The American Public Power Association ("APPA") and the National Rural
Electric Cooperative Association ("NRECA") submit these comments on the Notice of
Proposed Rulemaking ("NOPR") issued in the above-referenced proceeding on December
15, 2016.1
APPA and NRECA urge the Commission to recognize that Regional
Transmission Organizations (“RTOs”) and Independent System Operators (“ISOs”),
collectively referred to as “RTOs,” have been developing and implementing revised rules
to address the pricing of fast-start resources in the energy markets. In contrast to the
findings of the NOPR, these RTO efforts do not indicate a need for a standardization of
rules across all RTOs. 
FULL FILING
