Educational primer · not legal advice
FERC Standards of Conduct (Part 358)
A readable introduction to how transmission providers keep transmission work and marketing work from colliding—so non-affiliated customers are not left guessing. Use it alongside our SOC flashcard deck, Standards of Conduct: Utility Ops trainer, and the Field Manual (shift reference).
This page is for learning and orientation only. It does not describe your utility’s compliance program, filing obligations, or how the Commission would view a specific fact pattern. For binding requirements, rely on your counsel and the official codification linked at the bottom.
What the Standards of Conduct are trying to fix
When a company both moves power for others and sells power (or related products), customers worry about a simple failure mode: the transmission side tips the marketing side—through staffing overlap, informal chatter, or information that never quite makes it to the market at large. Part 358 is the Commission’s framework for keeping transmission decisions and marketing incentives from blending in ways that disadvantage independent competitors. Order 717 (2008) is the landmark restructuring that set the current architecture; the operational ideas are often summarized as three pillars.
Three pillars (with desk-style examples)
1. Independent functioning
Day-to-day transmission roles (planning, operations, evaluating service requests) are meant to run without marketing employees leaning on the people who grant or schedule service.
Example: A marketer asks a transmission planner to “just take a quick look” at whether an affiliate’s request will clear before lunch. Even if the answer sounds harmless, the habit collapses the firewall—decisions should follow posted processes, not side conversations.
2. No conduit
Operational detail that is not fairly available to the broader market should not flow to marketing through back channels—email mis-fires, shared chat rooms, consultants, or “I heard on the floor” updates.
Example: A control-room note about a likely curtailment circulates to traders before the same picture is visible to all transmission customers through the channels your tariff expects. That timing gap is the risk the “no conduit” idea targets.
3. Transparency / equal access
When non-public transmission information must be shared with marketing, the regime expects a path that gives everyone else the same shot at the same facts on a similar timeline—often through OASIS postings, tariff notices, or other simultaneous disclosure paths your compliance team defines.
Example: HR posts an internal transfer moving someone between transmission and marketing functions. Customers who watch OASIS and tariff pages should see that class of event called out in the same window as your internal org chart—not learn about it later through rumor.
Study the terms (glossary)
Each link opens a dedicated term page with the same definitions used in our flashcard deck.
- Part 358 applicability (electric)
- Independent functioning principle
- No conduit principle
- Equal access to information
- Transmission function employee
- Marketing function employee
- Transmission function information
- Order 717 — Standards of Conduct (2008)
Official codification
Primary source (external): 18 CFR Part 358 on eCFR.