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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The press has stated that PUHCA is to be repealed with the signing of the new energy bill.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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