On November 1, 2019, NRECA filed comments
at FERC in a proceeding where FERC held a technical conference in September on the topic of "Managing Transmission Line Ratings." The conference discussed industry use of ambient-adjusted ratings (AARs) and dynamic line ratings (DLRs) and possible FERC actions on line ratings and related practices to increase the efficient use of the transmission grid. This is not a rulemaking, but simply an information-gathering proceeding, which might be the prelude to a rulemaking in the future. The NRECA comments make three points: (1) FERC's focus should be on benefits to consumers in the form of lower costs of delivered energy and improved reliability; (2) FERC should not mandate AARs and DLRs on all lines by all transmission owners, since that would be a waste of money and disproportionately costly for rural utilities; and (3) FERC should not adopt prescriptive rules that preempt industry discussions of ways to make transmission line rating methodologies more transparent.