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
