Findings of Fact

1. For the initial RPS procurement, it is reasonable to evaluate transmission costs of renewable projects using System Integration Studies and Facility Studies and to rely on existing conceptual transmission studies to the extent that System Impact Studies and Facilities Studies do not exist or are not sufficient.

2. For the initial RPS procurement, it is reasonable to require that each utility describe in its Transmission Ranking Cost Report each transmission upgrade identified in its conceptual studies that may be shared by renewable projects but which the utility considers to be gen-ties, and the basis for this conclusion.

3. For the initial RPS procurement, it is reasonable to require that each bidder be given the opportunity to list its gen-tie costs separately in its bid, and each utility should seek opportunities for the sharing of gen-tie costs among selected bidders.

4. For the initial RPS procurement, it is reasonable to allow bidders to describe expected network benefits in their bids and to require the utilities to consider this information in evaluating the bids in a method that is consistent and transparent.

5. For the initial RPS procurement, it is reasonable to allow the utilities to assess RPS bids that propose curtailability as an attribute of their projects on a case-by-case basis, subject to the requirement that such consideration be documented in a manner that is consistent and transparent to the Commission when it reviews proposed RPS contracts.

6. It is reasonable to require the utilities to assume in estimating transmission costs that wind generators will utilize modern technologies that employ VAR compensators and capacitor banks, in accordance with industry standards and, thus, to not increase transmission costs assessed to wind projects due to concerns that the projects may be VAR consumers.

7. It is reasonable to allow wind developers to include in their bids documentation that they will be net producers of VARs and to require the utilities to consider any such proposals they receive on a case-by-case basis.

8. It is reasonable to require that the utilities include in their Transmission Ranking Cost Reports separate reporting for each distinct network upgrade needed to accommodate renewable projects which have not had transmission upgrades identified through System Impact Studies or Facilities Studies.

9. It is reasonable to allow each utility to report a base case in its Transmission Ranking Cost Reports that includes transmission capacity which was identified through System Impact Studies and Facilities Studies for projects in the ISO queue and included in the base cases utilized in its conceptual transmission studies.

10. It is reasonable to require that the utilities describe in their Transmission Ranking Cost Reports the results of existing System Impact Studies and Facility Studies for projects in the ISO queue.

11. It is reasonable to require that wheeling costs for the transport of power through non-ISO control areas be included in the bid price and in the first ranking of RPS bids. Because of this, it is not necessary for developers to list expected wheeling charges separately in their bids.

12. It is reasonable to require the utilities to prepare and file their Transmission Ranking Cost Reports within 14 days of the effective date of this order.

13. It is reasonable to allow developers to bid who have not previously notified the utilities of their existence; however, all bids should be limited to interconnection points analyzed in the Transmission Ranking Cost Reports.

14. It is reasonable to allow the utilities to modify conceptual studies' cost estimates to be consistent with System Impact and Facilities Studies if the latter include AFUDC and/or O&M cost components that were not considered in the conceptual studies.

15. It is reasonable to delegate to the Assigned Commissioner in I.00-11-001 the assessment of the adequacy of Transmission Ranking Cost Reports required by this order, so that the bid ranking process is not delayed.

16. It is reasonable to adopt the methodology for the development and consideration of transmission costs in the initial RPS procurement contained in the April 2, 2004 ALJ ruling, with the modifications adopted in this order.