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Subject:
From:
"LEVEY, MICHAEL D" <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Wed, 24 Apr 2013 19:01:36 +0000
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In 2007 NARUC revised down their retention periods for many utility records. For example, some accounting records were required to be retained 50 years and now just 25 years.  Additionally, a state in which your utility operates may require you to adhere to the NARUC guidelines. For example, one of our subsidiaries is located in NC and as a result is required to adhere to NARUC.  So it is imperative to identify all the jurisdictions and regulations that your utility may fall under. FERC also has recordkeeping requirements and schedules beyond 18CFR125 and 18CFR225 for Holding Companies and also for the FERC Standards of Conduct. A consideration may be to review retention periods for purchasing orders and contracts in tandem.  Plant specific requirements may require you to keep contracts and purchase orders for plants much longer than for the service company or administrative areas.  Another consideration may be your need to need to support corporate tax returns, so it is important to include the IRS period of limitations in your decision making process. 
 
Mike Levey
SCANA


--------------------------------------------------------------------------------------------
From: Records Management Program [mailto:[log in to unmask]] On Behalf Of bobd
Sent: Wednesday, April 24, 2013 1:17 PM
To: [log in to unmask]
Subject: Re: Electric Utilities: Retention of Contracts/Agreements

If one is using the NARUC as legal source for retention of records they
should be aware that the NARUC is an private association retention schedule.
The retention periods for the record series are based on the longest
retention as contributed by the state governments and may be far longer than
required by your state legal requirements.

However, I would highly recommend purchasing the document from the
association as a guideline of what records a public/private utility may
have, but it is not all inclusive.    If at all possible I would rely and
follow the FERC  (125.3/225.3).


Robert W Dalton, CRM
Dalton Consulting
253-229-4555
[log in to unmask]


............................

In addition to FERC (NRC and other Federal and State regulatory authorities)
we rely upon guidance of NARUC, the National Association of Regulatory
Utility Commissioners.  NARUC indicates that certain contracts be retained
as contract expiration/termination/cancellation + 6 years.   Other contracts
may need to be retained for Life of Plant (Plant Retirement date + 6 years
or Sale of Plant + 6 years. You may also need/want to factor in
depreciation, decommissioning, etc. Additional factors for consideration may
be the need to support any environmental claims.
I hope this info helps!

Michael D. Levey
SCANA
W:803-217-8580
F:803-933-8612

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