NRECA and the American Public Power Association (APPA) filed comments with the Federal Energy Regulatory Commission (FERC) on uplift cost allocation and transparency in the markets operated by RTOs and ISOs. NRECA and APPA question the need for FERC's proposed requirements for real-time uplift allocation. NRECA and APPA do not oppose the transparency provisions of FERC's notice of proposed rulemaking, but suggest FERC seek input from the RTOs and ISOs on the feasibility and timing of their ability to comply with these provisions. FULL FILING​