Of course, in the retention process one will ask, what is the standard
business practice for most utilities when it comes to these record types -
and someone will pull out that dog-eared copy of the 1972 version of Title
18 and say, "well traditionally..."

The regs may be gone, but the expectation will still be there and the
opposing side will claim any changes you made, were to ditch your smoking
guns.

                           Christian Meinke, CRM
                           Edison International
                          Information Management
                                 PAX 27079
                              (626) 302-7079
                         [log in to unmask]




             Steven Whitaker
             <[log in to unmask]
             .NV.US>                                                    To
             Sent by: Records          [log in to unmask]
             Management                                                 cc
             Program
             <[log in to unmask]                                     Subject
             UFL.EDU>                  Re: FW: End of PUHCA  and RIM


             08/05/2005 08:09
             AM


             Please respond to
                  Records
                Management
                  Program
             <[log in to unmask]
                 UFL.EDU>






I am no longer in the energy or utilities business...; however, if this
is true, it is wonderful for utilities.  It takes the FERC 18 CFR
"regulatory" retention requirement out of the 5 retention policy
factors:
Operational
Fiscal
Regulatory
Legal
Historic

Utilities folks should rejoice at having less regulation.

Best regards, Steve
Steven D. Whitaker, CRM
Records Systems Manager; City of Reno

>>> [log in to unmask] 08/04/05 12:40PM >>>
The CSM answered my question...

"neither FERC nor states will be permitted to require certain records
to
be kept, as was the case under PUHCA"

http://www.csmonitor.com/2005/0803/p08s02-comv.html



This statement is pretty amazing...and may be poorly written, but is
it
stating that the bill is actually prohibiting states and FERC from
mandating records retention?



Does this wipe out FERC (18 CFR 125) records retention requirements as
well?



- Chuck



-----Original Message-----
From: Piotrowski, Charles
Sent: Thursday, August 04, 2005 3:33 PM
To: [log in to unmask]
Subject: End of PUHCA and RIM



Hi,



The press has stated that PUHCA is to be repealed with the signing of
the new energy bill.  As y'all may know PUCHA is one of the few laws
that actually contains a record schedule.

Does this mean the end of 17 CFR 257, 17 CFR 257.2 and RIN 3235-AI12
SEC
Final Rule?  Or did the record keeping requirements get absorbed into
the new energy bill?



Thanks,

Chuck



Chuck Piotrowski

CVPS

Records Manager

(802)747-5447



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