Sagarin has their SOS at 93.
http://sagarin.com/sports/cfsend.htm
By your logic of conference champ only...they should be considered.
All this is actually my point. An amalgam of ratings and algorithms picked teams for the BCS. We decided we hated that. Too subjective, we said. What about so-and-so, we said. Okay, so we make it subjective; play it off. When it started it was the best 4 of the 5 conf champs, plus maybe ND. Well, that is an element of subjectivity right there, and by year 3 the Committee had basically thrown the conf championship thing out the window. We basically now have 4 BCS teams rather than 2, with the alogorithms replaced by a lot of private conversations. So we're almost back where we started, which actually places a larger spotlight on ND's non conference status. This year ND was #3 after everyone's 12th game, and there was almost no way it could be jeapordized. Just dont lose in week 13 and they're in. So they stay home and cant lose. Or maybe next year they are 5 and sit home and hope someone loses game #13. Surely you see why people dont like that.
The ND response vascillates between two arguments:
1. Objective: we won all our games. Fine, so did UCF. And if objectivity is the standard, winning a Power 5 conf champ is usually objectively higher than winning 12 (or 10 or 11) games.
2. Subjective: Our regular season showed we were one of the top 4. Fine, but that is just the BCS argument we all hated. One could very well make the case that a team like UGA did more to elevate its subjective status in a loss to Alabama than ND did in any of its wins.
The existence of objectively determined conf winners and subjectively selected Playoff participants creates an inherent inequity when a non conference team like ND is considered. As I said in a previous answer to you, it could hurt ND as much as anyone else. As of yet this hasnt happened, but in a coming year, maybe 2019, they could be undefeated and legitimately a top 4 team, lose to USC at the end of the year, and have no recourse as a #5 team wins its conf champ game. ND almost has to go undefeated.