Excerpt:
The National Rural Electric Cooperative Association (“NRECA”) and the American
Public Power Association (“APPA”)(collectively referred to herein as the “NFP Electric
Associations”),1
respectfully submit these comments to the Commodity Futures Trading
Commission (the “Commission”) on the Proposed Amendment (the “Proposed Amendment”) to
the Final Order in Response to a Petition from Certain Independent System Operators and
Regional Transmission Organizations to Exempt Specified Transactions Authorized by a Tariff
or Protocol Approved by the Federal Energy Regulatory Commission or the Public Utility
Commission of Texas from Certain Provisions of the Commodity Exchange Act Pursuant to
Authority Provided in the Act (the “2013 RTO/ISO Exemption Order”).
2 We respectfully
request that the Commission not adopt the Proposed Amendment, or reopen and upset the
carefully-balanced and reasoned CEA 4(c)(6) “public interest” exemption in the 2013 RTO/ISO
Exemption Order by adding back Section 22 private rights of action for transactions entered into
under an RTO/ISO tariff.3 FULL FILING