On January 21, 2020, NRECA submitted short comments in the FERC proceedings ​regarding Tri-State G&T's rate filings. In late December Tri-State G&T filed its wholesale contracts, wholesale tariffs, transmission tariff, and assorted other rate schedules with FERC. This is Tri-State's second try, after FERC rejected as deficient a similar set of filings by Tri-State last summer. 

The comments do not take a position on Tri-State's rates but explain the importance of the wholesale power contracts to a G&T's finances. The comments urge FERC not to use this case to impose broad rate-filing requirements on all FERC-regulated G&Ts and to address only Tri-State's rates and not its governance or corporate structure.  These comments are substantially the same as comments we filed previously.