FEDERAL ENERGY REGULATORY COMMISSION 

Annual Freedom of Information Act Report 

FY 2009 

 February 2009
FEDERAL ENERGY REGULATORY COMMISSION 

 ANNUAL FREEDOM OF INFORMATION ACT REPORT 

 FY 2009 

I. BASIC INFORMATION REGARDING REPORT 

1. Contact with questions about the report. 

Toyia Johnson 

FOIA Liaison 

Federal Energy Regulatory Commission 

888 First Street, NE, Code EA-1 

Washington, DC 20426 

 Toyia.Johnson@ferc.gov

 Telephone : 202-502-6088 

Toll-free: 1-866-208-3372 

FAX Number: 202-208-2106 

2. Electronic address for report on the World Wide Web. 

http://www.ferc.gov/legal/ceii-foia/foia/ann-rep.asp

3. How to obtain a copy of the report in paper form. 

Write to the following address: 

Public Reference and Files Maintenance Branch Federal Energy Regulatory 

Commission 888 First Street, NE, Room 2A Washington, DC 20426 

Telephone: 202-502-8371 

FAX Number: 202-208-2320 

E-Mail: public.referenceroom@ferc.gov 

II. MAKING A FOIA REQUEST 

1. Name, address, and telephone number of agency component that receive 

FOIA requests.

Julia Bovey 

Director, Office of External Affairs 

FOIA Officer 

Federal Energy Regulatory Commission 

888 First Street, NE, Code EA-1 

Washington, DC 20426 

Telephone: 202-502-8004 
 2

 Requests may be submitted via: 

• Online FOIA request form: http://www.ferc.gov/legal/ceii-foia/foia 

• Mail: 888 First Street, NE, Code EA-1, Washington, DC 20426 

• Fax: 202-208-2106

• E-mail: FOIA-CEII@ferc.gov

Please refer to the FOIA Reference Guide on the Commission's Web Site 

http://www.ferc.gov/legal/ceii-foia/foia/guide/basics.asp 

2. Some FOIA requests are not granted because (a) the agency has no 

responsive documents, (b) the responsive documents fall within one or more 

FOIA exemptions and are not appropriate for discretionary release, or (c) a 

request has been rendered moot because the responsive documents were 

subsequently released through other means, such as a negotiated disclosure in 

the course of a Commission proceeding. 

III. ACRONYMS, DEFINITIONS, AND EXEMPTIONS 

1. Agency-specific acronyms or other terms. 

a. Track One Requests -- the processing track for a FOIA request that 

is seeking records that are readily identifiable or were 

previously cleared for release. 

b. Track Two Requests -- the processing track for a FOIA request that is 

seeking records that are readily identifiable and require limited review. 

c. Track Three Requests -- the processing track for a FOIA request that 

is seeking records that are complex and/or voluminous and require a 

significant search and/or review. 

2. Definitions of terms used in this Report: 

a. Administrative Appeal – a request to a federal agency asking that it 

review at a higher administrative level a FOIA determination made by 

the agency at the initial request level. 

b. Average Number – the number obtained by dividing the sum of a 

group of numbers by the quantity of numbers in the group. For 

example, of 3, 7, and 14, the average number is 8. 

c. Backlog – the number of requests or administrative appeals that are 

pending at an agency at the end of the fiscal year that are beyond the 

statutory time period for a response. 
 3

d. Component – for agencies that process requests on a decentralized 

basis, a “component” is an entity, also sometimes referred to as an 

Office, Division, Bureau, Center, or Directorate, within the agency that 

processes FOIA requests. The FOIA now requires that agencies 

include in their Annual FOIA Report data for both the agency overall 

and for each principal component of the agency. All FOIA requests 

for the Federal Energy Regulatory Commission are received and 

processed by the Washington DC branch. 

e. Consultation – the procedure whereby the agency responding to a 

FOIA request first forwards a record to another agency for its review 

because that other agency has an interest in the document. Once the 

agency in receipt of the consultation finishes its review of the record, it 

responds back to the agency that forwarded it. That agency, in turn, 

will then respond to the FOIA requester. 

f. Exemption 3 Statute – a federal statute that exempts information 

from disclosure and which the agency relies on to withhold 

information under subsection (b)(3) of the FOIA. 

g. FOIA Request – a FOIA request is generally a request to a federal 

agency for access to records concerning another person (i.e., a “thirdparty” request), or concerning an organization, or a particular topic of 

interest. FOIA requests also include requests made by requesters 

seeking records concerning themselves (i.e., “first-party” requests) 

when those requesters are not subject to the Privacy Act, such as nonU.S. citizens. Moreover, because all first-party requesters should be 

afforded the benefit of both the access provisions of the FOIA as well 

as those of the Privacy Act, FOIA requests also include any first-party 

requests where an agency determines that it must search beyond its 

Privacy Act “systems of records” or where a Privacy Act exemption 

applies, and the agency looks to FOIA to afford the greatest possible 

access. All requests which require the agency to utilize the FOIA in 

responding to the requester are included in this Report. 

Additionally, a FOIA request includes records referred to the agency 

for processing and direct response to the requester. It does not, 

however, include records for which the agency has received a 

consultation from another agency. (Consultations are reported 

separately in Section XII of this Report.) 

h. Full Grant – an agency decision to disclose all records in full in 

response to a FOIA request. 
 4

i. Full Denial – an agency decision not to release any records in 

response to a FOIA request because the records are exempt in their 

entireties under one or more of the FOIA exemptions, or because of a 

procedural reason, such as when no records could be located.

j. Median Number – the middle, not average, number. For example, of 

3, 7, and 14, the median number is 7. 

k. Multi-Track Processing – a system in which simple requests 

requiring relatively minimal review are placed in one processing track 

and more voluminous and complex requests are placed in one or more 

other tracks. Requests granted expedited processing are placed in yet 

another track. Requests in each track are processed on a first in/first 

out basis. 

i. Expedited Processing – an agency will process a FOIA request 

on an expedited basis when a requester satisfies the 

requirements for expedited processing as set forth in the statute 

and in agency regulations. 

ii. Simple Request – a FOIA request that an agency using multitrack processing places in its fastest (non-expedited) track based 

on the low volume and/or simplicity of the records requested. 

iii. Complex Request – a FOIA request that an agency using 

multi-track processing places in a slower track based on the 

high volume and/or complexity of the records requested. 

l. Partial Grant/Partial Denial – in response to a FOIA request, an 

agency decision to disclose portions of the records and to withhold 

other portions that are exempt under the FOIA, or to otherwise deny a 

portion of the request for a procedural reason. 

m. Pending Request or Pending Administrative Appeal – a request or 

administrative appeal for which an agency has not taken final action in 

all respects. 

n. Perfected Request – a request for records which reasonably describes 

such records and is made in accordance with published rules stating 

the time, place, fees (if any) and procedures to be followed. 

o. Processed Request or Processed Administrative Appeal – a request 

or administrative appeal for which an agency has taken final action in 

all respects. 

p. Range in Number of Days – the lowest and highest number of days to 

process requests or administrative appeals. 
 5

q. Time Limits – the time period in the statute for an agency to respond 

to a FOIA request (ordinarily twenty working days from receipt of a 

perfected FOIA request). 

3. Include the following concise descriptions of the nine FOIA exemptions: 

a. Exemption 1: classified national defense and foreign relations 

information 

b. Exemption 2: internal agency rules and practices 

c. Exemption 3: information that is prohibited from disclosure by 

another federal law 

d. Exemption 4: trade secrets and other confidential business 

information 

e. Exemption 5: inter-agency or intra-agency communications that are 

protected by legal privileges 

f. Exemption 6: information involving matters of personal privacy 

 

g. Exemption 7: records or information compiled for law enforcement 

purposes, to the extent that the production of those records (A) could 

reasonably be expected to interfere with enforcement proceedings, (B) 

would deprive a person of a right to a fair trial or an impartial 

adjudication, (C) could reasonably be expected to constitute an 

unwarranted invasion of personal privacy, (D) could reasonably be 

expected to disclose the identity of a confidential source, (E) would 

disclose techniques and procedures for law enforcement investigations 

or prosecutions, or would disclose guidelines for law enforcement 

investigations or prosecutions, or (F) could reasonably be expected to 

endanger the life or physical safety of any individual 

h. Exemption 8: information relating to the supervision of financial 

institutions 

i. Exemption 9: geological information on wells 
 6

IV. EXEMPTION 3 STATUTES 

A. List of Exemption 3 statutes relied on by the Commission during 

FY 2009. 

Statute Type of 

InformationWithheld

Case 

Citation

Number of 

Times Relied 

upon per 

Component

Total Number of Times 

Relied upon by Agency

16 U.S.C. § 470aa, et seq. 

(1994) [Specifically 

16 U.S.C. § 470hh(a)] 

Archaeological survey data None N/A 4 

. 

. 
 7

V. FOIA REQUESTS 

A. Received, Processed and Pending FOIA Requests 

1. The numbers of received, processed, and pending requests. 

 Column 1 Column 2 Column 3 Column 4 

Number of 

Requests 

Pending as of 

Start of Fiscal 

Year

Number of 

Requests 

Received in 

Fiscal Year

Number of 

Requests 

Processed in 

Fiscal Year

Number of 

Requests 

Pending as of 

End of Fiscal 

Year

Federal Energy 

Regulatory 

Commission 

(FERC)

26 113 112 27 
 8 

B.(1) Disposition of FOIA Requests – All Processed Requests

Number 

of Full 

Grants 

Number 

of 

Partial 

Grants/ 

Partial 

Denials 

Number of Full 

Denials Based 

on Exemptions 

Number of Full Reasons Other Denials Based on than 

No Records All Records 

Referred to 

Another 

Component 

or Agency

Request 

Withdrawn

FeeRelated 

Reason

Records 

not 

Reasonably 

Described

Improper 

FOIA 

Request 

for Other 

Reason

Not 

Agenc

Recor

Federal Energy Regulatory Commission (FERC)

23 27 29 18 2 11 2 0 0 0 
 9 

B.(2) Disposition of FOIA Requests – “Other” Reasons for “Full 

Denials 

 Based on Reasons Other than Exemptions” from Section 

V, B (1) Chart 

Component Description of “Other” 

Reasons for Denials from 

Chart B (1) & Number of 

Times Those Reasons Were 

Relied upon 

TOTAL 

Federal Energy 

Regulatory 

Commission 

(FERC)

 N/A 0 

B.(3) Disposition of FOIA Requests – Number of Times 

Exemptions Applied 

Ex. 

1 

Ex. 

2

Ex. 

3 

Ex.

 4 

Ex.

5

Ex.

6 

Ex. 

7(A)

Ex.

(B)

Ex. 

7(C)

Ex. 

7(D)

Ex. 

7(E)

Ex. 

7(F)

Ex. 

8

Ex. 

9 

Federal 

Energy 

Regulatory 

Commission 

(FERC)

N/A 3 4 17 19 18 8 6 2 N/A 5 5 N/A N/A

 
 10 

VI. ADMINISTRATIVE APPEALS OF INITIAL 

DETERMINATIONS OF FOIA REQUESTS 

A. Received, Processed and Pending Administrative Appeals 

 Column 1 Column 2 Column 3 Column 4 

Number of 

Appeals Pending 

as of Start of 

Fiscal Year 

Number of 

Appeals Received 

in Fiscal Year 

Number of 

Appeals 

Processed in 

Fiscal Year 

Number of 

Appeals 

Pending as of 

End of Fiscal 

Year 

 1 14 13 2 

B. Disposition of Administrative Appeals – All Processed 

Appeals 

Number 

Affirmed 

on Appeal

Number Partially 

Affirmed & Partially 

Reversed/Remanded 

on Appeal

Number Completely 

Reversed/Remanded 

on Appeal

Number 

of 

Appeals 

Closed 

for Other 

Reasons

TOTAL

 9 1 1 2 13 

 

C. (1) Reasons for Denial on Appeal – Number of Times 

 Exemptions Applied 

Ex. 

1 

Ex. 

2 

Ex. 

3 

Ex. 

4 

Ex. 

5 

Ex. 

6 

Ex. 

7(A) 

Ex. 

7(B) 

Ex. 

7(C) 

Ex. 

7(D) 

Ex. 

7(E) 

Ex. 

7(F) 

Ex. 

8 

Ex. 

 9 

N/A N/A N/A N/A 5 1 2 1 1 N/A N/A N/A N/A N/A
 11 

C. (2) Reasons for Denial on Appeal – Reasons Other than Exemptions 

1. Number of administrative appeals resulting in denial for reasons other than exem

No Records 

Records 

Referred 

at Initial 

Request 

Level 

Request Withdrawn 

FeeRelated Reason 

Records 

not 

Reasonably 

Described 

Improper 

Request 

for Other 

Reasons 

Not Agency Record 

Duplicate 

Request 

or 

Appeal 

Request 

in 

Litigation 

Appeal 

Based 

Solely oDenial o

Reques

for 

Expedite

Processin

N/A N/A N/A N/A N/A N/A N/A N/A N/A 2 

C. (3) Reasons for Denial on Appeal – “Other” Reasons from Section VI, C (2) Chart 

Description of “Other” Reasons for Denial on Appeal from Chart C (2) & Number of Times Those Reasons Were Relied upon 

TOTAL 

N/A

Description # Description # 

 N/A 
 12 

C. (4) Response Time for Administrative Appeals

C. (5) Ten Oldest Pending Administrative Appeals 

 10th Oldest  Appeal 9th 8th 7th 6th 5th 4th 3rd Date of Receipt of Ten Oldest Appeals 

N/A N/A N/A N/A N/A N/A N/A N/A 

Number of Days Pending 

N/A N/A N/A N/A N/A N/A N/A N/A 

Median Number

of Days

Average Number

of Days

Lowest Number

of Days

Highest Num

of Days

 29 36 19 94 
 13 

VII. FOIA REQUESTS: RESPONSE TIME FOR PROCESSED AND PENDING REQUESTS 

A. Processed Requests – Response Time for All Processed Perfected Requests 

1. Median, average and range in number of days to process all perfected requests. 

 TRACK 1 TRACK 2 T

Median Number of Days 

Average Number of Days 

Lowest Number of Days 

Highest Number of Days 

Median Number of Days 

Average Number of Days 

Lowest Number of Days 

Highest Number of Days 

Median Number of Days 

AvNuof 

AGENCY OVERALL Federal Energy Regulatory Commission (FERC)

20 21 1 59 26 24 2 62 30 39 
 14 

EXPEDITED

Median 

Number 

of Days 

Average 

Number 

of Days 

Lowest 

Number 

of Days 

Highest 

Number 

of Days 

 N/A N/A N/A N/A 

AGENCY OVERALL 

Federal Energy Regulatory Commission (FERC) 

0 0 0 0 
 15 

B. Processed Requests – Response Time for Perfected Requests in Which Information Was G

1. The median, average and range in number of days to process all perfected request

information was granted. (“Granted” refers to full grants and partial grants.) 

TRACK 1 TRACK 2 TRACK 3Median Number of Days 

Average Number of Days 

Lowest Number of Days 

Highest Number of Days 

Median Number of Days 

Average Number of Days 

Lowest Number of Days 

Highest Number of Days 

Median Number of Days 

AvNuof 

AGENCY OVERALL Federal Energy Regulatory Commission (FERC)

24 25 8 59 29 30 18 62 30 42 
 16 

EXPEDITED

Median Number of Days 

Average Number of Days 

Lowest Number of Days 

Highest Number of Days 

 N/A N/A N/A N/A AGENCY OVERALL Federal Energy Regulatory Commission (FERC) 

0 0 0 0 
 17 

 C. Processed Requests – Response Time in Day Increments 

1. Provide the number of perfected requests processed in each of the thirteen design

increments (i.e., report the number of requests processed within 20 days in the firthe number processed within 21-40 days in the second column, etc.) 

TRACK 1 

1-20 Days 

21-40 Days 41-60 

Days 

61-80 Days 

81-100 Days 

101-120 Days 

121-140 Days 

141-160 Days 

161-180 Days 

181-200 Days 

201-300 Days 

AGENCY OVERALL Federal Energy Regulatory Commission (FERC)

33 24 1 0 0 0 0 0 0 0 0 
 18 

TRACK 2 

1-20 Days 

21-40 Days 41-60 

Days 

61-80 Days 

81-100 Days 

101-120 Days 

121-140 Days 

141-160 Days 

161-180 Days 

181-200 Days 

201-300 Days 

AGENCY OVERALL Federal Energy Regulatory Commission (FERC)

16 22 3 0 0 0 0 0 0 0 0 

TRACK 3 

1-20 Days 

21-40 Days 41-60 

Days 

61-80 Days 

81-100 Days 

101-120 Days 

121-140 Days 

141-160 Days 

161-180 Days 

181-200 Days 

201-300 Days 

AGENCY OVERALL Federal Energy Regulatory Commission (FERC)

3 7 0 1 1 1 0 0 0 0 
 19 

REQUESTS GRANTED EXPEDITED PROCESSING 1

1-20 Days 

21-40 Days 

41-60 Days 

61-80 Days 

81-100 Days 

101-120 Days 

121-140 Days 

141-160 Days 

161-180 Days 

181-200 Days 

201-300 Days 

AGENCY OVERALL Federal Energy Regulatory Commission (FERC)

0 0 0 0 0 0 0 0 0 0 0 

1 No requests for expedited processing were granted. However, some requests seeking expedited treatment were co

day statutory response timeline, therefore, making the request a moot issue. 
 20 

D. Pending Requests – All Pending Perfected Requests

1. Number of perfected requests pending as of the end of the fiscal year, 

and the median and average number of days those requests had been 

pending. 

TRACK 1 TRACK 2 TRACK 3

Number 

Pending 

Median 

Number 

of Days 

Average 

Number 

of Days 

Number 

Pending 

Median 

Number 

of Days 

Average 

Number 

of Days 

Number 

Pending 

Median 

Number 

of Days 

Average 

Number 

of Days 

AGENCY 

OVERALL 

Federal 

Energy 

Regulatory 

Commission 

(FERC)

13 29 46.15 6 37 34 8 116 202 

EXPEDITED

Median 

Number 

of Days 

Average 

Number 

of Days 

Lowest 

Number 

of Days 

Highest 

Number 

of Days 

 N/A N/A N/A N/A 

AGENCY OVERALL 

Federal Energy Regulatory Commission 

(FERC) 

0 0 0 0 
 21 

E. Pending Requests – Ten Oldest Pending Perfected Requests

1. Dates of receipt of the ten oldest perfected requests pending as of the end of the fisc

number of days those requests had been pending. 

2 FOIA number FY04-191 was on hold for 252 days in FY 2006 at the behest of the requester. 

Date of Receipt of Ten Oldest Pending 

10th Oldest 

Request and 

Number of 

Day Pending 

9th 8th 7th 6th 5th 4th 3rd 

Agency Overall Federal Energy Regulatory Commission (FERC)

 7/22/09 

49 days 

7/8/09  55 days 6/17/09 

52 days 

6/16/09 

52 days 

4/23/09 112 days 

3/17/09 121 days 

3/17/09 121 days 

11/24/08 212 days 
 22 

VIII. REQUESTS FOR EXPEDITED PROCESSING AND REQUESTS FOR 

 FEE WAIVER

A. Requests for Expedited Processing 

Number 

Granted

Number 

Denied

Median 

Number of 

Days to 

Adjudicate

Average 

Number of 

Days to 

Adjudicate

Number 

 Adjudicated 

 Within Ten 

Calendar Days

AGENCY 

OVERALL 

Federal Energy 

Regulatory 

Commission 

(FERC)

0 10 9 8 10 

. 
 23 

B. Requests for Fee Waiver 

IX. FOIA PERSONNEL AND COSTS

Number 

Granted

Number 

Denied

Median 

Number of 

Days to 

Adjudicate

Average 

Number of 

Days to 

Adjudicate

AGENCY 

OVERALL 

Federal Energy 

Regulatory 

Commission 

(FERC)

2 7 10 10 

PERSONNEL COSTS

Number of 

“Full-Time 

FOIA 

Employees” 

Number of 

“Equivalent 

Full-Time 

FOIA 

Employees” 

Total Number of 

“Full-Time 

FOIA Staff” 

Processing 

Costs 

LitigationRelated Costs 

Total 

Costs

AGENCY 

OVERALL 

Federal 

Energy 

Regulatory 

Commission 

(FERC)

1 3.56 4.56 $ 692,848 N/A $ 692,848
 24 

X. FEES COLLECTED FOR PROCESSING REQUESTS 

Total Amount of Fees 

Collected 

Percentage of Total 

Costs 

AGENCY 

OVERALL 

Federal Energy Regulatory 

Commission 

(FERC)

 

$839.19 1.5% 

XI. FOIA REGULATIONS 

Electronic links to FERC’s FOIA regulations and fee schedule: 

• FOIA REGULATION: 18 C.F.R. § 388.108, can be accessed through GPO 

http://www.access.gpo.gov/nara/cfr/index.html

• FEE SCHEDULE: http://www.ferc.gov/legal/ceii-foia/foia/guide/fees.asp
 25 

XII. BACKLOGS, CONSULTATIONS, AND COMPARISONS 

A. Backlogs of FOIA Requests and Administrative Appeals 

Number of Backlogged 

Requests as of End of 

Fiscal Year 

Number of Backlogged 

Appeals as of End of 

Fiscal Year 

AGENCY 

OVERALL 

Federal Energy Regulatory 

Commission 

(FERC)

0 0 
 26 

B. Consultations on FOIA Requests – Received, Processed, and Pending Consultations 

 Column 1 Column 2 Column 3 

Number of Consultations 

Received from Other 

Agencies that Were 

Pending at Your Agency 

as of Start of the Fiscal 

Year

Number of 

Consultations 

Received from 

Other Agencies 

During the Fiscal 

Year

Number of Consultations 

Received from Other 

Agencies that Were 

Processed by Your Agency 

During the Fiscal Year

Co

fr

th

Y

En

AGENCY OVERALL Federal Energy Regulatory Commission (FERC)

0 1 1 
 27 

C. Consultations on FOIA Requests – Ten Oldest Consultations Received from Other Ag

at Your Agency 

10th Oldest 

Consultation 

and Number 

of Days 

Pending 

9th 8th 7th 6th 5th 4th 3rd 

Date Received 0 0 0 0 0 0 0 0 0 

Number of 

Days Pending 0 0 0 0 0 0 0 0 0 
 28 

D. Comparison of Numbers of Requests from Previous and Current Annual 

Report – Requests Received, Processed, and Backlogged 

 

 Column 1 Column 2 Column 3 Column 4 

NUMBER OF REQUESTS 

RECEIVED

NUMBER OF REQUESTS 

PROCESSED

Number 

Received 

During Fiscal 

Year from Last 

Year’s Annual 

Report 

Number 

Received 

During Fiscal 

Year from 

Current 

Annual Report 

Number 

Processed 

During Fiscal 

Year from Last 

Year’s Annual 

Report 

Number Processed 

During Fiscal Year 

from Current 

Annual Report 

Agency 

Overall 

Federal Energy 

Regulatory 

Commission 

(FERC)

111 113 96 112 

Column 1 Column 2 

Number of Backlogged 

Requests as of End of 

the Fiscal Year from 

Previous Annual Report 

Number of Backlogged Requests 

as of End of the Fiscal Year from 

Current Annual Report 

AGENCY 

OVERALL 

Federal Energy Regulatory 

Commission 

(FERC)

*0 0 

*CORRECTION: FY08 Annual report incorrectly reflected one backlogged request. 
 29 

E. Comparison of Numbers of Administrative Appeals from Previous and Current 

Annual Report – Appeals Received, Processed, and Backlogged 

 

Column 1 Column 2 Column 3 Column 4

NUMBER OF APPEALS RECEIVED NUMBER OF APPEALS PROCESSED

Number Received 

During Fiscal Year 

from Last Year’s 

Annual Report

Number Received 

During Fiscal Year 

from Current 

Annual Report 

Number Processed 

During Fiscal Year 

from Last Year’s 

Annual Report 

Number Processed 

During Fiscal Year 

from Current 

Annual Report 

Agency 

Overall 

Federal Energy 

Regulatory 

Commission 

(FERC)

8 14 7 13 

 

Number of Backlogged Appeals 

 as of End of the Fiscal Year from 

Previous Annual Report 

Number of Backlogged Appeals as 

 of End of the Fiscal Year from 

Current Annual Report 

AGENCY 

OVERALL 

Federal Energy 

Regulatory 

Commission 

(FERC)

0 0 

 
 30 

F. Discussion of Other FOIA Activities (Optional) 

1. Provide here any further information about the agency’s efforts to 

improve FOIA administration. 

The Commission has completed negotiations for new FOIA software. This new 

technology will enable FERC to manage requests in the most efficient manner possible. This 

software will streamline the FOIA process by using templates for routine correspondence, 

permit requesters to view the status of request on our webpage and easily identify similar 

FOIA requests. 

All FERC staff employees attended mandatory FOIA training. This training advised 

staff of the new open government initiative and emphasized the importance of conducting an 

adequate search.