ii

Federal Energy 

Regulatory Commission
iii

The Strategic Plan 

FY 2018–2022

Contents

Message from the Chairman ...................................................................................................v

About the Federal Energy Regulatory Commission...........................................................vi

Mission......................................................................................................................................viii

Strategic Plan Structure............................................................................................................x

Goal 1: Ensure Just and Reasonable Rates, Terms, and Conditions ................................1

Objective 1.1: Establish Commission rules and policies that will result in just, reasonable, and not 

unduly discriminatory or preferential rates, terms, and conditions of jurisdictional service..........................1

Objective 1.2: Increase compliance with FERC rules; detect and deter market manipulation.....................5

Goal 2: Promote Safe, Reliable, and Secure Infrastructure..............................................9

Objective 2.1: Facilitate benefits to the nation through the review of natural gas and hydropower 

infrastructure proposals. ...............................................................................................................................................9

Objective 2.2: Minimize risks to the public associated with FERC-jurisdictional energy 

infrastructure................................................................................................................................................................ 12

Goal 3: Mission Support through Organizational Excellence..........................................21

Objective 3.1: Manage resources effectively through an engaged workforce.................................................. 21

Objective 3.2: Facilitate public trust and understanding of Commission activities by promoting 

transparency, open communication, and a high standard of ethics. ................................................................. 26

Appendix A: Organization Chart..........................................................................................29

Appendix B: Acronyms ..........................................................................................................30
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Federal Energy 

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v

The Strategic Plan 

FY 2018–2022

Message from the Chairman

The Federal Energy Regulatory Commission (FERC or the 

Commission) has very important work to do in the years covered 

by this Strategic Plan, fiscal years (FY) 2018 through 2022. 

The nation is experiencing significant changes in energy supply 

due to a number of factors, such as the increased availability of 

domestic natural gas and the emergence and growth of new energy 

technologies. Both the nation’s energy infrastructure and energy 

markets must adapt to these changes to ensure that consumers have 

access to economically efficient, safe, reliable, and secure energy at a 

reasonable cost. 

The FYs 2018 – 2022 Strategic Plan builds on the success of our 

previous Strategic Plan, which encompassed all major functions 

and operations of the Commission, including management and 

stewardship responsibilities.  In looking forward over the next 4-5 

years, we conducted a situational assessment relative to each of our 

six strategic objectives.  The results, including key challenges and 

opportunities facing the agency and our responsive actions, are 

highlighted in the plan.  

We recognize our responsibility to fully address these challenges and seize these opportunities.  The 

Commission is fortunate to have a highly dedicated and professional team of employees across all areas of 

our operations. We are committed to executing our Strategic Plan to achieve results and to address important 

energy challenges that face our nation. 

Kevin J. McIntyre

Chairman

Federal Energy Regulatory Commission
vi

Federal Energy 

Regulatory Commission

About the Federal Energy Regulatory 

Commission

Overview

The Federal Energy Regulatory Commission (FERC or the Commission) is an independent agency that 

regulates the transmission and wholesale sale of electricity and natural gas in interstate commerce, and 

regulates the transportation of oil by pipelines in interstate commerce. FERC also reviews proposals to build 

interstate natural gas pipelines, natural gas storage projects, and liquefied natural gas (LNG) terminals, and 

FERC licenses non-federal hydropower projects. Congress assigned these responsibilities to FERC in various 

laws enacted over nearly 100 years, such as the Federal Power Act, Public Utility Regulatory Policies Act, 

Natural Gas Act, and Interstate Commerce Act. More recently, as part of the Energy Policy Act of 2005, 

Congress gave FERC additional responsibilities to protect the reliability and cybersecurity of the bulk-power 

system through the establishment and enforcement of mandatory reliability standards, as well as additional 

authority to enforce FERC regulatory requirements through the imposition of civil penalties and other 

means.

FERC is composed of up to five commissioners who are appointed by the President of the United States 

with the advice and consent of the Senate. Commissioners serve staggered five-year terms and have an 

equal vote on the orders through which FERC acts. The President appoints one of the commissioners to 

be the chairman of FERC, the administrative head of the agency. FERC is a bipartisan body; no more than 

three commissioners may be of the same political party. To carry out its authorities, the Commission has 

approximately 1,500 staff that are organized into 12 offices.1 Commission staff are located primarily in the 

Washington D.C. region, with several field offices across the country.

1

 See the organization chart in Appendix A
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The Strategic Plan 

FY 2018–2022

FERC’s Responsibilities

The Commission has many responsibilities under various statutes. There are, however, many energy-related 

areas that are outside FERC’s jurisdictional responsibilities and fall to other federal agencies or state public 

utility commissions. Examples include:

What FERC does

• Regulates the transmission and wholesale sales 

of electricity in interstate commerce

• Reviews certain mergers and acquisitions and 

corporate transactions by electricity companies

• Regulates the transportation and sale of natural 

gas for resale in interstate commerce

• Regulates the transportation of oil by pipeline 

in interstate commerce

• Approves the siting and abandonment of 

interstate natural gas pipelines and storage 

facilities

• Reviews siting applications for electric 

transmission projects under limited 

circumstances

• Ensures the safe operation and reliability of 

proposed and operating LNG terminals

• Licenses and inspects private, municipal and 

state hydroelectric projects

• Protects the reliability and security of the highvoltage interstate transmission system through 

mandatory reliability standards

• Monitors and investigates energy markets 

• Enforces FERC regulatory requirements 

through imposition of civil penalties and other 

means

• Oversees environmental matters related to 

natural gas and hydroelectricity projects and 

other matters

• Administers accounting and financial 

reporting regulations and conduct of regulated 

companies

What FERC does not do

• Regulation of retail electricity and natural gas 

sales to consumers

• Approval for the physical construction of 

electric generation facilities

• Regulation of many activities of state and 

municipal power systems, federal power 

marketing agencies, and most rural electric 

cooperatives

• Regulation of nuclear power plants

• Issuance of state water quality certificates

• Oversight for the construction of oil pipelines

• Abandonment of service as related to oil 

facilities

• Mergers and acquisitions as related to natural 

gas and oil companies

• Responsibility for pipeline safety or for 

pipeline transportation on or across the Outer 

Continental Shelf

• Regulation of local distribution of electricity 

and natural gas

• Development and operation of natural gas 

vehicles

• Reliability problems related to local 

distribution facilities

• Tree trimming near local distribution power 

lines in residential neighborhoods
viii

Federal Energy 

Regulatory Commission

Mission

Economically Efficient, Safe, Reliable, 

and Secure Energy for Consumers 

Assist consumers in obtaining economically efficient, safe, reliable, 

and secure energy services at a reasonable cost through appropriate 

regulatory and market means, and collaborative efforts.

Goal 1: Ensure Just and Reasonable Rates, Terms, and Conditions

Objective 1.1: Establish Commission rules and policies that will result in just, reasonable, and not unduly 

discriminatory or preferential rates, terms, and conditions of jurisdictional service.

Core Function 1.1.1: Evaluate existing Commission rules and policies in light of emerging issues and 

changing circumstances to determine whether modification of such rules and policies is necessary or 

new rules or policies need to be developed.

Core Function 1.1.2: Analyze and act upon filings in a fair, clear, and timely manner. Where filings do 

not provide the Commission with sufficient information to act upon their merits, facilitate settlements 

of disputes or, in the absence of settlement, develop an adequate record for Commission action.

Objective 1.2: Increase compliance with FERC rules; detect and deter market manipulation.

Core Function 1.2.1: Increase compliance by identifying anomalies and potential rule improvements, 

and through stakeholder education and outreach.

Core Function 1.2.2: Detect and deter market manipulation by identifying and conducting 

investigations of potential violations.
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The Strategic Plan 

FY 2018–2022

Goal 2: Promote Safe, Reliable, and Secure Infrastructure

Objective 2.1: Facilitate benefits to the nation through the review of natural gas and hydropower 

infrastructure proposals.

Core Function 2.1.1: Conduct thorough and timely technical review of applications to construct, 

operate, or modify natural gas and hydropower infrastructure.

Core Function 2.1.2: Ensure natural gas and hydropower infrastructure is constructed and operated in 

compliance with environmental mitigation conditions in FERC orders.

Objective 2.2: Minimize risks to the public associated with FERC-jurisdictional energy infrastructure.

Core Function 2.2.1: Conduct comprehensive and timely inspections of hydropower and LNG facilities 

to ensure compliance with the Federal Power Act, the Natural Gas Act, and Commission orders.

Core Function 2.2.2: Protect and improve the reliable and secure operation of the bulk-power system by 

identifying reliability and security risks; overseeing the development, implementation and enforcement 

of mandatory reliability standards; and promoting the resilience, reliability and security of the bulkpower system.

Core Function 2.2.3: Protect against cyber and physical security threats to FERC-jurisdictional energy 

infrastructure and improve their resilience by working with regulated entities and stakeholders and by 

coordinating with other government agencies to identify and apply best practices separate from basic 

regulatory requirements.

Goal 3: Mission Support through Organizational Excellence

Objective 3.1: Manage resources effectively through an engaged workforce.

Core Function 3.1.1: Maintain processes and provide compliant services that enable FERC to manage 

resources effectively and efficiently.

Core Function 3.1.2: Provide tools and services that enable FERC staff to effectively perform their jobs 

and drive Commission success.

Objective 3.2: Facilitate public trust and understanding of Commission activities by promoting 

transparency, open communication, and a high standard of ethics. 

Core Function 3.2.1: Develop and maintain internal processes and services that promote high standards 

of ethics.

Core Function 3.2.2: Maintain processes and public information services in accordance with the 

principles of transparency and open communication.
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Federal Energy 

Regulatory Commission

Strategic Plan Structure

Every four years, FERC updates its Strategic Plan as required by the GPRA Modernization Act of 2010. 

The Commission believes in the benefit of establishing goals, communicating priorities, and holding 

itself accountable. As a regulatory agency, the foundation of the Commission’s Strategic Plan is rooted 

in its federal mandates under various laws and statutes. The plan also demonstrates the Commission’s 

responsiveness to changes in stakeholder needs and the energy landscape. The plan is designed to help 

employees align their individual work to the mission and goals of the agency. The plan also gives external 

stakeholders an understanding of the Commission’s authorities, priorities, and processes.

This figure below depicts the overall structure of the FERC strategic plan. The plan is ultimately focused on 

fulfilling FERC’s mission of Economically Efficient, Safe, Reliable, and Secure Energy for Consumers at a 

Reasonable Cost. The goals represent broad outcomes that FERC is trying to achieve. The first two goals are 

mission critical and correspond to key aspects of FERC’s legislative authority. The third goal is a stewardship 

goal focused on establishing a foundation of organizational excellence that enables the achievement of 

FERC’s mission. 

The objectives in this plan describe more specific, action-oriented steps that FERC will employ to meet the 

goal. For each objective, the strategic plan identifies a set of core functions. A core function is an integrated 

and focused combination of activities and capabilities that carry out a critical operation or program necessary 

to achieve the objective and fulfill its mandate. Core functions describe what, as a regulatory agency, the 

Commission has an obligation to do. Within the strategic plan, core functions represent an investment in 

and a commitment to maintaining FERC’s ability to fulfill its responsibilities as a regulatory agency and 

demonstrate its dependability and dedication to excellence.
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The Strategic Plan 

FY 2018–2022

Since the last strategic plan was published in 2014, the energy landscape has changed considerably and is 

likely to continue to do so. FERC conducted a situational assessment of each of the six strategic objectives 

included in the plan. Each situational assessment identifies factors that are likely to have a significant 

impact on the achievement of the objective over the next four years. The identified factors could be either 

an issue that poses a barrier to the achievement of the objective or an opportunity that offers a benefit/

advantage relative to achieving of the objective. For each situational assessment item, FERC developed 

a strategic response that will be implemented to address the identified issue or opportunity. The strategic 

responses range from a refocusing of effort or attention to a more structured set of actions directed toward 

a particular result. The range of strategic responses enables more flexible action and broader organizational 

engagement in strategic action. The situational assessments and strategic responses represent an investment in 

and commitment to maintaining awareness and responsiveness in regard to evolving stakeholder needs and 

changing external conditions.

The strategic plan also identifies performance measures that provide a general indication of progress toward an 

objective. Alongside the measures, Commission staff use supplemental information and other indicators to 

fully analyze and understand the Commission’s performance within each objective. 

In preparing this plan for publication, FERC was assisted by contractors, who provided technical input into 

the design and assembly of this document.
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Federal Energy 

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The Strategic Plan 

FY 2018–2022

Goal 1: Ensure Just and Reasonable 

Rates, Terms, and Conditions

Ensure that rates, terms, and conditions of jurisdictional services are just, 

reasonable, and not unduly discriminatory or preferential. 

The nation’s security and economic prosperity depend on maintaining economically efficient, safe, reliable, 

and secure energy services at a reasonable cost for consumers. FERC’s regulation ensures just and reasonable 

rates, terms, and conditions for jurisdictional services. 

In carrying out its regulatory role, FERC uses a range of ratemaking activities as well as market oversight and 

enforcement. FERC’s jurisdiction includes the wholesale sales and transmission of electricity and natural 

gas in interstate commerce, as well as the transportation of oil by pipeline in interstate commerce. FERC’s 

ratemaking activities leverage both regulatory and market means, and involve the issuance of orders and 

the establishment of rules and policies. Its enforcement activities include both increasing compliance and 

detecting and deterring market manipulation. 

Through these efforts, FERC ensures that consumers have reasonable access to the services they need and that 

service providers are appropriately compensated.

Objective 1.1: Establish Commission rules and policies that will 

result in just, reasonable, and not unduly discriminatory or 

preferential rates, terms, and conditions of jurisdictional service.

Electricity, natural gas, and oil are vital resources that fuel economic activity and help to meet the nation’s 

energy needs. Through the Federal Power Act, Public Utility Regulatory Policies Act, Natural Gas Act, and 

Interstate Commerce Act, among other laws, Congress gave FERC authority to regulate the transmission 

and wholesale sale of electricity and natural gas in interstate commerce, and to regulate the transportation 

of oil by pipeline in interstate commerce. The Commission’s responsibility in the exercise of this authority is 

to ensure that rates, terms, and conditions for wholesale sales and transmission of electric energy and natural 

gas in interstate commerce, as well as for transportation of oil by pipeline in interstate commerce, are just and 

reasonable and not unduly discriminatory or preferential. 

FERC carries out this responsibility by issuing orders and establishing rules and policies that continually 

balance two important interests: protecting energy consumers against excessive rates, and providing an 

opportunity for regulated entities to recover their costs and earn a reasonable return on their investments. 

FERC’s orders, rules, and policies use both market and regulatory means to impact energy service provider 

practices. FERC leverages competitive market forces to promote efficiency for consumers where appropriate. 

When competitive market conditions do not exist or competitive forces are inadequate to protect consumers, 

FERC relies on traditional rate-setting authority and tools such as cost-of-service ratemaking. 

In exercising its authority, FERC ensures that interested stakeholders have the opportunity to provide 

their views and that the Commission’s ultimate decisions are adequately supported by the public record. 

Stakeholder engagement and transparency help FERC establish rules and policy that result in just, 

reasonable, and not unduly discriminatory or preferential rates, terms, and conditions.

1
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Federal Energy 

Regulatory Commission

Objective 1.1: Situational Assessment and Strategic Responses

Situational Assessment Item – Changes in Energy Supply and Demand

Changes in both energy supply and demand are having an impact on the fuel mix of resources 

participating in wholesale energy markets, the dynamics of competitive markets, incentives for 

investment in infrastructure, and the security and resilience of the bulk-power system. These changes 

create new challenges and increase the complexity of maintaining just, reasonable, and not unduly 

discriminatory or preferential rates, terms, and conditions of jurisdictional service. 

Strategic Response

The Commission will use its diverse resources to address this issue from multiple perspectives:

• Identify key services and products that contribute to meeting short-term and long-term consumer 

needs, including but not limited to reliability and the need for a secure and resilient bulk-power 

system, and ensure appropriate compensation for those services and products through just and 

reasonable rates. 

• Perform analysis to consider compensation for necessary services and products that enhance bulkpower system reliability, security, and resilience and/or benefits consumers.

• Focus on removing barriers to technology that enhances bulk-power system reliability, security, and 

resilience and/or benefits consumers by promoting market competitiveness.

• Explore whether evolving competitive opportunities warrant revision to the Commission’s regulations 

implementing the Public Utility Regulatory Policies Act (PURPA) of 1978.

• Evaluate and revise, as appropriate, the current policies for the establishment of base return on equity 

in light of changes in market dynamics and court precedent.

In addition to addressing the situational assessment item through the stated actions above, the Commission 

will continue to carry out its core functions as a regulatory agency, which are described below.

Core Functions for Objective 1.1

Core Function 1.1.1: Evaluate existing Commission rules and policies in light of emerging issues 

and changing circumstances to determine whether modification of such rules and policies is 

necessary or new rules or policies need to be developed.

To adapt to emerging issues and changing circumstances in the electric and natural gas industries, FERC 

evaluates existing rules and policies to assess whether they continue to ensure just, reasonable, and not unduly 

discriminatory or preferential rates, terms, and conditions of service. This evaluation allows FERC to develop 

or modify its existing rules and policies to improve economic efficiency and operations in the markets. The 

evaluation also enables FERC to ensure adequate compensation for resources responding to system needs, to 

remove barriers to ensure access to the market and grid by all resources, and to ensure that consumers have 

reasonable access to the services they need. 

FERC accomplishes its ongoing review of existing rules and policies in a number of ways. Based on its 

knowledge and experience with the industries it regulates, FERC may gather information through technical 

conferences or other means of outreach with stakeholders. FERC also keeps informed of national and 

international events and trends and draws on its knowledge and experience with its jurisdictional industries 
3

The Strategic Plan 

FY 2018–2022

to detect important recurring or emerging issues. FERC gathers data and uses it to perform economic, 

engineering, and technical analyses of the energy markets to inform policy recommendations. FERC 

evaluates the outcomes of recent policy changes on market participant behavior and market operations. 

FERC also undertakes research projects on energy market design issues. FERC’s technical, legal, and policy 

experts also carefully review and analyze filings to support the Commission’s review of industry proposals.

Where necessary, the Commission will pursue changes to its regulations through rulemaking proceedings. 

In some instances, the Commission on its own initiative will institute a rulemaking to address new concerns 

or trends in the industry. In other instances, the regulated community or other stakeholders will petition 

the Commission for changes to its regulations. FERC engages in a transparent rulemaking process to pursue 

changes to its regulations. A process of notice and comment maintains transparency and ensures stakeholder 

input. Through staff reports and white papers, technical conferences and workshops, and presentations and 

speeches, FERC also provides guidance to the regulated community and other stakeholders.

By remaining aware and agile, FERC can adjust existing policies and develop new policies to ensure that 

consumers have reasonable access to needed services and that service providers are appropriately compensated 

in a rapidly changing marketplace. 

Core Function 1.1.2: Analyze and act upon filings in a fair, clear, and timely manner. Where 

filings do not provide the Commission with sufficient information to act upon their merits, 

facilitate settlements of disputes or, in the absence of settlement, develop an adequate 

record for Commission action.

To maintain or establish just, reasonable, and not unduly discriminatory or preferential rates, terms, and 

conditions of service, FERC analyzes and takes appropriate action on applications to change existing or 

implement new rates, terms, and conditions of service. 

Jurisdictional entities have tariffs on file with the Commission that state what rates they can charge for 

jurisdictional services, as well as establish the rates, terms and conditions of service. Jurisdictional entities may 

submit to FERC requests to make changes to existing tariffs or implement new ones, and most orders that 

the Commission issues are in response to such requests. FERC may also conduct an independent review of 

tariff provisions and rates—i.e., a review not initiated by a jurisdictional entity’s filing—either pursuant to a 

stakeholder complaint or on its own motion. 

Other stakeholders (such as ratepayers and state and local government agencies) may participate in 

proceedings. The Commission has adopted procedures that allow broad participation in its proceedings by 

the regulated entity and other parties impacted by its decisions.

FERC advisory staff develop recommendations to the Commission regarding potential actions through a 

multifaceted process that varies in complexity with the nature of the request. Analysis of the initial filing 

requires broad legal and technical expertise—from attorneys, economists, accountants, engineers, and rate 

and policy analysts—and includes a careful examination of the record, Commission policy and precedent 

relevant to each filing. Based on this analysis, the Commission issues a fair, clear, and timely order accepting, 

modifying, suspending, setting for hearing, or rejecting the rates, terms, and conditions of service.

Some issues are not easily resolved, especially those where there are material issues of fact in dispute. In 

such cases, the Commission may set the matter for hearing and/or direct the parties involved to engage 

in settlement judge procedures. If in the settlement judge procedures the negotiations reach an impasse, 

the Commission’s chief administrative law judge terminates those procedures and appoints a presiding 

administrative law judge to conduct a hearing and issue an initial decision. In the hearing, the parties and 

Commission trial staff conduct discovery to develop the record. The parties and trial staff file testimony 

prepared by expert witnesses on the disputed issues, conduct cross-examination of witnesses at the hearing, 

and file briefs with the presiding judge. An administrative law judge presides over the hearing, and ensures 
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Federal Energy 

Regulatory Commission

due process by ruling on discovery disputes, motions to compel, and issuing procedural and substantive 

orders. The administrative law judge also has the obligation to develop the evidence that will be made 

part of the official record and to ensure a full and complete record. At the conclusion of the hearing, the 

presiding judge considers the evidentiary record and issues a fair and impartial initial decision. The parties 

and Commission trial staff may file briefs on exceptions or opposing exceptions to the initial decision 

with the Commission. Finally, Commission advisory staff review the judge’s initial decision and provide 

recommendations to the Commission regarding final action, including whether to affirm, modify, or reverse 

it in a Commission order.

Objective 1.1: Performance Measure

Commission staff will use the following measure to assess performance in Objective 1.1. The result of this 

measure will be used in combination with other data and supplemental information to establish a more 

complete picture of performance on this objective.

The degree to which electric storage 

resources are participating annually in 

organized wholesale electricity markets 

operated by regional transmission 

organizations (RTOs) and independent 

system operators (ISOs) after the issuance 

and implementation of Order No. 841 (Electric 

Storage Participation in Markets Operated by 

RTOs/ISOs)2 

This measure assesses the participation of electric 

storage resources in organized wholesale electric 

markets, where increased participation would serve 

as an indication that competition has increased in 

electricity markets. This is an outcome measure, 

which along with other indicators and supplemental 

information, could provide a useful benchmark by 

which to evaluate the effectiveness of FERC’s Order 

No. 841. 

The intent of Order No. 841 is to remove barriers 

to the participation in organized wholesale electric 

markets of electric storage resources. The entrance 

of these resources into the organized wholesale 

electric markets helps promote competitiveness and 

enhances bulk-power system reliability, security, and 

resilience.

This measure will demonstrate accountability and 

inform decision making. There are two parts to 

this performance measure: (1) the Commission 

expects to act on 75 percent of the six RTO/ISO3

compliance filings by FY 2020; (2) after FY 2020 

and the implementation of Order No. 841, the 

Commission will measure the degree of participation 

of electric storage resources in at least three of the 

six RTOs/ISOs on an annual basis. Although the 

Commission is aware that other factors influence 

the degree to which electric storage resource 

participation in organized wholesale electric markets, 

comparing the results up to FY 2020 and after FY 

2020 should provide useful insight into the order’s 

impact.

2 Electric Storage Participation in Markets Operated by Regional Transmission Organizations and Independent System 

Operators, Order No. 841, FERC Stats. & Regs. ¶ 31,398 (2018) (cross-referenced at 162 FERC ¶ 61,127), available 

at https://www.ferc.gov/media/news-releases/2018/2018-1/02-15-18-E-1.asp. 

3 California Independent System Operator Corporation (CAISO), ISO New England, Inc. (ISO-NE), New York 

Independent System Operator, Inc. (NYISO), Midcontinent Independent System Operator, Inc. (MISO), PJM 

Interconnection, L.L.C. (PJM), and Southwest Power Pool, Inc. (SPP).
5

The Strategic Plan 

FY 2018–2022

Objective 1.2: Increase compliance with FERC rules; detect and 

deter market manipulation.

The Federal Power Act and the Natural Gas Act, along with other statutory authorities, give FERC oversight 

and enforcement responsibilities that focus on increasing compliance of regulated entities and detecting 

and deterring market manipulation. The Energy Policy Act of 2005 in particular increased both the 

Commission’s responsibilities and its penalty authority. 

Within the compliance focus of this objective, FERC gathers information about and analyzes market 

fundamentals, behavior, and trends in order to take proactive steps to reduce the probability that violations 

of applicable laws, the Commission’s regulations, or market rules will occur. FERC also promotes 

internal compliance programs and employs a robust audit program to identify problems and provide 

recommendations to improve compliance. FERC also makes market and audit data transparent to the public 

and market participants so that market efficiency is promoted and anomalies and areas of concern may be 

identified and reported.

Fraud and market manipulation pose a significant threat to the markets overseen by the Commission, and 

the financial harm imposed by such actions ultimately is borne by consumers. To detect and deter fraud 

and market manipulation, FERC uses market surveillance and other sources to identify indications of 

misbehavior. FERC then conducts investigations, and, when appropriate, exercises the Commission’s civil 

penalty authority to discourage violations. 

Promoting compliance and inhibiting market misconduct strengthen markets, increase market confidence, 

and support the Commission’s goal of ensuring that rates, terms, and conditions of jurisdictional energy 

services are just, reasonable, and not unduly discriminatory or preferential. 

Objective 1.2: Situational Assessment and Strategic Responses

Situational Assessment Item – Non-traditional Market Participants

FERC-jurisdictional energy markets are continuing to evolve, including increasing participation of 

non-traditional market participants, which offers an opportunity to engage with traditional and new 

stakeholders to bolster compliance.

Strategic Response

• The Commission will bolster its existing efforts and explore new ways to educate market participants, 

including with respect to market manipulation and the evolving nature of markets.

In addition to addressing the situational assessment item through the stated actions above, the Commission 

will continue to carry out its core functions as a regulatory agency, which are described below.

Core Functions for Objective 1.2

Core Function 1.2.1: Increase compliance by identifying anomalies and potential rule 

improvements, and through stakeholder education and outreach.

In the complex and rapidly evolving energy marketplace, ongoing observation and analysis are necessary 

to ensure that market rules are effective and practicable for those who must follow them. FERC monitors 

market activities and conducts audits of jurisdictional entities to understand the factors affecting compliance 

and facilitate compliance through information sharing, feedback, and practical recommendations. 
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Federal Energy 

Regulatory Commission

FERC staff routinely monitor the energy markets to identify and evaluate significant market events and 

trends, inefficient market rules, and other unusual market behavior. In addition, FERC staff have developed 

and routinely run algorithmic screens and conduct ongoing analysis of transactional and other market data to 

identify factors that may inhibit compliance and/or indicate a need for new or adapted market rules. These 

analyses may result in reports to the Commission or the public to inform recommendations for market rule 

changes or other Commission action and to provide market participants with information about market 

fundamentals.

FERC staff also work to increase compliance by conducting audits of jurisdictional entities. These audits 

assess compliance with carefully crafted rules and regulations and provide insight into the factors affecting 

compliance. FERC staff thoroughly examine areas identified within the scope of each audit in order to assess 

compliance and, in cases of noncompliance can often identify irregularities and/or areas where existing 

policies or regulations are not wholly effective. Audits thus require a deep understanding of both FERC 

policy and the complexities of energy markets and draw on the expertise of different Commission offices with 

multidisciplinary skills in auditing, accounting, engineering, rate design, policy, and law. In addition, audit 

staff provide informal feedback to the audited entities during the audit engagements, and formal findings are 

issued in public reports that facilitate compliance across jurisdictional entities.

A risk-based approach to plan and prioritize audits helps FERC examine areas of regulatory importance 

and make the most efficient use of its resources. Annual risk assessments gather input from a variety of 

resources, including forms filed with the Commission, state commissions, and the Securities and Exchange 

Commission; rate information; FERC and state rate actions; discussions with industry and state officials; 

discussions with senior FERC officials and staff; and internally developed audit screens. 

FERC’s oversight activities promote compliance and alert the Commission to potential areas of concern. By 

reducing the probability that noncompliance will occur, FERC ensures that policies and regulations continue 

to promote a fair marketplace and market efficiencies. 

Core Function 1.2.2: Detect and deter market manipulation by identifying and conducting 

investigations of potential violations.

Even the most carefully crafted policies are ineffective if they are not followed. Surveillance and enforcement 

promote a fair market for both service providers and end users. In its role as an enforcement body, FERC 

conducts surveillance and investigations with the aim of detecting and deterring violations, including market 

manipulation by regulated entities. 

FERC staff monitor energy markets on a daily basis using sophisticated surveillance screens and tools 

developed by staff that algorithmically screens data from the physical and financial energy markets. Staff 

run these automated screens on a routine basis (daily, weekly, monthly, as appropriate depending on the 

nature of the screen) and carefully study the results. Staff analyze any screen trips in depth to determine 

whether anomalous market behavior is an indication of a potential violation or the result of factors such as 

market fundamentals, weather or unusual market activity, or business needs. To the extent data are available, 

the screening and analysis will incorporate financial products to examine their interaction with physical 

transactions. When staff analyses identify potential violations by market participants, staff refer them for 

investigation. 

FERC monitoring is only one source for detecting market manipulation. FERC may be notified through 

a variety of sources, including self-reports, tips, calls to the Enforcement Hotline, and referrals from 

organized markets or their monitoring units. In addition, information may come from other offices within 

the Commission or other authorities such as state agencies. FERC staff may also follow up on findings from 

other investigations.
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The Strategic Plan 

FY 2018–2022

In response to any of these inputs, FERC staff conduct public and non-public investigations of these possible 

violations of the statutes, regulations, rules, orders, and tariffs administered by the Commission. Attorneys, 

analysts, and economists, who are experienced and knowledgeable about energy markets, compile and 

review information from data requests, sworn testimony, field audits, and similar methods, and develop 

an investigative record. In attempting to achieve a fair resolution of an investigation, FERC staff will also 

consider the level of cooperation by the utility being investigated, whether the violation was self-reported, the 

compliance culture of the organization, and the harm or risk of harm posed by the violation.

FERC staff determine whether the evidence indicates a violation. If no violation is identified, the 

investigation is terminated. If a violation of sufficient seriousness is indicated, the Office of Enforcement 

reports its factual findings and legal conclusions to the Commission and, upon authorization from the 

Commission, attempts to resolve the investigation through settlement. If a settlement is not reached, FERC 

staff may recommend that the Commission pursue further enforcement proceedings and participates in 

enforcement proceedings before an administrative law judge or district court. All investigations produce an 

administrative record that reflects the investigative findings and legal conclusions. 

FERC’s enforcement efforts lead to a fair resolution of each investigation, whether the result is a settlement 

or an enforcement proceeding that results in the payment of a civil penalty, disgorgement of unjust profits, 

compliance monitoring, and/or other remedies available to the Commission. FERC’s actions to detect and 

deter market manipulation by market participants ensure that policies and regulations continue to promote a 

fair marketplace.

Objective 1.2: Performance Measure

Commission staff will use the following measure to assess performance in Objective 1.2. The result of this 

measure will be used in combination with other data and supplemental information to establish a more 

complete picture of performance on this objective.

Percentage of audit recommendations 

implemented within six months of issuance

This measure tracks the timeliness of the industry’s 

implementation of audit recommendations 

directed by FERC. These recommendations 

include corrective actions that improve compliance 

and enforce FERC’s regulations of the interstate 

transmission of electricity, natural gas, and oil. 

Timely implementation of audit recommendations 

helps to maximize their impact. The sooner 

recommendations are implemented, the sooner the 

jurisdictional entity will experience the benefits. 

Timely implementation of recommendations also 

helps to demonstrate industry’s commitment to 

compliance and fair, competitive markets. 

FERC’s audits include a review of the jurisdictional 

entity’s compliance program and provide feedback 

on the ways the entity may strengthen its program. 

A strong internal compliance program is an 

effective way of ensuring compliance with statutes, 

Commission rules, orders, regulations, and tariff 

provisions, and significantly increases the likelihood 

that entities will abide by, and follow the spirit of, 

relevant rules and regulations. 

Compliance programs with a strong emphasis on risk 

assessment encourage and promote self-detection of 

issues in a timely manner to prevent noncompliance 

proactively, rather than responding reactively to 

mitigate and remediate compliance deficiencies. 

The measurement results will be used to evaluate the 

industry’s responsiveness to audit recommendations, 

inform future audits, and help FERC to determine 

whether additional and/or different outreach and 

educational materials are needed. 
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Federal Energy 

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9

The Strategic Plan 

FY 2018–2022

Goal 2: Promote Safe, Reliable, and 

Secure Infrastructure

Promote the development of safe, reliable, and secure infrastructure that serves 

the public interest.

The nation’s demand for energy continues to grow, requiring the expansion of the infrastructure that provides 

that energy. Infrastructure for which FERC approval is required includes interstate natural gas pipelines and 

storage projects, LNG facilities, and non-federal hydropower facilities. These facilities are critical to meet 

the nation’s growing energy needs. Ensuring the development of safe, reliable, and secure infrastructure that 

provides energy for consumers at a reasonable cost is a significant, multifaceted challenge. Because of its 

many uses, particularly as a fuel for electric power generation, the demand for natural gas in the United States 

is at its highest levels on record and natural gas production continues to increase due to the development 

of shale gas. Interest in developing hydropower projects has also increased. Hydropower facilities provide 

renewable, domestic energy.

FERC’s role as an independent regulatory agency includes both the review of infrastructure projects as well 

as the minimization of risks to the public in the operation of the infrastructure. To promote safe, reliable, and 

secure infrastructure, FERC must ensure the sustainability and safety of non-federal hydropower projects 

and LNG facilities throughout their entire life cycle; oversee the development and review of, as well as 

compliance with, mandatory reliability and security standards for the bulk-power system; and help to secure 

the infrastructure from cyber and physical attacks. 

Objective 2.1: Facilitate benefits to the nation through the review 

of natural gas and hydropower infrastructure proposals.

The Natural Gas Act and the Federal Power Act, among other statutory authorities, charge FERC with the 

responsibility to oversee the development of robust, reliable and secure energy infrastructure that operates 

safely. More specifically, FERC is charged with authorizing the construction and operation of interstate 

natural gas pipelines and storage projects, LNG facilities, and non-federal hydropower projects. With the 

rising demand for natural gas and hydropower comes increased infrastructure construction, making it all the 

more important that FERC oversee the private sector development of safe, reliable, and secure infrastructure 

in a way that fosters economic and environmental benefits for the nation. 

FERC achieves this objective through the review of applications to construct, operate, or modify natural gas 

and hydropower infrastructure by ensuring that facilities are constructed and operated in compliance with 

the conditions of FERC orders. FERC’s review of proposed projects must balance a range of factors such 

as competing interests, legal requirements, and environmental impacts. FERC also coordinates with other 

agencies, as appropriate, to consider issues related to environmental statutes such as the Endangered Species 

Act, National Historic Preservation Act, Coastal Zone Management Act, and Clean Water Act. In exercising 

its authority, FERC ensures the development and operation of safe, reliable, and secure infrastructure while 

ensuring that impacts are mitigated to acceptable levels. 

2
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Federal Energy 

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Objective 2.1: Situational Assessment and Strategic Responses

Situational Assessment Item – Permitting Challenges

It is increasingly difficult for the Commission to complete its permitting process for needed energy 

infrastructure on a schedule that is timely and predictable.

Strategic Response

The Commission will implement a combination of internal and external process improvements and 

stakeholder communication to address permitting challenges:

• Seek and implement ways to make the Commission’s permitting process more efficient. Such 

efforts include implementation of the Fixing America’s Surface Transportation Act of 2015; 

enhanced interactions with other federal agencies, including pursuant to the One Federal Decision 

Memorandum of Understanding; and a formal review of the Commission’s 1999 Certificate Policy 

Statement for Natural Gas Pipelines, launched in April of 2018. 

• Provide to the public more detailed, project-specific information on FERC.gov.

• Develop and provide to the public clearer information on FERC’s role and responsibilities with respect 

to infrastructure permitting, as well as how FERC’s permitting process works. 

In addition to addressing the situational assessment item through the stated actions above, the Commission 

will continue to carry out its core functions as a regulatory agency, which are described below.

Core Functions for Objective 2.1

Core Function 2.1.1: Conduct thorough and timely technical review of applications to construct, 

operate, or modify natural gas and hydropower infrastructure.

To meet the demand for energy, FERC must respond to energy infrastructure applications with timely 

and well-reasoned decisions. FERC receives applications for original hydropower construction, relicensing 

of existing hydropower facilities, amendments to hydropower licenses, LNG facility construction, and 

natural gas pipeline and storage project construction. It is incumbent upon FERC to ensure that such 

projects are constructed safely and result in sustainable infrastructure that benefits the nation economically 

by providing widespread energy access and fostering competitive markets. Therefore, each application 

undergoes a thorough review as part of FERC’s authorization process. FERC establishes a cross-office team 

of subject matter experts, including engineers, biologists, archaeologists, geologists, other environmental 

scientists, accountants, economists, and lawyers, who thoroughly review and analyze the application from 

environmental, engineering, economic, and legal perspectives; for natural gas applications, FERC also 

considers accounting and rate impacts. During the review, staff prepare documents in accordance with the 

National Environmental Policy Act, e.g., an environmental assessment or environmental impact study. 

For less complex applications, the Commission may delegate to staff authorization to approve or deny the 

application; for more complex applications, the Commission reviews staff ’s recommendation and makes the 

final determination. The process results in a Commission order, including terms and conditions, addressing 

the application. The Commission’s review processes are designed to result in well-reasoned decisions based on 

a wide range of input from staff technical experts, other regulatory agencies, and the public.
11

The Strategic Plan 

FY 2018–2022

Core Function 2.1.2: Ensure natural gas and hydropower infrastructure is constructed and 

operated in compliance with environmental mitigation conditions in FERC orders.

FERC issues orders authorizing energy infrastructure projects for natural gas pipelines and storage facilities, 

LNG facilities, and hydropower facilities. FERC’s orders include terms and conditions designed to address 

impacts resulting from a project on the environmental resources in project areas. Among other things, 

these terms and conditions address water and air quality, land use and recreation, erosion control, cultural 

resources, and wildlife and endangered species.

As specified by the authorization, licensees and certificate holders must implement specific environmental 

and operational measures, generally after filing detailed plans, proposals, and reports regarding this 

implementation. FERC ensures compliance with the terms and conditions of the order through extensive 

environmental review and inspection programs of jurisdictional facilities during construction and operation. 

These programs evaluate and assess implementation and compliance with the environmental and public use 

requirements of authorizations. At regularly scheduled intervals, qualified Commission staff familiar with the 

project and FERC rules and regulations conduct on-site inspections to confirm that licensees and certificate 

holders are abiding by terms and conditions specified in the authorizations. 

By helping to ensure that facilities are built and operated in compliance with the stipulated terms and 

conditions, FERC’s review and inspection programs support the operation of safe, reliable, and secure energy 

infrastructure.

Objective 2.1: Performance Measure

Commission staff will use the following measure to assess performance in Objective 2.1. The result of this 

measure will be used in combination with other data and supplemental information to establish a more 

complete picture of performance on this objective. 

Percent of orders issued within established 

timeframes

The measure reflects the Commission’s ability to 

analyze proposals for infrastructure while ensuring 

any decisions are based on thorough environmental 

and technical analyses in a timely manner. 

FERC regulated entities must obtain authorization 

before beginning the construction of natural 

gas pipeline, gas storage, LNG, and hydropower 

facilities and implementing measures required 

from relicensing a hydropower facility. FERC 

must process applications in an efficient and timely 

manner and ensure that its authorizations are based 

on thorough environmental analysis. In most cases, 

the Commission is required to prepare a National 

Environmental Policy Act (NEPA) document that 

looks at the various potential environmental impacts 

of a project.

The preparation of NEPA documents depends on 

the quality and timeliness of the data provided by 

the applicant. FERC has made an effort to improve 

application quality by developing a pre-filing 

process in which the applicant works to compile the 

necessary information before the application is filed. 

The results of this performance measure will 

be used to determine whether the FERC 

processes, capabilities, and resources for analyzing 

infrastructure proposals needs to be improved or 

expanded. The Commission may also use the results 

to determine whether staff, licensees, or applicants 

need additional guidance for any component of 

the process (e.g., performing outreach, submitting 

adequate applications, completing NEPA 

documents, or drafting orders).
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Federal Energy 

Regulatory Commission

 Cross Agency Priority Goal

The Commission has been named as an Agency Partner to achieve a Cross-Agency Priority (CAP) Goal. 

CAP Goals have been established to drive implementation of the President’s Management Agenda and tackle 

critical government-wide challenges that cut across agencies.

Per the GPRA Modernization Act requirement to address CAP Goals in the agency strategic plan, the 

annual performance plan, and the annual performance report, please refer to www.Performance.gov for the 

agency’s contributions to those goals and progress, where applicable. The Commission currently contributes 

to the Modernizing the Infrastructure Permitting Process CAP Goal.

As a lead agency responsible for the environmental review of non-federal hydropower, interstate natural 

gas facilities, and natural gas import/export projects, the Commission contributes to this CAP Goal by 

providing a more predictable and transparent review process, based on concurrent and synchronized 

evaluations with other agencies. In accordance with the CAP Goal, the Commission will seek to review 

proposals within an average of two years from complete application to decision. 
13

The Strategic Plan 

FY 2018–2022

Objective 2.2: Minimize risks to the public associated with FERCjurisdictional energy infrastructure.

The Natural Gas Act and the Federal Power Act, among other statutory authorities, charge FERC with 

ensuring that energy infrastructure, once authorized, continues to operate safely and reliably. Failure of LNG 

or hydropower infrastructure due to structural issues, unsafe operations, natural disasters, cyber and physical 

attacks, or other hazards can result in loss of life as well as environmental and economic consequences. 

In addition, the Energy Policy Act of 2005 amended the Federal Power Act to give FERC authority 

with respect to reliability standards for the bulk-power system and oversight of an Electric Reliability 

Organization (ERO). In fulfilling these responsibilities, it is critical that FERC minimize risks to the public 

associated with FERC-jurisdictional energy infrastructure

FERC achieves this objective through a range of activities. FERC conducts timely safety reviews and 

inspections with rigorous requirements, thereby advancing the safety of non-federal hydropower projects 

and LNG facilities throughout their entire life cycle. FERC also oversees the development and review of 

mandatory reliability and security standards for the bulk-power system, as well as compliance with these 

standards. In addition, FERC collaborates with regulated entities and other federal and state governmental 

agencies to identify and seek solutions to cyber and physical threats to FERC-jurisdictional infrastructure, 

facilitating proactive efforts that prevent or mitigate loss or damage. 
14

Federal Energy 

Regulatory Commission

Objective 2.2: Situational Assessment and Strategic Responses

Situational Assessment Item – Public and Environmental Safety Impacts

The Commission has witnessed recent incidents at jurisdictional facilities that have highlighted the safety 

and environmental impacts that can be associated with hydropower and natural gas infrastructure.

Strategic Response 

The Commission will take additional actions to address emerging public and environmental safety issues:

• Focus on identifying areas for improvement based on the results of the peer review analysis of the 

Commission’s dam safety program performed after the Oroville incident.

• Continue to improve the Commission’s compliance program to ensure that the regulated community 

is held to the high standards set forth in project-specific certificate conditions.

Situational Assessment Item – New and Evolving Threats

FERC-jurisdictional infrastructure and facilities are at increased risk from new and evolving threats, 

including physical and cyber security threats, by sophisticated perpetrators that often have access to 

significant resources.

Strategic Response

In light of such threats, the Commission will implement a variety of actions: 

• Strengthen internal expertise related to the cyber and physical security of jurisdictional facilities 

through hiring of additional qualified staff, enhanced training and educational activities. 

• Apply, as appropriate, staff expertise related to cyber and physical security in inspections, audits, and 

reviews to help regulated entities improve their responses to threats and their overall security posture; 

assist owners and operators of jurisdictional facilities in recognizing vulnerabilities within their 

facilities; and provide guidance about how to improve security and reduce risk to themselves and the 

public.

• Conduct oversight activities to observe the implementation of cyber and physical security at 

jurisdictional facilities and to identify areas where reliability and security standards can be 

strengthened or best practices applied.

• Work with other federal agencies to improve information sharing and awareness of interdependencies 

and the need to address critical infrastructure issues using a holistic approach as opposed to acting in 

isolation.
15

The Strategic Plan 

FY 2018–2022

Situational Assessment Item – New Challenges to Bulk-Power System Performance

Multiple internal and external factors – including the development, application and increased 

penetration of new technologies, including electric storage; the deployment of distributed energy 

resources; increased dependence on computing and telecommunications; and threats from extreme 

weather and natural disasters – are creating new challenges and opportunities to maintain and improve 

reliability, security, and resilience. All of these trends are occurring in an environment of greater customer 

needs, expectations, and capabilities.

Strategic Response

• Conduct monitoring, analysis of bulk-power system performance, the targeted application and 

oversight of market rules and mandatory reliability standards, oversight of the ERO, and engagement 

with interested industry members and groups to promote additional best practices.

In addition to addressing the situational assessment item through the stated actions above, the Commission 

will continue to carry out its core functions as a regulatory agency, which are described below.

Core Functions for Objective 2.2

Core Function 2.2.1: Conduct comprehensive and timely inspections of hydropower and 

LNG facilities to ensure compliance with the Federal Power Act, the Natural Gas Act, and 

Commission orders.

To fulfill its responsibility for ensuring the safety of an LNG facility or a non-federal hydropower project, 

FERC relies on physical inspections. Before hydropower and LNG facilities are constructed, FERC staff 

review the design, plans, and specifications in both the Commission order and the documents and reports 

filed by authorization holders. During facility construction and operation, FERC engineers conduct 

regularly scheduled and comprehensive inspections. The inspections verify that dams and LNG facilities 

meet stipulated design criteria that ensure safe and reliable operation. The resulting inspection reports and 

deficiency reports also include necessary remedial modifications and/or required maintenance. 

Core Function 2.2.2: Protect and improve the reliable and secure operation of the bulkpower system by identifying reliability and security risks; overseeing the development, 

implementation and enforcement of mandatory reliability standards; and promoting the 

resilience, reliability and security of the bulk-power system.

The nation’s bulk-power system is the backbone of the economy, delivering essential services to end users 

every moment of every day. FERC promotes the reliability of that system through oversight of the ERO, 

which develops mandatory reliability and security standards in the United States and enforces compliance 

with those standards through audits, investigations, and proposed penalties. 

In its oversight role, FERC reviews reliability and security standards proposed by the ERO. For proposed 

standards, the Commission may issue an order to accept, remand, or direct modifications. 

FERC reviews documentation supporting ERO audits, investigations, and proposed penalties and 

remediation for non-compliance. FERC also gathers information through near-real-time monitoring of the 

grid, obtaining supplementary data on grid functionality through data services and coordination with facility 

owners and operators. FERC maintains an up-to-date knowledge on grid technologies and changes in the 

bulk-power system to assess potential risks to reliability and opportunities to improve reliability. In addition, 

FERC engages with stakeholders and experts, sometimes by hosting technical conferences, to better monitor 

the cyber security landscape and remain abreast of trends that may affect bulk-power system reliability. 
16

Federal Energy 

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These sources inform FERC’s assessment and analysis activities. First, drawing on the substantial expertise of 

its staff, including electrical engineers with many years of experience in the utility industry, FERC analyzes 

proposed ERO standards to determine whether they support the reliable operation of the grid. In addition, 

FERC oversees ERO audits, investigations, and proposed penalties and remediation to determine whether 

they lead to compliance with reliability and security standards. The Commission may issue an order initiating 

review of a proposed penalty in cases where further review is warranted. FERC conducts inquiries, audits, 

and investigations of major blackouts and other grid-related events to determine whether the standards 

were violated and whether adjustments to the standards are needed to help prevent future blackouts. FERC, 

sometimes in collaboration with the ERO, engages with regulated entities to assess how the standards are 

implemented and to determine if changes to the standards are warranted.

Core Function 2.2.3: Protect against cyber and physical security threats to FERC-jurisdictional 

energy infrastructure and improve their resilience by working with regulated entities and 

stakeholders and by coordinating with other government agencies to identify and apply best 

practices separate from basic regulatory requirements.

Growing cyber and physical security threats, along with increasing automation and other developments, 

demand an agile and focused approach to energy infrastructure security. FERC staff employ deep familiarity 

with FERC-jurisdictional infrastructure, extensive experience in grid operations, and cyber security expertise 

to coordinate with and support other government agencies and regulated entities in addressing these threats. 

FERC employs a four-part process of identify, inform, assess, and address cyber and physical security 

threats. FERC partners with federal agencies to identify and assess threats, activities, and capabilities of 

adversaries that may initiate a cyber or physical attack on FERC-jurisdictional infrastructure and ensures that 

jurisdictional entities are made aware of these threats. FERC also works with government partners to identify 

and assess key infrastructure facilities that present the greatest risk. By maintaining connections, partnership, 

and awareness, FERC’s collaboration and outreach efforts to inform are directed toward both government 

partners and jurisdictional entities. To ensure that jurisdictional entities are informed about security threats 

and counter measures, FERC conducts briefings and helps infrastructure representatives obtain security 

clearances that gives them access to classified threat information. FERC also reviews and provides input 

to ERO alerts, advisories, and bulletins to ensure they are useful and relevant to jurisdictional entities. 

Finally, FERC helps jurisdictional entities address cyber and physical threats by developing and compiling 

best practices, mitigation measures, and tools and techniques to enhance protection of facilities. FERC 

encourages the implementation of these best practices, mitigation measures, and tools and techniques by 

conducting onsite security assessments of jurisdictional electric, natural gas, hydropower, and LNG facilities.

The Commission’s contributions reduce the risk of cyber and physical security threats to vital energy 

infrastructure. The Commission’s efforts in this area thus provide an important complement to FERC’s 

related responsibilities for both regulatory requirements and enforcement. 
17

The Strategic Plan 

FY 2018–2022

Objective 2.2: Performance Measures

Commission staff will use the following measures to assess performance in Objective 2.2. The results of these 

measures will be used in combination with other data and supplemental information to establish a more 

complete picture of performance on this objective.

The annual amount of lost load in a given 

year resulting from bulk-power system 

transmission-related events (unplanned 

disturbances), excluding weather related 

outages

The annual amount of lost load (measured in 

megawatts) resulting from unplanned disturbances 

other than weather provides a measure of FERC’s 

impact on system reliability and serves as an 

indicator of the Commission’s effectiveness in 

minimizing risks to the public associated with 

FERC-jurisdictional energy infrastructure. FERC’s 

efforts to protect and improve the reliable and secure 

operation of the bulk-power system are intended to 

minimize avoidable outages caused by problems on 

the bulk-power system. 

The measure helps to inform the Commission’s 

understanding of the quality and sufficiency of 

reliability standards proposed by the ERO in 

avoiding or reducing outages. The measure also 

helps to inform FERC’s efforts in overseeing the 

ERO’s enforcement of the reliability standards. A 

pattern of lost load would indicate a need for further 

investigation.

The time in which each U.S. interconnection 

recovers from generator loss events 

This measure serves as a proxy for the bulk-power 

system’s ability to recover from disturbances as 

mandated by the reliability standards. For example, 

the reliability standards require that entities plan and 

deploy sufficient online reserves to enable the system 

to recover from the loss of a generator. 

Specifically, this measure tracks the recovery of Area 

Control Error (ACE) – a measure of imbalance of 

generation and load in an area, and its restoration of 

reserves.

The change in frequency and elapsed time 

from the initial disturbance to the frequency 

minimum

This measure assesses the performance of the 

three U.S. interconnections in providing primary 

frequency response. Frequency response is a measure 

of an interconnection’s ability to stabilize frequency 

immediately following the sudden loss of generation 

or load. It is a critical aspect of the reliable operation 

of the bulk-power system, particularly during 

disturbances and restoration. Maintaining the 

capability to provide primary frequency response was 

the purpose of Order No. 842 (Essential Reliability 

Services and the Evolving Bulk-Power System—

Primary Frequency Response).4

This measure demonstrates the adequacy of 

Commission-approved reliability standards and 

other actions in stabilizing the bulk-power system 

following the sudden loss of generation and load as 

the resource mix changes. Additionally, the measure 

could inform the Commission’s decisions as it 

pertains to the quality and sufficiency of reliability 

standards proposed by the ERO in ensuring the 

provision of essential reliability services.

4 Essential Reliability Services and the Evolving Bulk-Power System – Primary Frequency Response, Order No. 842, 83 

Fed. Reg. 9,636 (Mar. 6, 2018), 162 FERC ¶ 61,128, order on clarification and reh’g, 164 FERC ¶ 61,135 (2018), 

available at https://www.ferc.gov/media/news-releases/2018/2018-1/02-15-18-E-2.asp. 
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Federal Energy 

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The number of cyber events and the number 

and severity of reliability impacts (including 

outages) in a given year resulting from cyber 

events on bulk-power system assets subject to 

reliability standards 

This measure assesses the degree to which cyber 

related events impact the reliability of the bulkpower system. By following, categorizing and 

tracking cyber events, FERC will better understand 

the root cause of cyber events. Additionally, 

measuring the reliability impact of cyber events is 

one indicator of how well the Critical Infrastructure 

Protection Reliability Standards are protecting 

reliability. 

The information gathered will provide insight 

into any gaps and/or weakness that may exist in 

the Critical Infrastructure Protection Standards 

allowing FERC, the ERO, and industry to address 

these issues with a modification to a standard, a new 

proposed standard, or other approaches to ensure the 

reliability of the grid. 

The extent to which other federal agencies 

are recognizing critical infrastructure 

interdependencies and adopting a holistic 

approach to infrastructure protection 

With cyber and physical security at jurisdictional 

facilities at increasing risk from cyber and physical 

threats, a holistic approach to infrastructure security 

provides a beneficial framework for federal agencies. 

Through information sharing and participation 

in joint assessments, FERC is able to meet the 

increasing security needs of jurisdictional facilities by 

sharing best practices, assisting them with identifying 

vulnerabilities, and providing mitigation strategies to 

promote cyber and physical security at their facilities. 

The performance measure may serve to inform 

decision making within the Commission and to 

provide external stakeholders an indication of 

FERC’s efforts in collaboration, and common 

understanding regarding the security challenges of 

jurisdictional infrastructure. 
19

The Strategic Plan 

FY 2018–2022
20

Federal Energy 

Regulatory Commission
21

The Strategic Plan 

FY 2018–2022

Goal 3: Mission Support through 

Organizational Excellence

Achieve organizational excellence by using resources effectively, adequately 

equipping FERC employees for success, and executing responsive and 

transparent processes that strengthen public trust.

The public interest is best served when the Commission operates in an efficient, responsive, and transparent 

manner. The Commission pursues this goal by maintaining processes and providing services in accordance 

with governing statutes, authoritative guidance, and prevailing best practices. The Commission’s staff, while 

serving in different component offices, must work collaboratively and execute processes that work in concert 

with each other to produce the high-quality results expected by the American people. In accomplishing this 

goal, the Commission will use its resources efficiently, empower its employees, and earn the public trust. 

These essential outcomes are indicative of a model regulatory agency. 

Objective 3.1: Manage resources effectively through an engaged 

workforce.

As the Commission faces new and increasing challenges, the demands on Commission offices and employees 

continue to grow. It is essential for the organization to provide support that addresses internal needs and 

enables organizational excellence. 

FERC achieves this objective by providing processes and services that help office leadership prioritize 

resource allocations, make prudent investments that yield returns that directly benefit the agency’s mission, 

and use Commission resources in an efficient manner. These processes and services also help management 

meet federal statutes that require the Commission to recover its operating costs from the entities it regulates 

and do so in a manner that avoids unnecessarily increasing the cost of energy to consumers. 

FERC also achieves this objective by providing services, tools, and resources that equip employees to drive 

success and accomplish the agency’s mission. On an annual basis, the Commission allocates over two-thirds 

of its budget to directly cover the compensation costs of its employees. Given this significant investment, 

the Commission places extremely high value on its employees and is focused on ensuring that employees 

have a performance management system that clarifies expectations, removes barriers to performance and 

engagement, and provides useful feedback that supports employee effectiveness. 

By providing processes and services that meet internal needs, FERC supports the effective use of resources, 

equips employees for success, and achieves organizational excellence.

3
22

Federal Energy 

Regulatory Commission

Objective 3.1: Situational Assessment and Strategic Responses

Situational Assessment Item – New Challenges and Opportunities for Mission-Related 

Information

Availability of mission-related information is increasing, which presents new challenges and 

opportunities for FERC to leverage analytics to help identify and understand issues, assess implications 

of actions, and evaluate Commission effectiveness.

Strategic Response

• The Commission will implement a multi-step initiative that includes: 1) data assessment, including 

identifying what data are currently available, uses the data could serve, and limits on such uses; 2) data 

validation and standardization; 3) development of user friendly analytic tools; and 4) building the 

internal capability to support the initiative, including a recruitment strategy.

Situational Assessment Item – Maintaining a Secure and Reliable IT Infrastructure

FERC is challenged with maintaining a secure and reliable IT infrastructure to meet the needs of the 

Commission and provide innovative solutions to support employees.

Strategic Response

• Resource planning will include a focus on identifying and updating high priority systems and 

addressing system vulnerabilities.

Situational Assessment Item – New and Emerging Knowledge/Skill Demands

The challenges of new and emerging knowledge/skill demands and the loss of institutional knowledge 

will create increasing staffing vulnerabilities, employee development pressures, and a need for crossfunctional collaboration.

Strategic Response

To address these workforce issues and enable the application of new skills and a greater depth and 

breadth of skills, the Commission will implement an integrated human capital initiative that includes the 

following actions: 

• Identify knowledge and skill gaps/needs and staffing vulnerabilities across the Commission.

• Align and integrate three elements to efficiently address human capital gaps and staffing vulnerabilities: 

1) competency-based training; 2) knowledge management tools; and 3) targeted hiring process to 

acquire new knowledge and skills in the workforce (e.g., electrical engineering expertise relevant to the 

bulk-power system, cyber security, data analytics, etc.). 

• Enhance communication, collaboration, and knowledge sharing to promote cross-functional 

understanding and enable more efficient integration and coordination of efforts.

In addition to addressing the situational assessment item through the stated actions above, the Commission 

will continue to carry out its core functions as a regulatory agency, which are described on the next page.
23

The Strategic Plan 

FY 2018–2022

Core Functions for Objective 3.1

Core Function 3.1.1: Maintain processes and provide compliant services that enable FERC 

offices to manage resources effectively and efficiently.

The Commission achieves its mission when the internal management of FERC is supported by processes and 

services that enable organizational performance and the efficient use of resources.

To support the mission, FERC plans resource needs, executes compliant and effective processes and services, 

and assesses results against established objectives. In the planning stages, FERC employs a collaborative 

management approach and establishes systems to identify organizational needs – identifying staffing and 

competency needs through human capital processes, information technology and infrastructure needs 

through capital planning and investment control processes, and financial needs through the budget 

formulation process. FERC then develops comprehensive plans to address those needs for achieving program 

results. 

The Commission executes its resource plans to achieve effective and efficient operations, reliable financial 

reporting, and compliance with applicable laws and regulations through mission-support services. 

To ensure the effectiveness of resource planning and execution, FERC measures and evaluates how well 

established processes and services are meeting statutory requirements and addressing identified needs. FERC 

develops control programs and reporting requirements and implements data collection and analyses to 

inform decisions and actions to address performance deficiencies. 

The rigorous and thoughtful application of the planning, execution, and evaluation cycle results in 

compliant processes and services that enable the acquisition and retention of a diverse and skilled workforce; 

procurement of value-added commodities and contractor assistance; delivery of a stable, resilient, and secure 

infrastructure; and the authorization of financial activities. 

This cycle also ensures that the Commission is always cognizant of performance against strategic and 

operational plans and has the information to produce financial statements that accurately represent the 

Commission’s financial condition as well as other federally mandated reports that maintain the Commission’s 

accountability and provide stakeholders with performance information. 

The ongoing delivery of effective internal processes and services is critical to enabling FERC to achieve 

operational excellence, use resources efficiently, and fully contribute to the agency’s mission.

Core Function 3.1.2: Provide tools and services that enable FERC staff to effectively perform 

their jobs and drive Commission success.

The Commission achieves its mission when employees are equipped for success and empowered to take 

accountability for achieving the Commission’s mission, goals, and objectives. FERC enables staff to perform 

effectively and drive success by deploying tools, services, and resources that meet employee needs.

Supervisors and staff jointly apply these tools, services, and resources to enhance individual performance. 

FERC’s performance management system serves as a planning tool that communicates expectations and 

individual responsibilities and establishes accountability for expected results. Supervisors and staff also use 

the system to establish a line of sight between individual performance and the Commission’s mission, goals, 

and objectives. 

To enable the effective execution of performance expectations and responsibilities, FERC provides 

technology, employee development and training programs, health and wellness programs, and other 
24

Federal Energy 

Regulatory Commission

employee services and resources to meet employees’ performance needs and remove obstacles to engagement. 

However, the effective deployment of these services and resources must be a joint responsibility for 

supervisors and staff.

Staff effectiveness and engagement is further supported by performance measurement processes that provide 

feedback to employees, supervisors and the organization. Regular performance appraisals indicate how well 

employees are performing against expectations and objectives, identify performance issues and obstacles, and 

provide useful feedback that enables performance improvement. In addition, organizational assessments such 

as the Federal Employee Viewpoint Survey (FEVS) allow employees to provide feedback about how effective 

the tools, services, and resources provided by the organization are in supporting performance and meeting 

employee needs. 

Effective deployment of performance management tools, services, and resources serves to inform and focus 

employee effort, encourage engagement, and enable employees to drive success. Effective appraisals and 

organizational assessment produce useful feedback about performance and timely information about the 

collective work environment. An effective and engaged staff is critical to achieving the Commission’s mission. 

Objective 3.1: Performance Measures

Commission staff will use the following measures to assess performance in Objective 3.1. The results of these 

measures will be used in combination with other data and supplemental information to establish a more 

complete picture of performance on this objective.

The extent to which employees are engaged 

and equipped to perform their jobs to the best 

of their ability (People Measure)

This measure assesses the degree to which employees 

are engaged and equipped to perform their jobs 

to the best of their ability. Engagement is defined 

as employees’ capacity to remain dedicated and 

committed to FERC and its mission as well as 

their sense of purpose at work. It plays a vital role 

in ensuring that employees fully contribute and 

perform at their best. This measure is comprised of 

19 questions from the FEVS and will help FERC 

monitor the overall level of dedication, commitment, 

and satisfaction of its employees. The FEVS is 

an annual, anonymous survey offered to federal 

employees by the Partnership for Public Service, a 

nonprofit, nonpartisan organization that strives for a 

more effective government for the American people. 

FERC management will use the survey results to 

identify and share best practices and continuously 

strive to maintain an engaged workforce. The results 

of the measure can also serve as an alert system 

for employee issues or unmet employee needs that 

may need to be addressed. FERC may respond to 

a significant decrease in the results by obtaining 

additional qualitative feedback from employees to 

gain a better understanding of specific concerns, then 

modifying its internal operations and services, where 

possible. 

The percent of dollars appropriated that have 

been obligated (Dollars Measure)

The measure captures FERC’s efforts to utilize 

its resources effectively and efficiently. Congress 

determines appropriations based in part on FERC’s 

annual budget request of its resource needs and 

projected spending levels. FERC obligates funds 

for its planned requirements and, when necessary, 

makes decisions to use unobligated funding for new 

or changed requirements. The more effective FERC 

is at forecasting its resource needs and executing 

its operating plans in an efficient manner, the more 

likely it is to meet its mission. 

To assist the offices in effectively and efficiently 

utilizing FERC’s resources, FERC provides support 

to the offices in formulating and executing their 

budgets. This support includes the development 

and administration of acquisition and budgeting 
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The Strategic Plan 

FY 2018–2022

processes and procedures designed to promote 

more efficient and effective resource utilization. The 

measure results thus provide an assessment of how 

well FERC effectively and efficiently developed 

and executed its operating plans in carrying out its 

mission.

The degree to which internal services meet 

employee and organizational needs (Quality 

Measure)

This measure assesses FERC’s internal, organizational 

effectiveness in providing services to employees and 

offices. By delivering these services, FERC supports 

the effective use of resources, equips employees for 

success, and achieves organizational excellence. To 

calculate the results, the Commission administers 

two internal customer satisfaction surveys. The first 

survey assesses customer satisfaction of services 

provided directly to employees, such as health and 

life programs, benefits counseling, and IT support. 

The second survey assesses customer satisfaction of 

services provided to support a Commission office, 

such as acquisition services, hiring processes, and 

systems development. As an aggregate of customers’ 

overall impression ratings for all services, the Quality 

Measure provides a high level indication of FERC’s 

responsiveness in providing quality services that 

meet the needs of its employees and offices. 

The results will help FERC determine the extent 

to which a service needs improvement and to help 

identify courses of action to improve the service.
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Federal Energy 

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Objective 3.2: Facilitate public trust and understanding of 

Commission activities by promoting transparency, open 

communication, and a high standard of ethics.

Facilitating understanding of how the Commission carries out its responsibilities and maintaining public 

trust in the Commission are important components of the Commission’s commitment to organizational 

excellence. Trust and understanding increase acceptance of FERC decisions and reduce the potential for the 

public to dispute FERC rules and regulations, thus enabling the creation and enforcement of policy. 

The Commission achieves this objective by maintaining processes and public information services that 

promote transparency and open communication with respect to the conduct of the Commission’s business. 

FERC’s proactive communication, along with an online document repository and timely responses to 

inquiries, foster awareness and understanding of the Commission’s activities.

The Commission also advances this objective by maintaining internal processes and services that ensure 

adherence to statutes, regulations, and self-imposed standards. In addition, FERC provides training and 

guidance to promote an ethically informed workforce. These activities further encourage public confidence in 

the Commission’s activities and ability to fulfill its responsibilities.

Objective 3.2: Situational Assessment and Strategic Responses

Situational Assessment Item – Greater Public Interest in Regulatory Issues

Greater public interest in and concern about issues that are or may come before the Commission are 

creating the need for more dynamic engagement processes with the public.

Strategic Response

The Commission will take multiple actions to enhance communication and engagement with the public.

• Explore opportunities to engage more effectively with the public and enhance public participation in 

Commission proceedings through its online applications and website.

• Focus on deploying more flexible, multimodal mechanisms to enhance communication with the public 

and other stakeholders.

• Focus on understanding engagement/participation/messaging needs of the Commission and aligning 

FERC’s efforts.

In addition to addressing the situational assessment item through the stated actions above, the Commission 

will continue to carry out its core functions as a regulatory agency, which are described below.

Core Functions for Objective 3.2

Core Function 3.2.1: Develop and maintain internal processes and services that promote high 

standards of ethics.

To ensure public trust in the exercise of FERC’s regulatory authority, the Commission promotes and 

demonstrates a high standard of ethics.
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The Strategic Plan 

FY 2018–2022

The Commission develops and maintains processes and programs to ensure that the activities of its employees 

conform to statutes and regulations relating to the standards of ethics and conduct. The Commission utilizes 

innovative annual ethics training to promote an ethically informed workforce. 

The Commission manages the financial disclosure processes, established by 5 U.S.C. §§ 101-111, through 

review of employees’ financial disclosure reports to avoid, detect, or resolve conflicts and to promote 

compliance with relevant statutory and associated regulatory requirements. 

The Commission’s ethics program is supplemented by an established internal process that, among other 

facets, provides staff with resources to seek guidance regarding the executive branch ethics requirements and 

other relevant laws. The Commission also has processes to address alleged wrong-doing, unethical behavior, 

and allegations of unauthorized release of non-public information. 

The training programs, guidance, and disclosure forms produced by these efforts provide on-going 

documentation and demonstration of FERC’s high standards of ethics. They provide a concrete 

representation of FERC’s commitment to integrity in the exercise of its regulatory authority and thus 

encourage a level of public trust and confidence that enables FERC to carry out its mission effectively and 

efficiently.

Core Function 3.2.2: Maintain processes and public information services in accordance with 

the principles of transparency and open communication.

Promoting transparency and open communication with respect to the conduct of the Commission’s business 

facilitates both understanding of how the Commission carries out its responsibilities and public trust in 

the Commission. Indeed, transparency and open communication are the primary means by which the 

Commission ensures that regulated entities and other interested stakeholders have access in a timely manner 

to accurate information about the Commission’s activities. The Commission demonstrates its commitment to 

transparency and open communication in many ways. 

Commission decisions regarding orders and the Commission rulemaking process are supported through 

open communication and documented on eLibrary – FERC’s online document repository. Highly trained 

Commission staff prepare notices that promptly announce incoming filings or proposed rules and establish a 

deadline for other interested stakeholders to submit comments or protests to those filings or rules. To further 

promote transparency, the evidentiary record that documents the basis for Commission decisions on orders 

and rules is inputted into eLibrary and made available online for public view. Moreover, the Commission 

announces open meetings in which the Commission votes on orders with notices that list matters that the 

Commission will discuss. Finally, FERC issues a bi-weekly public notice to make the public aware of any 

off-the-record communications to Commission staff that could influence the Commission’s decision-making 

process. 

Commission transparency is also supported by timely responses to information requests and proactive 

communication and relationship building with stakeholders. Commission staff frequently address questions 

from Congress and other government agencies, state agencies and regulators, the international community, as 

well as from the media and the public at large. 

The Commission pursues proactive engagement and relationship building with regulated entities and other 

interested stakeholders. This includes educating the public and stakeholders about the agency’s mission, 

role, direction, and policy. Experts in communications identify key messages and develop and execute 

communication strategy in collaboration with the Chairman. This includes identifying key messages and 

employing a range of media (email, podcasts, webinars, social media feeds, videos, presentations, press 

releases, reports, etc.) to deliver those messages. FERC staff also advise and work with the Chairman, 

Commissioners, and senior staff to prepare them to testify before Congress.
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Federal Energy 

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The Commission also responds to requests for Critical Energy/Electric Infrastructure Information (CEII) as 

well as inquiries for under the Freedom of Information Act (FOIA) with a focus on transparency and open 

communication. The Commission releases information to the greatest extent possible, while recognizing 

the need for certain information to be withheld from disclosure consistent with statutory exemptions. The 

extensive experience of Commission staff with respect to CEII, FOIA, and the Commission’s processes 

enables prompt issuance of prudent determinations.

FERC’s commitment to maintain a complete and accessible evidentiary record along with a variety of 

multimedia information services ensure transparency regarding Commission actions and decisions and 

promote trust and engagement with public and private stakeholders and the public. Transparency, open 

communications, and ongoing engagement by which stakeholders both have access to information and 

provide input and comment are the mechanisms that build trust and facilitate the exercise of FERC’s 

regulatory authority. 

Objective 3.2: Performance Measure

Commission staff will use the following measure to assess performance in Objective 3.2. The result of this 

measure will be used in combination with other data and supplemental information to establish a more 

complete picture of performance on this objective.

The percent of Commission filings and 

issuances that are disseminated to the public 

within established timeframes

This measure serves as an indicator of FERC’s 

effectiveness in providing timely access to 

documentation associated with a proceeding, an 

application, other FERC action, or filer request. As 

such, the measure reinforces FERC’s commitment 

to transparency, by making documents readily 

and quickly available to all interested parties. By 

providing timely access to documents, FERC builds 

public trust and reinforces its ethical stance.

The measure demonstrates FERC’s commitment 

to open communications. Just as FERC mandates 

that applicants, intervenors, and other filing parties 

adhere to published timeframes, by this performance 

measure FERC shows that the Commission holds 

itself accountable to like standards. 

The results will help FERC determine if software 

applications, business procedures, and staff/

contractor capabilities adequately support the 

performance goal. Where a performance trend 

indicates less than optimal results, FERC will initiate 

a business analysis to identify points of weakness. 

Those points will be strengthened through training, 

application upgrades, or revision in operational 

procedures. 
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The Strategic Plan 

FY 2018–2022

A

Appendix A: Organization Chart5

5 FERC Offices. ferc.gov/about/offices.asp
30

Federal Energy 

Regulatory Commission

B

Appendix B: Acronyms

ACE Area Control Error

CAP Cross-Agency Priority

CEII Critical Energy/Electric Infrastructure Information

ERO Electric Reliability Organization

FERC Federal Energy Regulatory Commission

FEVS Federal Employee Viewpoint Survey

FOIA Freedom of Information Act

FY fiscal year

GPRA Government Performance Results Act of 1993

ISO Independent System Operator

LNG liquefied natural gas

NEPA National Environmental Policy Act

PURPA Public Utility Regulatory Policies Act of 1978

RTO Regional Transmission Organization
31

The Strategic Plan 

FY 2018–2022
Federal Energy 

Regulatory Commission