UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

						)
	California Independent System	)	Docket No. ER98-990-001
	  Operator Corporation		)
						)

ANSWER OF THE 
CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION
TO MOTIONS TO INTERVENE

	Pursuant to Rule 213 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. § 385.213 (1997), the California Independent System Operator Corporation (“ISO”) submits this answer to the motions to intervene submitted in this docket.  As stated herein, the ISO does not oppose any of the interventions.
I.  BACKGROUND
	On June 1, 1998, the ISO submitted a compliance filing amending the ISO Tariff (including the ISO Protocols), the ISO Code of Conduct, the Transmission Control Agreement, certain of the ISO’s pro forma operating agreements, and certain of the ISO’s bilateral operating agreements.  Included in the June 1, 1998, compliance filing were amendments to the pro forma and bilateral Schedule Coordinator Agreements (“SCAs”).
	The Commission noticed the ISO’s filing on June 9, 1998, with interventions and protests due by August 5, 1998.  The Commission specified that comments related to the pro forma and bilateral SCAs were to be submitted in Docket No. ER98-990-001. 
	Interventions were filed by five parties:  the Western Area Power Administration, the California Department of Water Resources, Enron Power Marketing, Inc., the California Electricity Oversight Board, and CalEnergy Company, Inc.  None of the interventions raised substantive issues concerning the SCAs.  By order dated August 14, 1998, the Commission granted the ISO’s motion for an extension of time to respond to all of the interventions in the various compliance dockets, including this matter.
II.  DISCUSSION
	The ISO does not oppose the intervention of any of the parties that have moved to intervene in this proceeding.  Given that no party has raised a substantive issue concerning the compliance filing with respect to the SCAs, the ISO respectfully requests that the Commission approve the amendments filed by the ISO in the compliance filing.
III.  CONCLUSION    
	Wherefore, for the reasons stated herein, the ISO respectfully requests that the motions to intervene be granted and that the Commission accept, without modification, the ISO’s compliance filings of the pro forma and bilateral SCAs. 
				Respectfully submitted,

_______________________		________________________
N. Beth Emery				Edward Berlin
Vice President and General Counsel	Kenneth G. Jaffe
Roger E. Smith				David B. Rubin
Regulatory Counsel			Swidler Berlin Shereff Friedman, LLP
The California Independent		3000 K Street, N.W.
System Operator Corporation		Washington, D.C.  20007-3851
151 Blue Ravine Road			(202) 424-7500
Folsom, CA 95630
(916) 351-4400

Dated:  September 3, 1998

CERTIFICATE OF SERVICE
	I hereby certify I have this day served this document upon each person designated on the official service list compiled by the Secretary in this docket  in accordance with the requirements of Rule 2010 of the Commission’s Rules of Practice and Procedure (18 C.F.R. ¶ 385.2010).

	Dated at Washington, D.C. on this 3rd day of September, 1998.

						David B. Rubin

September 3, 1998

The Honorable David P. Boergers
Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C.  20426

Re:	California Independent System Operator Corporation
	Docket No. ER98-990-001 

Dear Secretary Boergers:

	Enclosed is an original and fourteen copies of the Answer of the California Independent System Operator Corporation To Motions To Intervene in the above-captioned docket.

	Also enclosed is an extra copy of the filing to be time/date stamped and returned to us by the messenger.  Thank you for your assistance.  

					Respectfully submitted,

					Kenneth G. Jaffe
					David B. Rubin
					Swidler Berlin Shereff Friedman, LLP
					3000 K Street, N.W.
					Washington D.C.  20007

					Counsel for the California
					Independent System Operator

Enclosures
cc:	Service List