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Subject:
From:
Christian Meinke <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Wed, 6 May 2009 08:49:17 -0700
Content-Type:
text/plain
Parts/Attachments:
text/plain (132 lines)
NARUC and FERC (or actually the FPC at the time) were the same circa 1972
before the paperwork reduction act. I'm still not sure which came first, I
suspect it was the federal regulations and NARUC adopted them  (as
guidelines not regulations) and encouraged states to adopt the same
requirements so there would be consistency in state and federal rules.

The original retentions were broad and intended to capture the whole range
of documentation that a utility might possess. Someone went to a great deal
of trouble searching the various federal agencies and consolidating the
findings in these documents. But the paperwork reduction act came into
being and FERC began removing items that were not in it's jurisdiction -
which wasn't to say those items no longer needed to be retained, just that
they were outside FERC's jurisdiction to require them - other agencies
(SEC, IRS, NRC) still had their own requirements to be met, they just had
to be codified elsewhere. Consequently many states continued to use the
"old" NARUC guidelines, or (such as my state,  California) the 1972 version
of FERC for their own audit/retention requirements.

So NARUC alone is probably best considered an "industry practice." but
depending on differing state' s public utility commission, they may have
become adopted as regulations.

                           Christian Meinke, CRM
                        Southern California Edison
                          Information Governance
                          (626) 302-7133/PAX 27133
                           Mobile (818) 414-9515
                         [log in to unmask]


Records Management Program <[log in to unmask]> wrote on 05/06/2009
08:18:38 AM:

> NARUC is actually $21.00 and dated Oct 2007.
>
> I'm not sure how they put the document together as it does not have legal
> citations to substantiate the retention periods.  Some of their long term
> retentions like Time Sheet, office equipment purchases, throughout the
> document are way over the top.  Life of Corporation.
>
> It looks like it follows the FERC requirements 18CFR 125.3/18CFR225.3,
but
> it goes much deeper.
>
>
> Robert W. Dalton, CRM
> Dalton Consulting
> 1-253-229-4555
> [log in to unmask]
>
>
> "This communication is intended for the sole use of the individual and
> entity to whom it is addressed, and may contain information that is
> privileged, confidential and excempt from disclosure under application
law.
> If you have received this communication in error, please notify me
> immediately by calling 1-253-229-4555, or by reply to this communication
>
>
>
> -----Original Message-----
> From: Records Management Program [mailto:[log in to unmask]] On
Behalf
> Of LEVEY, MICHAEL D
> Sent: Wednesday, May 06, 2009 05:55
> To: [log in to unmask]
> Subject: [RM] Subject: Taxonomy/Classification for Digital Archives
>
>  Dustin,
>
> To start, consider the regulatory requirements from the below
> authorities to assist you in the build out of your taxonomy.  All
> requirements are searchable online with the exception of NARUC.  NARUC
> regs are available via their website for $5.00.  You should include the
> requirements of your state utility commission, statutes, codes and any
> additional states in which you operate.  If you would like more
> information, please contact me offline.
>
> FERC PUHCA  2005            18CFR368.3
>
> NARUC 1985                       (National Association of Regulatory
> Utility Commissioners)
>
> FERC (electric)                    18CFR125.3
>
> FERC (gas)             18CFR225.3
>
> EPA                                   40CFR
>
> TX Utility Codes/Statutes
>
> TX Statute of Limitations
>
> TX Statute of Repose
>
>
>
> Best regards,
>
> Michael Levey
>
> SCANA
>
> Supervisor of Corporate Records
>
> Tel:(803)217-8580
>
> Fax:(803)933-8612
>
> [log in to unmask]
>
>
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