The National Rural Electric Cooperative Association (NRECA) is the national service organization representing more than 900 not-for-profit, member-owned rural electric cooperatives (“Cooperatives”). Most of NRECA’s members are distribution cooperatives, providing retail electric service to more than 42 million consumers in 47 states. NRECA members also include approximately 66 generation and transmission (“G&T”) cooperatives that supply wholesale power to their distribution cooperative member-owners. Cooperatives provide service to approximately 75 percent of the nation’s land mass, resulting in a consumer density of just seven consumers per mile of line, significantly less density than that of investor or municipally owned utilities.1 Both distribution and G&T Cooperatives were formed to provide their members with adequate and reliable electric service at the lowest reasonable cost. In total, kilowatt-hour sales by Cooperatives account for approximately 11 percent of all electric energy sold in the United States.