​​​The National Rural Electric Cooperative Association (“NRECA”) appreciates the opportunity to submit comments addressing the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) letter on April 11, 2016, soliciting comments on the applicability of Regional Transmission Organization (“RTO”) and Independent System Operator (“ISO”) market rules to electric storage resources. The Commission’s request reflects a strong interest in the use of electric storage resources and the role and treatment of those resources within organized wholesale markets. FULL FILING