VI. Document Retention
A. The Proposal
The rulemaking proposes the following amendment of § 9.1.9.
"Utilities shall retain their workpapers associated with their WMDVBE annual report and shall provide these workpapers to the Commission upon request."
B. The Parties' Comments
All utilities commenting on the document retention proposal believed it was too vague. The joint utilities and SBC request a definition of the term "workpapers," stating that they do not generate workpapers in preparing their annual reports, but compile data from a variety of sources, such as the utilities' accounting systems.
Most utilities suggest that the Commission should clarify how long the workpapers should be retained. The joint utilities recommend that the utilities should keep relevant documents in accordance with document retention policy or corporate retention schedule that classifies and specifies the length of time required for retention.8 Edison concurs, stating that § 9.1.9 should be modified so that the requirement to retain workpapers be subject to each utility's document retention policy. SBC recommends that the utilities be required to retain their workpapers for three years, and Sprint supports a two-year document retention policy. None of these parties suggests specific word changes to the GO.
Greenlining/LIF recommend that the utilities should be required to retain the workpapers from three to ten years, in keeping with their various document retention policies.
C. Discussion
We clarify the proposed rule for utilities to understand that they should retain all documents or data they rely on in preparing their WMDVBE reports. Clarifying the length of time a utility should retain this information is reasonable, and generally, conforming the time limit to the utilities' various document retention policies is reasonable. However, we agree with Greenlining/LIF that, at a minimum, utilities should retain this information for three years. We, therefore, modify our proposed § 9.1.9 to reflect these changes.
Amended § 9.1.9 reads as follows:
8 The joint utilities state that 18 C.F.R. Part 125 requires energy utilities to retain their annual reports for 5 years, general accounting ledgers for 10 years, insurance records until the expiration of the policies, and procurement documents for 3-6 years depending on the type of document."Utilities shall retain all documents and data they rely on in preparing their WMDVBE annual report for the longer of either three years or in conformance with the utilities' individual document retention policies, and shall provide these documents and data to the Commission upon request."
