​​​The American Public Power Association (APPA) and the National Rural Electric Cooperative Association (NRECA) submit these comments on the notice of proposed rulemaking issued in this docket. See 80 Fed. Reg. 80,302 (Dec. 24, 2015) (NOPR). The Commission proposes to clarify—and reduce—the ownership information required to be filed by a public utility seeking to obtain or retain authority to make wholesale sales of electric energy, capacity, and ancillary services at market-based rates. FULL FILING