Bob, I generally agree. We are not mandating the size or rating of a generator that would be required for an optional standby system. However, we do not feel that an automatic transfer switch allows the "user" to select the loads to be served. If a whole house automatic transfer switch is installed, we conclude the user has selected all the loads of the home to be served. In this case, we request a load calculation not exceeding the rating of the generator output. As you are fully aware, a decent sized home has a relatively small calculated load as compared to the size of the typically installed service.
We are permitting certain loads to be eliminated from the calculation such as the 5kW for the dryer, and the typical 8kW for a range. The user must be aware that operating these loads may exceed the rating of the generator if use din conjunction with other house loads.
This issue has been discussed to death here in Florida and this is the general compromise as determined by a joint effort of the IAEI and BOAF.