We
believe
that
the
records
developed
and
maintained
in
the
ordinary
course
of
business
will
provide
the
primary
means
of
assuring
compliance
with
today's
rule.
We
know
that,
as
a
general
rule,
companies
necessarily
generate
and
keep
records
related
to
the
types
of
projects
covered
by
today's
rule.
For
example,
companies
generally
have
comprehensive
procedures
by
which
funds
are
allocated
to
both
capital
and
maintenance
expense
projects.
Many
of
the
records
generated
by
these
procedures
are
needed
for
tax
accounting
purposes
and,
by
law,
must
be
maintained
for
at
least
6
years.
Moreover,
additional
records
must
be
maintained
in
industries
regulated
for
other
purposes,
such
as
the
energy
sector
(
over
90
percent
of
which,
by
capacity,
is
subject
to
FERC
regulations).
Electric
utilitiesPublic
|
utilities,
licensees
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
systems
of
accounts
that
isare
set
out
in
18
CFR
Part
|
101
for
electric
utilitiespublic
utilities
and
licensees,
and
18
|
CFR
Part
22501
for
natural
gas
companies.
These
uniform
systems
|
of
accounts
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
Part
125
(
for
electric
|
utilitiespublic
utilities
and
licensees)
and
18
CFR
Part
225
(
for
|
natural
gas
companies).
Just
a
few
of
theThe
types
of
records
|
that
companies
must
keep
include,
for
public
utilities
and
|
licensees,
for
example,
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
or
sold),
general
and
subsidiary
accounting
ledgers
(
10
|
years),
paid
and
canceled
vouchers,
and
original
bills
and
invoices
for
materials,
services,
etc.
(
5
years).

Altogether,
these
are
various
sources
of
information
provide
more
thatn
a
reasonable
assurance
of
compliance
with
today's
rule.
|
This
is
particularly
true
given
EPA's
broad
authority
to
inspect
affected
facilities
and
require
submission
of
compliance
related
data.
