Next, the Generators argue that allowing price suppression contravenes precedent regarding just and reasonable rates. According to the Generators, the Commission's approval of an exemption to the minimum offer price rule conflicts with its earlier decision in the Buyer Market Power Order to reject a categorical exemption to the minimum offer price rule. In NEPGA , this Court upheld the Commission's rejection of a categorical exemption because the Commission "reasonably acted to balance competing interests" by "mak[ing] the judgment that encouraging renewable energies was less important than allowing such out-of-market entrants to depress capacity prices." NEPGA , 757 F.3d at 295. Although we deferred to FERC's decision "to decline a categorical mitigation exemption," id. , we never held that the Commission must always weigh encouraging renewable energies as less important than preventing price suppression.
In the orders under review in this case, the Commission has performed an updated balancing of competing interests in the New England market. In the Buyer Market Power Order proceeding, the Commission explained that "[w]hether to grant an exemption is based on each case's unique facts" and the "[p]arties have not provided sufficient specificity to allow us to approve an appropriately narrow exemption." Remand Order at P 4 (quoting Buyer Market Power Order at P 171 ). In this case, the Commission considered the price suppression associated with the uneconomic entry of a small quantity of renewable resources, rather than the categorical exemption it had considered previously in the Buyer Market Power Order , and weighed it against state policies to promote renewable entry. Remand Order at PP 32-36, 39-43, 67-68 ;
*22Remand Rehearing Order at PP 19-29, 67-68. In its evaluation, the Commission explained that the new sloped demand curve mitigates the price suppression. Id. The Commission also considered expert testimony stating that any price suppression is limited by the renewable qualifying criteria, the low caps on the maximum amount exempted renewable capacity, and projected load growth and retirements. Id. The Commission explained why its view on the renewables exemption evolved and why the specific circumstances of this case led it to conclude that the renewable exemption is just and reasonable. Id. Under these circumstances, the Commission's decisions are distinguishable from the Buyer Market Power Order , and the decisions are not in conflict.
The Generators also argue that the orders under review are unreasonable because they are inconsistent with the Commission's decision to reject a renewable exemption to the minimum offer price rule in the New England Complaint Order . However, the New England Complaint Order is also distinguishable from the present orders because the tariff still relied on a vertical demand curve which results in more significant price suppression than a sloped demand curve. See New England Complaint Order at PP 15, 34-35 ; Remand Rehearing Order at PP 67-68.
Additionally, the burden of proof is different in the present case than in the New England Complaint Order . In the New England Complaint Order , the Commission rejected the complaint under section 206 of the Federal Power Act. Remand Rehearing Order at P 49. Under section 206, the complainant had to prove the existing rate was unjust and unreasonable without the renewable exemption, and then prove that the proposed exemption was just and reasonable. See Maine v. FERC , 854 F.3d 9, 24-25 (D.C. Cir. 2017). The present orders under review involve a tariff filing under section 205 of the Federal Power Act. Under section 205, FERC has to prove that it is establishing a just and reasonable rate. See id . The Commission is not required to show that the previous rate was unjust and unreasonable in order to demonstrate that the revised rate was just and reasonable under section 205. See id. The New England Complaint Order does not constrain the Commission from considering that changed circumstances now render the renewable exemption just and reasonable.
Next, the Generators ask the Court to consider a Third Circuit decision to affirm the elimination of an exemption to the minimum offer price rule in the mid-Atlantic power market, but that holding also does not counsel a different outcome in this case. See New Jersey Bd. of Pub. Utils. v. FERC , 744 F.3d 74, 100 (3d Cir. 2014) (" New Jersey "). In New Jersey , the Third Circuit considered a Commission order to eliminate a broad exemption to the minimum offer price rule that applied to any state-mandated resources. Id . at 95. New Jersey and Maryland planned to submit "thousands of megawatts of new capacity" below the minimum offer price floor under this exemption. Id . at 96. The Third Circuit affirmed the Commission's fact-specific determination that there was "mounting evidence of risk" that price suppression would distort the market and send the wrong signals regarding the need for new entrants to the market. Id . at 100-01. Notably, in the same decision, the Third Circuit also affirmed a more limited exemption for solar and wind resources. Id . at 106-07. The Third Circuit concluded that "FERC is permitted to weigh the danger of price suppression against the counter-danger of over-mitigation, and determine where it wishes to strike the balance." New Jersey, 744 F.3d at 109. We agree. Unlike in New Jersey , in this case the Commission found that the danger of *23price suppression was minor compared to other market considerations.
FERC has, at various times, considered exemptions to the minimum offer price rule in other markets. See Remand Order at PP 32-34. In some cases, the Commission accepted an exemption, despite the potential for price suppression. See, e.g. , New York Pub. Serv. Comm'n , 153 FERC ¶ 61,022 at P 10 (Oct. 9, 2015) ; PJM Interconnection , 135 FERC ¶ 61,022 at P 152 (Apr. 12, 2011). In some cases, the Commission rejected an exemption because of the potential for price suppression and market distortions. See, e.g. , PJM Interconnection , 135 FERC ¶ 61,022 at P 139 ; New England Complaint Order at PP 32-35 ; New York Indep. Sys. Operator, Inc. , 122 FERC ¶ 61,211 at P 110 (Mar. 7, 2008).
In those cases in which the Commission has considered exemptions to the minimum offer price rule, it considered exemptions using a fact-specific balancing test, factoring in the scope of the exemption, the existence of sloped demand curves, and the overall impact on the market, and only accepted exemptions that were appropriate based on the specific features of the market. The Commission engaged in the same type of analysis in the present case, and its conclusion is not contrary to precedent. This type of balancing requires an expert understanding of the market, which is well within the Commission's realm of expertise. We see no reason to disturb the Commission's balancing just because it came out in favor of the renewable exemption despite the potential for price suppression.
B. Did FERC engage in reasoned decision-making?
Now that we have established that an exemption to the minimum offer price rule can be just and reasonable under the Federal Power Act, we will consider the Generators' arguments that FERC was arbitrary and capricious in its evaluation of the renewable exemption.
First , the Generators argue that FERC acted unreasonably because it failed to quantify the price suppression resulting from the exemption. We defer to the Commission's reasoning when it relies on substantial evidence to make a predictive judgment in an area in which it has expertise, such as in the power markets. Wisconsin , 493 F.3d at 260. The Generators would like the Court to either require a quantitative assessment of price suppression or for FERC to explain "specifically why it could not have done so." Sierra Club v. FERC , 867 F.3d 1357, 1374 (D.C. Cir. 2017). In Sierra Club , we required a quantitative assessment of greenhouse gas emissions, because such an assessment was necessary to forecast the environmental impact of the decision under review. Id. Price suppression is not a scientific determination, but rather an economic construct. We permit the Commission to base its market predictions on "basic economic theory, given that it explained and applied the relevant economic principles in a reasonable manner." Sacramento Mun. Util. Dist. v. FERC , 616 F.3d 520, 531 (D.C. Cir. 2010) (per curiam); see also South Carolina Pub. Serv. Auth. v. FERC , 762 F.3d 41, 65 (D.C. Cir. 2014) (per curiam).
The Commission considered the contradictory expert testimony that the Generators presented that described and quantified potentially severe price suppression. See Remand Order at PP 37-44. The Commission credited competing expert testimony that predicted the price impact was more limited. Id . at PP 40-41. The Commission explained that the experts' conclusions differed because they disagreed on the predicted steepness of the supply curve, and it rejected the Generators' experts' assumptions on that topic. Id . It is *24well within the Commission's expertise to resolve conflicting expert testimony and make a judgment on which best predicts the scope and magnitude of the price suppression. The Commission is not required to rely only on quantitative predictions. Accordingly, we conclude that FERC relied on substantial evidence in determining that the price suppression from the renewable exemption will be minimal.
Second , the Generators argue that FERC acted unreasonably by relying on the sloped demand curve to justify its decision. The Generators argue that even though the sloped demand curve mitigates the price suppression compared to a vertical demand curve, it still results in significant price suppression and an unjust rate.
The Generators' objection revolves around the determination of the point where the supply curve intersects the demand curve, which sets the clearing price. When below-cost energy is added to the market, it shifts the supply curve to the right, so that it intersects the demand curve at a lower clearing price. Remand Rehearing Order at P 21. The Generators assert that the supply curve is steep where it intersects the demand curve. Because it is steep, small rightward shifts to the supply curve caused by the introduction of a limited amount of below-cost resources result in an intersection with the demand curve at a much lower clearing price. See id. at P 22. The Commission agrees that the steepness of the supply curve influences the magnitude of the price suppression. However, the Commission credited the testimony of an expert witness that explained that the supply curves are likely to be flatter than the supply curves offered by the Generators' experts. Remand Order at P 41 ; Remand Rehearing Order at P 25.
Likewise, the Generators also argue the Commission acted unreasonably in accepting ISO New England's revised demand curves and the addition of local sloped demand curves upon remand. Generators argue that the new demand curves are steeper at the point that they intersect the supply curve than the previous demand curves, resulting in greater price suppression. The Commission determined that the steepness in the new demand curves is mitigated because actual supply curves have been flatter than Generators predicted, and, if the performance of the demand curves changes over time, there are proceedings to review new curves that can address any issues. See Remand Order at P 44 ; Remand Rehearing Order at P 37. The Generators object to the inclusion of data from the ninth and tenth capacity year in the Commission's reasoning. However, the record was still open at the time the Commission considered the Remand Order and the Commission may fairly consider the market's actual performance.1
Again, we defer to the Commission's resolution of conflicting expert testimony regarding the relationship between the intersection *25between the supply and demand curves and the clearing price. The Commission reasonably determined that price suppression would be minimal because sloped demand curves mitigate price suppression.
Third , the Generators argue that FERC acted unreasonably by relying on anticipated load growth and retirements to mitigate price suppression. The Commission relied on expert testimony predicting that existing generators would leave the market and the demand for capacity would grow. Therefore, the small amount of renewable resources would fill some of this demand while prices remained stable. See Remand Order at P 53 ; Remand Rehearing Order at P 20.
The Generators counter that load growth failed to occur as the Commission anticipated. "[R]easoned decisionmaking does not require complete prescience." Florida Gas Transmission Co. v. FERC , 604 F.3d 636, 645 (D.C. Cir. 2010). The Commission relied on the expert predictions that were available at the time of its decision, and we defer to its use of these predictions.
The Generators also argue that the Commission did not rationally tie the magnitude of the exemption to any particular prediction of load growth or retirement. However, FERC explained that the 200 megawatt exemption was based on the best estimate of load growth, which was "estimated at 189 MW annually, plus an adjustment for the reserve margin required to meet the installed capacity requirement." Initial Order at P 83 ; Rehearing Order at P 22. The Commission also acknowledged load growth could be more or less than ISO New England anticipated, but ISO New England committed to "revisit[ing] the cap on the ... exemption in the future, should the entry of [renewable resources] exceed load growth." Rehearing Order at P 22. The Commission acted reasonably in tying the 200 megawatt exemption caps to load growth estimates.
With respect to retirements, the Generators argue that the retirement rationale was inappropriately raised on remand, that uneconomic entry will continue after retirements complete, and that its experts found price suppression will occur even with retirements. The Commission noted that ISO New England had previously predicted 6,500 megawatts of retirements by 2020, which is a substantial portion of the 35,000 megawatt market. Remand Order at P 53 ; Remand Rehearing Order at P 73. More recently, ISO New England "estimated that by 2020, resources representing about 30 percent of regional capacity have committed to cease operation or are at risk of retirement." Remand Order at P 53. The Commission observed that the predicted retirements were far in excess of the 600 megawatt carry-forward cap, and concluded that the exempted renewable energy would only make a small impact in replacing retiring resources. Id . Even with retirements, the Commission acknowledged the potential for minor price suppression. See Remand Rehearing Order at P 20. But the Commission is not required to protect against all price suppression. The Commission acted reasonably in concluding that retirements would help mitigate any price suppression.
Accordingly, we defer to the Commission's conclusion that the renewable energy exemption had only a limited potential for price suppression because of the implementation of the sloped demand curve, the prediction of a flatter supply curve, and predicted load growth and retirements. Therefore, we deny the Generators' petition for review.
C. The Generators' request for a hearing
Lastly, the Generators argue that the Commission should have settled *26issues of disputed fact regarding price suppression, load growth, and retirements at a hearing. The Commission's decision on whether to hold a hearing is reviewed for abuse of discretion. Louisiana Pub. Serv. Comm'n v. FERC , 184 F.3d 892, 895 (D.C. Cir. 1999). "In general, FERC must hold an evidentiary hearing only when a genuine issue of material fact exists, and even then, FERC need not conduct such a hearing if [the disputed issues] may be adequately resolved on the written record." Minisink Residents for Envtl. Pres. & Safety v. FERC , 762 F.3d 97, 114 (D.C. Cir. 2014) (quoting Cajun Elec. Power Coop., Inc. v. FERC , 28 F.3d 173, 177 (D.C. Cir. 1994) (per curiam) ).
In this case, the Commission decided that the material facts could be resolved on the written record. Remand Rehearing Order at PP 99-100. The extensive written record contained expert testimony and analysis regarding the market effects of the renewable exemption, the development of the sloped demand curve, and predictions for load growth and retirements. See id . Accordingly, the Commission did not abuse its discretion by relying on the written record to resolve disputes of material fact on these issues.
III. Conclusion
For the reasons set forth above, the Generators' petition for review is denied.