NEPGA and the Independent Power Producers of New York (IPPNY) jointly filed comments in response to the FERC Notice of Proposed Rulemaking initiated by the U.S. Department of Energy (DOE) regarding “reliability and resiliency” (No. RM18-1).  The NOPR proposed by DOE would, if adopted, require RTO/ISO wholesale markets to provide cost of service rates to generators that have 90 days of on-site fuel storage.  In their joint comments, NEPGA and IPPNY ask FERC to reject the proposed rule and consider market-based mechanisms to price any reliability or resiliency services needed but not properly priced in the markets.