​NRECA and the American Public Power Association (APPA) filed comments with the Federal Energy Regulatory Commission (FERC) on its Notice of Proposed Rulemaking (NOPR) on fast-start pricing in markets operated by RTOs and ISOs. NRECA and APPA urge FERC to recognize that RTOs and ISOs have been developing and implementing revised rules to address the pricing of fast-start resources in the energy markets and that standardization of rules across all RTOs is not warranted.FULL FILING