​NRECA, along with American Municipal Power (AMP) and the American Public Power Association (APPA), requested rehearing on the Federal Energy Regulatory Commission's (FERC) final electric storage rule issued in Order No. 841. In the request for rehearing, NRECA, AMP, and APPA ask FERC to:

  • State that Order No. 841 only affects RTO/ISO wholesale market rules and does not alter state and local authority over distribution-level and behind-the-meter resources;

  • Adopt a regulation allowing the “Relevant Electric Retail Regulatory Authority” to decide whether distribution-level and behind-the-meter storage resources may participate in RTO/ISO wholesale markets; and

  • RTO and ISO tariff revisions for market participation by distribution-level and behind-the-meter storage should not take effect until any tariff revisions required by FERC’s pending proposals for distributed energy resource (DER) aggregations take effect.