​​​NRECA, the American Public Power Association (APPA), and American Municipal Power, Inc. (AMP) submitted comments to the Federal Energy Regulatory Commission (FERC) on the Notice of Proposed Rulemaking (NOPR) issued on January 21, 2016. The NOPR proposes a generic change to the energy offer cap for all regional transmission organizations (RTOs) and independent system operators (ISOs), to cap each resource's incremental energy offer at the higher of $1,000/MWh or that resource's verified cost-based incremental energy offer. The NOPR further proposes that such verified, cost-based incremental energy offers above $1,000/MWh would be used for purposes of calculating Locational Marginal Prices (LMPs). In addition to a generic offer cap for all RTOs and ISOs, the NOPR seeks comments on related items including (1) whether to impose a "hard" cap as part of the Final Rule in this proceeding; (2) whether the Market Monitoring Units (MMU) and/or ISO/RTO can timely verify costs prior to the day-ahead or real-time market clearing process, and whether additional information or authority is needed; (3) application of the offer cap proposal to imports; (4) treatment of virtual transactions; and (5) the impact of the proposal on seams issues. FULL FILING