​NRECA and the American Public Power Association filed comments with the U.S. Federal Energy Regulatory Commission (FERC) in the agency's proposed rulemaking on distributed energy resources (DER) aggregations in Regional Transmission Organization (RTO) and Independent System Operator (ISO) wholesale markets. Our comments oppose a proposal from the Arkansas Public Service Commission and support a proposal from the Mississippi Public Service Commission. We recommend that FERC's final rule provide that the relevant electric retail regulatory authority (RERRA) has the authority to determine if a DER should be permitted to participate in a DER aggregation in the RTO and ISO wholesale markets.FULL FILING