​NRECA filed comments with the Federal Energy Regulatory Commission (FERC) on proposals concerning the participation of Distributed Energy Resource (DER) aggregations in Regional Transmission Organization (RTO) and Independent System Operator (ISO) markets. NRECA fully supports the development of DERs, but is concerned that FERC's proposal to require RTOs and ISOs to permit third party DER aggregators to participate directly in RTO and ISO markets could potentially pose a distinct set of challenges to cooperatives. NRECA urges FERC to modify its proposal to ensure that RTO and ISO market rules respect the decisions of the relevant electric retail regulatory authority (RERRA) - such as the state utility commission or co-op board - on whether to permit DER aggregations to participate directly in wholesale markets. The comments include an attached affidavit from a consulting engineer and five statements from distribution cooperatives highlighting specific issues of concern regarding FERC's proposal. FULL FILING