Elizabeth_
A._
Stolpe@
ceq.
eop.
gov
08/
18/
2003
01:
56
PM
To:
Bill
Wehrum/
DC/
USEPA/
US@
EPA
cc:
Subject:
FERC
recordkeeping
requirements
­­­­­­­­­
Forwarded
by
Elizabeth
A.
Stolpe/
CEQ/
EOP
on
08/
18/
2003
01:
56
PM
­­­­­­­­­­­­­­­­­­­­

(
Embedded
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"
Hill,
David
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(
GC)"
<
David.
R.
Hill@
hq.
doe.
gov>
to
file:
08/
14/
2003
05:
32:
29
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Record
Type:
Record
To:
See
the
distribution
list
at
the
bottom
of
this
message
cc:
Subject:
FERC
recordkeeping
requirements
Yesterday
Jim
requested
a
summary
of
FERC's
recordkeeping
requirements.
Electric
utilities
and
natural
gas
companies
that
are
subject
to
FERC
jurisdiction
must,
unless
they
receive
a
waiver
from
the
Commission,
comply
with
extensive
accounting
and
record
retention
requirements.
They
must
keep
financial
information
according
to
a
uniform
system
of
accounts
that
is
set
out
in
18
CFR
Part
101
for
electric
utilities
and
Part
225
for
natural
gas
companies.
The
systems
include
hundreds
of
specific
accounts,
including
individual
accounts
for
boiler
plant
equipment,
engines
and
engine­
driven
generators,
turbogenerator
units,
and
hundreds
of
other
asset,
liability,
cost
and
property
items.

These
companies
also
must
retain
records
according
to
the
schedules
set
forth
in
18
CFR
125
(
for
electric
utilities)
and
225
(
for
natural
gas
companies).
Just
a
few
of
the
types
of
records
that
companies
must
keep
are
generation
and
output
logs
(
records
must
be
kept
for
3
years),
generating
load
records
(
3
years),
gauge­
reading
reports
(
2
years),
maintenance
work
orders
and
job
orders
showing
entries
for
labor,
materials
and
other
charges
in
connection
with
maintenance
and
other
work
pertaining
to
utility
operations
(
5
years),
work
order
sheets
for
construction
work
in
progress
(
5
years),
appraisals
and
valuations
made
of
utility
property
or
investments
(
3
years),
engineering
records,
drawings,
and
other
supporting
data
for
proposed
or
as­
constructed
utility
facilities,
including
detail
drawings
and
records
of
engineering
studies
(
must
be
kept
until
facilities
are
retired),
contracts
or
other
agreements
relating
to
services
performed
in
connection
with
construction
of
utility
plant
(
6
years
after
the
plant
is
retired),
general
and
subsidiary
accounting
ledgers
(
10
years),
paid
and
canceled
vouchers,
and
original
bills
and
invoices
for
materials,
services,
etc.
(
5
years).

­­­­­
Original
Message­­­­­
From:
Elizabeth_
A._
Stolpe@
ceq.
eop.
gov
[
mailto:
Elizabeth_
A._
Stolpe@
ceq.
eop.
gov]
Sent:
Thursday,
August
14,
2003
2:
29
PM
To:
James_
Connaughton@
ceq.
eop.
gov;
Otis,
Lee;
Hill,
David
R.
(
GC);
Indur_
Goklany@
ios.
doi.
gov;
Steve_
Griles@
ios.
doi.
gov;
Clay_
Sell@
opd.
eop.
gov;
Kevin_
M._
O'Donovan@
oa.
eop.
gov;
Amy_
L._
Farrell@
omb.
eop.
gov;
Arthur_
G._
Fraas@
omb.
eop.
gov;
John_
Graham@
omb.
eop.
gov;
Paul_
R._
Noe@
omb.
eop.
gov;
Ted_
Gayer@
cea.
eop.
gov
Subject:
Comments
on
recordkeeping
From
Bill
H.
re
recordkeeping/
reporting
comments,
FYI
You
requested
a
review
of
what
commenters
had
said
about
recordkeeping
and
reporting
requirements
in
the
RMRR
proposal.
In
the
RMRR
proposal,
we
only
included
specific
reporting
requirements
for
the
allowance
approach.
We
did
not
include
recordkeeping
for
either
the
allowance
or
the
replacement
approach,
although
because
we
took
comment
on
using
a
multi­
year
rolling
average
for
the
allowance
approach
most
commenters
were
assuming
they
had
to
maintain
records.
In
general,
based
on
their
comments,
most
commenters
assumed
they
would
have
records
at
their
facilities.

State
and
local
air
pollution
agencies
had
significant
comments
about
the
administrative
burden
for
them
of
implementing
the
allowance
approach.
They
were
mostly
concerned
that
they
would
need
to
add
accountants
to
their
staff
to
review
the
documentation
at
plants.
The
environmental
commenters
generally
raised
strong
concerns
about
the
legal
basis
for
either
approach
and
did
not
get
into
the
specific
components
of
the
rule
such
as
recordkeeping
and
reporting.

Most
of
the
industry
commenters
made
no
comments
about
keeping
records
or
reporting
requirements.
There
were
no
other
direct
negative
comments
on
keeping
of
records
that
I
could
find
in
my
quick
search.
There
were
a
number
of
concerns
about
reducing
the
reporting
burden.
In
particular,
commenters
focused
on
the
need
for
reporting
only
when
a
threshold
was
exceeded
under
either
approach,
but
not
otherwise.
Of
the
major
trade
association
comments,
most
seemed
to
believe
they
would
have
records
available
related
to
either
option.
A
few
industry
commenters
such
as
TVA
and
NEDA/
CARP
(
association
of
a
broad
range
of
industries
including
automobile
manufacturing,
pharmaceuticals,
power
generation,
petroleum
refining,
and
chemical
manufacturing)
made
specific
comments.
TVA's
comments
assumed
that
the
way
to
enforce
the
RMRR
regulations
would
be
through
EPA
and
state
audit
and
inspection
programs.
Their
comments
imply
that
companies
have
strong
incentives
to
keep
good
"
books"
with
the
necessary
project
budget
information
and
that
this
would
need
to
be
public
and
easily
verified.
NEDA/
CARP
recommended
simple
recordkeeping
requirements.
They
recommended
logs
of
equipment
replaced
on
a
project
basis
that
would
be
readily
available
to
inspectors.
They
also
stated
that
if
a
project
were
to
exceed
50%
of
the
replacement
cost
of
a
process
unit
(
their
recommended
level
for
the
cutoff)
then
a
report
would
need
to
be
sent
to
the
reviewing
authority.

If
you
need
further
detail,
please
let
me
know.

Bill
Message
Sent
To:_____________________________________________________________

Elizabeth
A.
Stolpe/
CEQ/
EOP@
EOP
James
Connaughton/
CEQ/
EOP@
EOP
"
Otis,
Lee"
<
Lee.
Otis@
hq.
doe.
gov>
Indur_
Goklany@
ios.
doi.
gov
Steve_
Griles@
ios.
doi.
gov
Clay
Sell/
OPD/
EOP@
EOP
Kevin
M.
O'Donovan/
OVP/
EOP@
EOP
Amy
L.
Farrell/
OMB/
EOP@
EOP
Arthur
G.
Fraas/
OMB/
EOP@
EOP
John
Graham/
OMB/
EOP@
EOP
Paul
R.
Noe/
OMB/
EOP@
EOP
Ted
Gayer/
CEA/
EOP@
EOP
