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

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