From Federal Energy Regulatory Commission:

Other commenters also support the Commission’s basis for reform. R Street Institute states that the Commission’s problem statement is sound, explaining that transmission line ratings are chronically understated because they do not reflect current weather conditions, and as a result, according to R Street Institute, fail to allow for significant cost savings.[32]

R Street Institute states that understated transmission line ratings can result in increased congestion costs and underutilization of generation in export-constrained locales, which is disproportionately zero-emission generation.[168R Street Institute contends that the Commission should require DLRs by default and permit exceptions where justified by a cost-benefit analysis.[169]

R Street Institute, PG&E, Indicated PJM Transmission Owners, Dominion, and Potomac Economics also support incorporating predictable daytime/nighttime solar heating into AARs, with Dominion and Indicated PJM Transmission Owners noting that this is already the practice in PJM.[344

R Street Institute contends that DLRs should be required by default, with exception given when justified by a cost-benefit analysis.[523

R Street Institute, however, observes that transmission management inefficiency and transmission line rating opacity outside RTOs/ISOs is far greater than within RTOs/ISOs, and therefore concludes that updating transmission line ratings hourly outside RTOs/ISOs would be a prudent start.[550

R Street Institute notes that some transmission operators use a 30 minute duration and others use two to four hour durations.[628

R Street Institute similarly contends that the benefits of emergency ratings go beyond the production cost savings estimated by Potomac Economics and include avoided customer outages.[671R Street Institute notes that the cost of additional wear must consider the frequency and duration of emergency rating use, which is usually uncommon and brief.[672]

R Street Institute contends that emergency ratings should be required regardless of RTO/ISO participation, to avoid a disincentive to RTO/ISO membership, and that inaccurate emergency ratings are unjust and unreasonable.[677R Street Institute recognizes that the record on emergency ratings is sparse and that implementing emergency ratings may be prone to operator error, but notes that they are sometimes used implicitly during emergency conditions.[678]

R Street Institute argues that the NOPR proposal would provide insufficient transparency and that, ideally, transmission line ratings and methodologies would be available to a broader set of market participants and state commissions as well.[759]