3. On June 17, 2002, PG&E filed opening testimony on the expected net present value (NPV) of a PG&E-financed project compared to the NPV of the project financed under the terms of the letter agreement. ORA filed its opening testimony on July 3, 2002, and PG&E filed rebuttal on July 15, 2002. One day of evidentiary hearings were held in San Francisco on July 25, 2002. Subsequent to hearings, the assigned Administrative Law Judge (ALJ) directed PG&E, ORA and Energy Division to clarify the treatment of entitlements under the letter agreement and the ISO tariff. They filed a joint statement on this issue on September 6, 2002. Also on that day, PG&E and ORA filed opening briefs on the July 25, 2002 hearings. PG&E and ORA filed reply briefs on September 18, 2002. Issues and Scope

Although the Commission's concerns over congestion on Path 15 during 2000 and 2001 were expressed in terms of "system reliability" problems, it became clear during the course of this proceeding that Path 15 upgrades are not needed to meet the reliability criteria as defined by the ISO, the Western Systems Coordinating Council and the North American Electric Reliability Council. The ISO testified that the project is not required for reliability purposes, and that it does not plan to conduct any further reliability studies regarding Path 15.⁸ Therefore, the scope of our investigation focuses on the economic need for the project. More specifically, we examine the economics of the project on a "stand alone" basis-i.e., without considering the manner in which PG&E and other entities will participate in the project.