​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