Lorinda ... sound like a good idea, BUT the 2007 is drastic in changes to
the NARUC document.
I had to call the NARUC to get a copy of the document as it wasn't on their
website. Told it was out of print, but they would make me a copy and mail
it to me for $20.00.
In Washington State only three private investor owned utilities are required
to use the NARUC (UTC Document on WEB - Electric Companies - Reporting to
the WTUC).
Apparently the Public Sector (Cities, Utilities Districts, etc)only have to
use the FERC retention, plus of course other applicable federal and state
laws and regulations.
They (WA Utilities and Transportation Commission)looked at the newest
version of the NARUC document and found the changes so radical from the 1985
version they didn't adopt it. The new document doesn't reflect it is
revised or refer to any earlier versions, which I also find strange. They
didn't update, just created a new document.
Frankly, I don't know why the state doesn't remove the reference to the
NARUC all together and have all the utilities follow the FERC as it is based
on law, while the NARUC is based on ???. Much of verbiage in the NARUC is
word for word from the FERC with only the retention periods different.
It is my guess the NARUC is a composite of state requirements with the
longest retention reflected.
Now I can understand some of the long retention periods if they are based on
federal or state law or regulation. I know that some of the laws in our
state for public records (city, town, etc.,) are longer than required for
those in the private sector (time cards for one).
Per telecom with a representative from the state Utilities Commission, if I
want to make a change I would have to make a complaint through the State
Consumer Protection Agency as a rate payer. Apparently it isn't the
Utilities and Transportation Commission job to review and make
recommendations on questions pertaining to the NARUC to the commission.
I think I know a great state senator who might be willing to question why
(1) a private association retention schedule was adopted by the state, (2)
why the public sector (city, town, etc. utilities)only follow the FERC while
the private sector follows FERC and NARUC; why the rate payers of the
private sector most pay for the storage and maintenance of records such as
time card, invoices, purchase orders and other documents for the LIFE of the
PLANT. We are talking 50, 100, to infinity years.
I'm working on a comparison document between FERC - 2008; NARUC 1985 - 2007
which I will post here.
Have a great weekend everyone.
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 Lorinda Kasten-Lowerre
Sent: Friday, May 08, 2009 09:14
To: [log in to unmask]
Subject: Re: [RM] Taxonomy/Classification for Digital Archives (FERC
Retention Schedules)
Hi, Robert,
You asked, "Wouldn't it be better to just say follow the NARUC (including
updates)?"
I think legislators and regulators believe their legislation and
regulations cover all contingencies until the end of time (or in the case
of legislators, until The Administration changes.) Examples are "blue
laws", TVA, special telephone devices for the deaf, removing
no-longer-endangered species from the Endangered Species List..."
Happy Friday!
Lorinda Kasten-Lowerre
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