X. Record Retention Requirements

Existing G.O. 133-B rules require monthly summary records of service measurements to be retained for two years. We have found that this retention period is inadequate, because usually more than two years elapse between the Commission's review of service quality, and carrier data is sometimes not available. We note that the Commission currently requires utilities to retain cancelled tariff sheets for twenty years⁹⁵, while many accounting related records must be retained indefinitely.⁹⁶

Therefore, we propose to require that the data supporting reported service quality measures be retained for a minimum of six years. The Commission is required to audit carriers every three years pursuant to P.U. Code 314.5 A six year record retention requirement will help ensure that sufficient service quality information is available whenever the Commission conducts carrier audits, and provide data that can be used to compare one audit period to another.

We seek comment on whether the record retention requirement will ensure that service quality data is available for audit and review purposes.