DRAFT 

2020 Chief FOIA Officer Report

FEDERAL ENERGY REGULATORY COMMISSION (FERC)

Leonard Tao

Chief Officer

Director of Office of External Affairs

Section 1: Steps Taken to Apply the Presumption of Openness

The guiding principle underlying DOJ’s FOIA Guidelines is the presumption of openness.

Please answer the following questions in order to describe the steps your agency has taken to ensure that 

the presumption of openness is being applied to all decisions involving the FOIA. You may also include 

any additional information that illustrates how your agency is working to apply the presumption of 

openness.

A. FOIA Leadership

1. The FOIA requires each agency to designate a Chief FOIA Officer who is a senior official at the 

Assistant Secretary or equivalent level. Is your agency’s Chief FOIA Officer at this level? 

Yes

2. Please provide the name and title of your agency’s Chief FOIA Officer.

Leonard Tao

Chief Officer

Director of Office of External Affairs

B. FOIA Training

3. Did your FOIA professionals or the personnel at your agency who have FOIA responsibilities attend any 

substantive FOIA training or conference during the reporting period such as that provided by the 

Department of Justice?

Yes

4. If yes, please provide a brief description of the type of training attended or conducted and the topics 

covered.

FOIA for Attorneys by Department of Justice. 

During FY2019 several FOIA professionals attended a two day training 

session at the Department of Justice that provided a detailed overview of 
FOIA procedural requirements, exemptions, proactive disclosure 

requirements and all major aspects of FOIA.

5. Provide an estimate of the percentage of your FOIA professionals and staff with FOIA responsibilities 

who attended substantive FOIA training during this reporting period.

FERC has one full time FOIA professional and 17 individuals who routinely 

work on FOIA matters along with other responsibilities. Internal training 

was provided for new employees and refresher training was provided to 

staff, as necessary. Special training sessions were also conducted for 

specific program offices to address issues and offer guidance on conducting 

effective electronic searches for responsive material. Approximately, 80% 

of the FOIA professionals attended or conducted FOIA training during 

FY2019.

6. OIP has directed agencies to “take steps to ensure that all of their FOIA professionals attend 

substantive FOIA training at least once throughout the year.” If your response to the previous question is 

that less than 80% of your FOIA professionals attended training, please explain your agency’s plan to 

ensure that all FOIA professionals receive or attend substantive FOIA training during the next reporting 

year.

N/A

C. Outreach

7. Did your FOIA professionals engage in any outreach or dialogue with the requester community or open 

government groups regarding your administration of the FOIA? Please describe any such outreach or 

dialogue, and, if applicable, any specific examples of how this dialogue has led to improvements in your 

agency’s FOIA administration.

No

D. Other Initiatives

8. Describe any efforts your agency has undertaken to inform non-FOIA professionals of their obligations 

under the FOIA.

Training for new employees and refresher training advised individuals of 

their roles and obligations under FOIA. This includes an employee’s 

obligation to provide responsive material, along with an opinion regarding 

the impact of the possible release of such material. These elements are 

critical to have a successful FOIA program. Performance standards for 

current FOIA professionals include pertinent language that clearly define 

the duties and responsibilities of such individuals.
9. Optional -- If there are any other initiatives undertaken by your agency to ensure that the presumption 

of openness is being applied, please describe them here.

During this period FERC created “The FERC Insight” newsletter that 

provides another method in which information can be proactively shared 

with members of the public. This monthly newsletter includes a 

compilation that highlights Commission meetings, speeches, upcoming 

conferences, news releases and other special announcements relating to 

FERC matters. It also includes direct links to Commission orders, notices, 

reports, podcasts, and other pertinent material. This newsletter is available 

on our webpage: http://www.ferc.gov/media/insight.asp

• FERC insight | Volume 1 | May 2019

Section II: Steps Taken to Ensure that Your Agency Has an Effective 

System in Place for Responding to Requests

DOJ’s FOIA Guidelines emphasize that “[a]pplication of the proper disclosure standard is only one part of 

ensuring transparency. Open government requires not just a presumption of disclosure, but also an 

effective system for responding to FOIA requests.” It is essential that agencies effectively manage their 

FOIA program.

Please answer the following questions to describe the steps your agency has taken to ensure that the 

management of your FOIA program is effective and efficient. You should also include any additional 

information that describes your agency's efforts in this area.

1. For Fiscal Year 2019, what was the average number of days your agency reported for adjudicating 

requests for expedited processing? Please see Section VIII.A. of your agency's Fiscal Year 2019 

Annual FOIA Report.

8 Days

2. If your agency's average number of days to adjudicate requests for expedited processing was above ten 

calendar days, please describe the steps your agency will take to ensure that requests for expedited 

processing are adjudicated within ten calendar days or less.

N/A

3. During the reporting period, did your agency conduct a self-assessment of its FOIA program? If so, 

please describe the methods used, such as reviewing Annual Report data, using active workflows and 

track management, reviewing and updating processing procedures, etc.

No formal assessment was conducted during this period. However, FERC 

continuously strives to identify methods to improve the FOIA program on a 

regular basis. This includes routinely reviewing workflow activities.
• Note: In September 2017, OIP released a FOIA Self-Assessment

Toolkit as a resource for agencies conducting a self-assessment of 

their FOIA program. The Toolkit is available on OIP’s website for all 

agencies to use.

4. The FOIA Improvement Act of 2016 requires additional notification to requesters about the services 

provided by the agency’s FOIA Public Liaison. Please provide an estimate of the number of times 

requesters sought assistance from your agency’s FOIA Public Liaison during FY 2019 (please provide a 

total number or an estimate of the number).

100 (Estimate) 

5. Optional -- Please describe:

N/A

• Best practices used to ensure that your FOIA system operates 

efficiently and effectively

• Any challenges your agency faces in this area

Section III: Steps Taken to Increase Proactive Disclosures

The Department of Justice has long focused on the need for agencies to work proactively to post 

information online without waiting for individual requests to be received.

Please answer the following questions to describe the steps your agency has taken to increase the amount 

of material that is available on your agency websites. In addition to the questions below, you should also 

describe any additional steps taken by your agency to make and improve proactive disclosures of 

information.

1. Provide examples of any material that your agency has proactively disclosed during the past reporting 

year, including records that have been requested and released three or more times in accordance with 5 

U.S.C. § 552(a)(2)(D). Please include links to these materials as well.

The FERC elibrary database (http://www.ferc.gov/docs-filing/elibrary.asp) 

includes an index of documents that have been filed at FERC or issued by 

FERC. An index of these documents is available, along with the ability to 

view most public material online. The following material reflects some of 

the documents that have been posted to the FERC webpage 

(http://www.ferc.gov)

March 29, 2019 

FERC Staff Report Identifies Lessons Learned from CIP Reliability Audits News 

Release | Report

March 21, 2019 

Item: E-1: FERC Opens Inquiry on Improvements to Electric Transmission 

Incentives Policy News Release | Presentation | NOI
April 18, 2019 

Item H-1: FERC Finalizes Expedited Hydro Licensing Process News Release | Presentation | 

Order

April 15, 2019 - Dissenting Statement of Commissioner Richard Glick regarding PJM Interconnection, 

L.L.C., tariff Read More

April 18, 2019 - Commissioner Bernard L. McNamee Statement on FERC’s Approval of the Driftwood and 

Port Arthur LNG Export Facilities Read More

April 18, 2019 2018 State of the Markets Report | Presentation

May 16, 

2019

2019 Summer Energy Market and Reliability Assessment Report | Staff 

Presentation

June 12, 2019

FERC Chairman Neil Chatterjee and Commissioners Cheryl A. LaFleur, Richard Glick, and 

Bernard L. McNamee testify before the House Committee on Energy and Commerce, 

Subcommittee on Energy

Subject: Hearing on Oversight of FERC: Ensuring Its Actions Benefit Consumers and the 

Environment 

» Chairman Chatterjee Testimony

» Commissioners’ Testimony: LaFleur | Glick | McNamee

» Event Details

June 20, 2019

Item E-2: FERC Strengthens Cyber Security Standards for Bulk Electric System 

News Release | Staff Presentation | Order

June 20, 2019

Item M-1: FERC Revisions to the Filing Process for Commission Forms News Release | Order 

No. 859

July 10, 2019 - Chairman Chatterjee Talks Electricity Storage, recorded July 8, 2019. Transcript | MP3 

| YouTube | iTunes

July 12, 2019

OER Director J. Andrew Dodge, Sr., P.E, testifies before the House Committee on Energy and 

Commerce, Subcommittee on Energy on Keeping The Lights

Subject: Addressing Cyber Threats To The Grid. 

» Testimony

» Event Details

July 18, 2019

FERC and NERC Release Report on January 2018 Extreme Cold Weather Event News Release | 

Report
August 2, 2019 - Statement on ONEOK Elk Creek Pipeline, L.L.C. Read More

Executive Director Anton Porter testifies before The Senate Committee on Energy and Natural 

Resources Subcommittee on Energy, on S. 607, Timely Review of Infrastructure Act. Transcript

September 11, 2019 - Executive Director Anton Porter testifies before The Senate Committee on 

Energy and Natural Resources Subcommittee on Energy, on S. 607, Timely Review of 

Infrastructure Act. Transcript

September 11, 2019 - Energy Cybersecurity, recorded September 6, 2019

FERC cyber experts Andrew Dodge, director of the Office of Electric Reliability, and Joseph 

McClelland, director of the Office of Energy Infrastructure Security, discuss what the 

Commission is doing to help improve the security of the nation’s energy facilities. 

Transcript

Music: “Get Me Started” by juqboxmusic, 

courtesy Getty Images.

MP3

YouTube

iTunes

September 19, 2019

Item E-1: FERC Proposes to Modernize PURPA Regulations News Release | Presentation | 

NOPR | Fact Sheet | Commissioner Statements: Glick | McNamee

October 4, 2019 - Joint Statement of Chairman Neil Chatterjee and Commissioner Bernard L. McNamee 

on Southwest Power Pool, Inc., To Comply with the Fair Rates Act of 2018 Read More

October 4, 2019

FERC Staff Report Identifies Lessons Learned from CIP Reliability Audits News Release | 

Report

October 16, 2019 - McNamee. Markets. Metallica? Recorded October 9, 2019

Commissioner Bernard McNamee joins Open Access for a review of his first 10 months at FERC and 

shares his views on natural gas markets and energy regulation, and reveals he’s a huge fan of heavy 

metal in general and Metallica in particular. Transcript

Music: “Get Me Started” by juqboxmusic, 

courtesy Getty Images.

MP3

YouTube

iTunes
October 16, 2019

FERC's Open Access Podcast: McNamee. Markets. Metallica? Podcast

October 17, 2019

FERC Issues Guidance for Hydro Development News Release | Notice | Guide

October 17, 

2019

2019-2020 Winter Energy Market Assessment Presentation (As Presented) | 

Presentation (Full Version) 

November 5, 2019

Today at 10 a.m. ET, Mr. James P. Danly will testify before the Energy & Natural Resources 

Committee to be a Member of the Federal Energy Regulatory Commission Event Details | 

Testimony

November 15, 2019

FERC Staff Issues Final Environmental Impact Statement for the Jordan Cove Energy Project 

(CP17-494-000 and CP17-495-000) Read More

November 20, 2019 - What does OEPI do? Recorded November 14, 2019

Learn all about the important policy work in the FERC Office of Energy Policy and Innovation from Office 

Director Jignasa Gadani. Transcript

Music: “Get Me Started” by juqboxmusic, 

courtesy Getty Images.

MP3

YouTube

iTunes

November 21, 2019

Item E-11: FERC Adopts New Base ROE Methodology, Addresses Complaints 

Against MISO News Release | Presentation | Commissioner Statements: Glick | 

Order

November 21, 2019

Item A-4: FERC Staff Identifies Key Cybersecurity Program Priorities News 

Release | Staff Presentation

November 21, 2019

Item A-3: FERC Office of Enforcement Issues 13th Annual Report on 

Enforcement Presentation | Enforcement Report 
 » Visit our Enforcement section 

November 21, 2019

Items C-1, C-2, C-3, C-6: FERC Approves Four LNG Export Projects News 

Release | Commissioner Statements: Glick | Decisions: C-1 , C-2 , C-3

and C-6

November 19, 2019

FERC Announces Alternative Dispute Resolution Process for Midwest Propane Situation News 

Release

November 26, 2019

FERC Staff to convene EQR Users Group Meeting on December 4, 2019 Notice | 

Supplemental Notice | Event Details

December 5, 2019

FERC Chairman Chatterjee met December 4 with the President of the Polish Energy Regulatory 

Office on energy market oversight, development of the LNG sector in the U.S. and Europe, and 

renewable energy. Read More

December 9, 2019 

FERC, Czech ERO Chairmen Meet to Strengthen Ties News Release

Memoranda of Understanding (MOU)

Between FERC and Topic Date

Ontario's Independent 

Electricity System 

Operator

To encourage the sharing of information about the 

markets they oversee and their regulatory 

experiences and practices.

December 

10, 2019

December 17, 2019 

We're No. 1! FERC Rated 'Best Place to Work' in Federal Employee Survey 

News Release

December 18, 2019

Letter from FERC to Federal Communication Commission regarding the unlicensed use of the 6 

GHz spectrum band. Letter

December 19, 2019 - Concurrence of Commissioner Bernard L. McNamee Regarding New York 

Independent System Operator, Inc. Read More

January 9, 2020 - Concurrence in Part, Dissent in Part Regarding Constellation Mystic Power, LLC Read 

More
2. Beyond posting new material, is your agency taking steps to make the posted information more useful 

to the public, especially to the community of individuals who regularly access your agency’s website?

Yes

3. If yes, please provide examples of such improvements.

Ongoing efforts to enhance search capabilities and other functions in online services. This includes 

creating additional podcasts and videos that provide tutorials, along with an overview of FERC functions 

and responsibilities. FERC also anticipates enhancing the infrastructure of the FERC elibrary database to 

make the system more user friendly as well as enhancing the users experience on our webpage. 

4. Optional -- Please describe:

N/A

• Best practices used to improve proactive disclosures

• Any challenges your agency faces in this area

Section IV: Steps Taken to Greater Utilize Technology

A key component of FOIA administration is using technology to make information more accessible. In 

addition to using the internet to make proactive disclosures, agencies should also be exploring ways to 

utilize technology in responding to requests.

Please answer the following questions to describe how your agency is utilizing technology to improve its 

FOIA administration and the public's access to information. You should also include any additional 

information that describes your agency's efforts in this area.

1. Is your agency leveraging or exploring any new technology to facilitate efficiency in its FOIA 

administration that you have not previously reported? If so, please describe the type of technology. 

During this period our IT experts are exploring additional types of software that may assist with 

conducting searches of emails that result in user friendly results to reduce the amount of time required to 

review and compare search results.

2. OIP issued guidance in 2017 encouraging agencies to regularly review their FOIA websites to ensure 

that they contain essential resources, and are informative and user-friendly. Has your agency reviewed its 

FOIA website(s) during the reporting period to ensure it addresses the elements noted in the guidance?

Yes.

3. Did your agency successfully post all four quarterly reports for Fiscal Year 2019?

Yes

4. If your agency did not successfully post all quarterly reports, with information appearing on FOIA.gov, 

please explain why and provide your agency’s plan for ensuring that such reporting is successful in Fiscal 

Year 2020.

Reports were posted on FERC webpage. However, they were not 

captured by the automated tool on foia.gov. FERC is working with OIP to 
identify technical issues and assure that all future reports are reflected on 

the FERC webpage and foia.gov.

5. The FOIA Improvement Act of 2016 requires all agencies to post the raw statistical data used to 

compile their Annual FOIA Reports. Please provide the link to this posting for your agency’s Fiscal Year 

2018 Annual FOIA Report and, if available, for your agency’s Fiscal Year 2019 Annual FOIA Report. 

2019 Annual Report Raw Data

6. Optional -- Please describe:

N/A

• Best practices used in greater utilizing technology

• Any challenges your agency faces in this area

Section V: Steps Taken to Improve Timeliness in Responding to 

Requests and Reducing Backlogs

The Department of Justice has emphasized the importance of improving timeliness in responding to 

requests. This section of your Chief FOIA Officer Report addresses both time limits and backlog 

reduction. Backlog reduction is measured both in terms of numbers of backlogged requests or appeals 

and by looking at whether agencies closed their ten oldest requests, appeals, and consultations.

For the figures required in this Section, please use the numbers contained in the specified sections of your 

agency’s 2019 Annual FOIA Report and, when applicable, your agency’s 2018 Annual FOIA Report.

A. Simple Track

Section VII.A of your agency’s Annual FOIA Report, entitled "FOIA Requests – Response Time for All 

Processed Requests," includes figures that show your agency's average response times for processed 

requests. For agencies utilizing a multi-track system to process requests, there is a category for "simple" 

requests, which are those requests that are placed in the agency’s fastest (non-expedited) track, based on 

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

1. Does your agency utilize a separate track for simple requests? 

Yes

Simple - These requests are identified as track 1.

Complex - These requests are identified as track 2 and track 3.

2. If your agency uses a separate track for simple requests, was the agency overall average number of days 

to process simple requests twenty working days or fewer in Fiscal Year 2019?

No 
3. Please provide the percentage of requests processed by your agency in Fiscal Year 2019 that were placed 

in your simple track.

34% 

4. If your agency does not track simple requests separately, was the average number of days to process all 

non-expedited requests twenty working days or fewer?

N/A

B. Backlogs

Section XII.A of your agency’s Annual FOIA Report, entitled "Backlogs of FOIA Requests and 

Administrative Appeals" shows the numbers of any backlogged requests or appeals from the fiscal year. 

You should refer to these numbers from your Annual FOIA Reports for both Fiscal Year 2018 and Fiscal 

Year 2019 when completing this section of your Chief FOIA Officer Report.

BACKLOGGED REQUESTS

5. If your agency had a backlog of requests at the close of Fiscal Year 2019, did that backlog decrease as 

compared with the backlog reported at the end of Fiscal Year 2018?

No

6. If not, did your agency process more requests during Fiscal Year 2019 than it did during Fiscal Year 

2018?

Yes

7. If your agency’s request backlog increased during Fiscal Year 2019, please explain why and describe the 

causes that contributed to your agency not being able to reduce its backlog. When doing so, please also 

indicate if any of the following were contributing factors:

There was an increase in the number of complex requests that were received in 2019. Many of these 

requests were processed on a rolling basis which required additional time. This included requests for key 

words within emails for extended date ranges.

• An increase in the number of incoming requests.

• A loss of staff.

• An increase in the complexity of the requests received. If possible, 

please provide examples or briefly describe the types of complex 

requests contributing to your backlog increase.

• Any other reasons – please briefly describe or provide examples when 

possible.

8. If you had a request backlog please report the percentage of requests that make up the backlog out of 

the total number of requests received by your agency in Fiscal Year 2019. If your agency has no request 

backlog, please answer with “N/A.”

34% 

BACKLOGGED APPEALS

9. If your agency had a backlog of appeals at the close of Fiscal Year 2019, did that backlog decrease as 

compared with the backlog reported at the end of Fiscal Year 2018?
The appeal backlog remained the same in FY19 as FY18 with 1 backlogged request.

APPEAL BACKLOG: 

10. If not, did your agency process more appeals during Fiscal Year 2019 than it did during Fiscal Year 

2018?

Yes

11. If your agency’s appeal backlog increased during Fiscal Year 2019, please explain why and describe 

the causes that contributed to your agency not being able to reduce its backlog. When doing so, please 

also indicate if any of the following were contributing factors:

N/A (The backlog was the same for FY2018 and FY2019. It did not increase).

• An increase in the number of incoming appeals.

• A loss of staff.

• An increase in the complexity of the requests received. If possible, 

please provide examples or briefly describe the types of complex 

requests contributing to your backlog increase.

• Any other reasons – please briefly describe or provide examples when 

possible.

12. If you had an appeal backlog please report the percentage of appeals that make up the backlog out of 

the total number of appeals received by your agency in Fiscal Year 2019. If your agency did not receive any 

appeals in Fiscal Year 2019 and/or has no appeal backlog, please answer with "N/A."

10%

C. Backlog Reduction Plans

13. In the 2019 guidelines for Chief FOIA Officer Reports, any agency with a backlog of over 1000 requests 

in Fiscal Year 2018 was asked to provide a plan for achieving backlog reduction in the year ahead. Did 

you agency implement a backlog reduction plan last year? If so, describe your agency’s efforts in 

implementing this plan and note if your agency was able to achieve backlog reduction in Fiscal Year 

2019?

N/A

14. If your agency had a backlog of more than 1,000 requests in Fiscal Year 2019, what is your agency’s 

plan to reduce this backlog during Fiscal Year 2020?

N/A

D. Status of Oldest Requests, Appeals, and Consultations

Section VII.E, entitled "Pending Requests – Ten Oldest Pending Requests," Section VI.C.(5), entitled "Ten 

Oldest Pending Administrative Appeals," and Section XII.C., entitled "Consultations on FOIA Requests –

Ten Oldest Consultations Received from Other Agencies and Pending at Your Agency," show the ten 

oldest pending requests, appeals, and consultations. You should refer to these numbers from your Annual 

FOIA Reports for both Fiscal Year 2018 and Fiscal Year 2019 when completing this section of your Chief 

FOIA Officer Report.
OLDEST REQUESTS

15. In Fiscal Year 2019, did your agency close the ten oldest requests that were reported pending in your 

Fiscal Year 2018 Annual FOIA Report?

No

16. If no, please provide the number of these requests your agency was able to close by the end of the fiscal 

year, as listed in Section VII.E of your Fiscal Year 2018 Annual FOIA Report. If you had fewer than ten 

total oldest requests to close, please indicate that.

6 

17. Beyond work on the ten oldest requests, please describe any steps your agency took to reduce the 

overall age of your pending requests.

FERC has designated a specific staff member to routinely monitor rolling, backlog and the ten oldest 

requests in an effort to finalize such matters during FY2020.

TEN OLDEST APPEALS

18. In Fiscal Year 2019, did your agency close the ten oldest appeals that were reported pending in your 

Fiscal Year 2018 Annual FOIA Report?

Yes

19. If no, please provide the number of these appeals your agency was able to close by the end of the fiscal 

year, as listed in Section VII.C.(5) of your Fiscal Year 2018 Annual FOIA Report. If you had fewer than 

ten total oldest appeals to close, please indicate that.

3 of 3 oldest appeals from FY28 were closed.

20. Beyond work on the ten oldest appeals, please describe any steps your agency took to reduce the 

overall age of your pending appeals.

N/A

TEN OLDEST CONSULTATIONS

21. In Fiscal Year 2019, did your agency close the ten oldest consultations that were reported pending in 

your Fiscal Year 2018 Annual FOIA Report?

Yes. 

22. If no, please provide the number of these consultations your agency was able to close by the end of the 

fiscal year, as listed in Section XII.C. of your Fiscal Year 2018 Annual FOIA Report. If you had fewer than 

ten total oldest consultations to close, please indicate that.

1 of 1 oldest consults from FY18 were closed.

E. Additional Information on Ten Oldest Requests, Appeals, and Consultations & Plans

23. Briefly explain any obstacles your agency faced in closing its ten oldest requests, appeals, and 

consultations from Fiscal Year 2019.
The ten oldest requests dealt with complex matters and/or large volumes of material and were processed 

on a rolling basis.

24. If your agency was unable to close any of its ten oldest requests because you were waiting to hear back 

from other agencies on consultations you sent, please provide the date the request was initially received 

by your agency, the date when your agency sent the consultation, and the date when you last contacted the 

agency where the consultation was pending.

N/A

25. If your agency did not close its ten oldest pending requests, appeals, or consultations, please provide a 

plan describing how your agency intends to close those “ten oldest” requests, appeals, and consultations 

during Fiscal Year 2020.

FERC has assigned a specific staff member to routinely monitor rolling, back log and ten oldest requests 

in an effort to finalize such matters during FY20.

F. Success Stories

Out of all the activities undertaken by your agency since March 2019 to increase transparency and 

improve FOIA administration, please briefly describe here at least one success story that you would like to 

highlight as emblematic of your agency’s efforts. The success story can come from any one of the five key 

areas. As noted above, OIP will highlight these agency success stories during Sunshine Week. To 

facilitate this process, all agencies should use bullets to describe their success story and limit their text to 

a half page. The success story is designed to be a quick summary of key achievements. A complete 

description of all your efforts will be contained in the body of your Chief FOIA Officer Report.

During this period FERC created “The FERC Insight” newsletter that 

provides another method in which information can be proactively shared 

with members of the public. This monthly newsletter includes a 

compilation that highlights Commission meetings, speeches, upcoming 

conferences, news releases and other special announcements relating to 

FERC matters. It also includes direct links to Commission orders, notices, 

reports, podcasts, and other pertinent material. This newsletter is available 

on our webpage: http://www.ferc.gov/media/insight.asp