​On January 21, 2020, NRECA filed a request for rehearing of FERC's order on the PJM Expanded Minimum Offer Price Rule. We sought clarification and requested rehearing (as did several co-ops in PJM) because FERC’s December 19 Order takes aim not only at state energy policies but also at actions taken by a co-op, public power utility, or a vertically integrated IOU to “self-supply” its capacity requirements outside the PJM capacity market, e.g., by owning or bilaterally contracting for capacity. Our focus is on challenging FERC’s misguided notion that the traditional co-op business model somehow amounts to a state subsidy of co-op resources that is inconsistent with wholesale competition. Our member East Kentucky Power Cooperative opted to join our pleading. Buckeye, Allegheny, ODEC, and SMECO have filed their own shorter request for rehearing.