VI. Comments on Proposed Decision

The proposed decision of the ALJ in this matter was mailed to the parties in accordance with § 311(d) and Rule 77.1 (now Rule 14.2) of the Commission Rules of Practice and Procedure. The CAISO, DRA, and BAMx filed comments on the proposed decision. SCE, SDG&E, and Global Energy filed reply comments taking issue with certain aspects of the CAISO and BAMx comments.

In its comments on the proposed decision, DRA fully supports the proposed decision and recommends its adoption. DRA comments that adoption of the proposed decision should aid the goal of streamlining major transmission proceedings. It comments that, as an added benefit, the principles and minimum requirements for the economic evaluation of transmission projects in certification proceedings should "spill over" into other resource planning and procurement proceedings and that the statewide planning process should be well served with adoption of the proposed decision.

The CAISO takes issue with the proposed decision's provision allowing a CPCN applicant to choose the type of system model to use in its economic assessment of the proposed transmission project. The CAISO reiterates its position that, because transportation models do not represent physical flows on the transmission system accurately, outcomes of transportation models are unreliable. We are unpersuaded by the CAISO's arguments that benchmarking efforts can never be sufficient to allow reliance on economic evaluations based on the use of transportation models. However, we have clarified the discussion regarding the showing that a party in a CPCN proceeding must make regarding the adequacy of the system modeling efforts that underlie its economic evaluation of a proposed transmission project.

The CAISO requests, if the Commission intends to rely on D.03-02-069 as a justification for the continued acceptance of transportation models, that the Commission reopen the record to evaluate the accuracy of the modeling effort using a transportation model to assess the economic benefits of the Miguel-Mission and Imperial Valley upgrades. Our determination in today's decision that a CPCN applicant should not be required to use a specific type of system model results from our assessment of the parties' showings in this proceeding, and is not based on the earlier findings in D.03-02-069. There is no need to reopen the record regarding the economic evaluations of the Miguel-Mission and Imperial Valley upgrades undertaken in I.00-11-001.

BAMx reiterates its position, stated for the first time in its opening brief, that the Commission should develop the long-term cost of entry for new capacity for various regions within California. We see no reason to modify the proposed decision in this regard.

BAMx also urges the Commission to keep I.05-06-041 open to examine the application of the adopted principles in the context of intra-zonal projects, such as SDG&E's pending application for a CPCN for the Sunrise Powerlink transmission project (A.05-12-014). However, continuation of this investigation is not needed to ensure the proper application in CPCN proceedings of the principles and guidance adopted in today's decision. Consistent with the provisions of § 1701.5, this investigation should be closed at this time.