The wires are quickly derated at the vertical run, but your photo does not illustrate how far that bundle continues at the ceiling before they are derated again.
I would not use ventilation (if you are speaking of air movement) in my narrative, for I do not think that is the issue.
Typically/usually/normally, I see bunched cables circuit much longer than 24" inches. 1950’s-60’s homes that had panels in the garage. Cables are bunched for 20 plus feet and enter into a wall assembly.
The circuit cables in the OP image look to me more than 9, and run longer than 24" inches.
Cables in homes have so much diversity that the bundling derating (although required) has no real world benefit. You mentioned homes that are up to 75 years old and they obviously didn’t burn down.
Yeah, you’re right, but that’s just the way I articulated here, not in the report. Here is what I said in report: “Electrical wires were bundled together above electrical panel, which can lead to potential overheating issues due to reduced heat dissipation - it is recommended that the wires be separated or spread out around each conductor” and I provided a photo as an example. After reading again, I wouldn’t have even articulated this way again.
I think the narrative was ok. Here is an interesting article, it is a good place to start down the rabbit hole. It speaks of a specific risk where wires are pushed into holes and filled with fire stop foam.