​On September 26, 2019, NRECA submitted comments in the FERC proceedings where Tri-State has filed its wholesale power contracts, transmission tariffs, and other rate-related documents to become a FERC-jurisdictional "public utility." The comments urge FERC to decide the rate issues presently narrowly without creating de facto rules that our other FERC-jurisdictional G&Ts will have to follow, especially rules on G&T organization and governance.