308-3374 |
PHONE: 404-506-1680 | FAX: 404.506.6652 | E: [log in to unmask]

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