API Comments to FERC re Docket No. RM16-5-000 (April 4, 2016)
Pursuant to the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) January 21, 2016 Notice of Proposed Rulemaking (“NOPR”) in the subject docket, the American Petroleum Institute (“API”) hereby submits comments regarding offer caps in markets operated by Regional Transmission Organizations (“RTOs”) and Independent System Operators (“ISOs”). API responds here to selected topics from the NOPR but reserves the right to comment on remaining issues as relevant in this docket. Though API references a few RTOs/ISOs as examples, these comments are meant to apply generally to all RTOs and ISOs under FERC jurisdiction.
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