​NRECA, along with the American Public Power Association and American Antitrust Institute, filed comments with the Federal Energy Regulatory Commission (FERC) opposing a proposed rulemaking to reduce the agency's screening of sellers' ability to exercise horizontal market power in wholesale electricity markets. Our comments argue that FERC's prior screening of sellers' ability to exercise horizontal market power has been central to FERC's market-based rate scheme, has been relied on by courts in upholding that scheme, and provides FERC critical information on market power and market structure. FULL FILING