UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION

Williams Energy Services Company	)	Docket No. ER98- 3106- 000

MOTION OF 
THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION
TO FILE MOTION TO INTERVENE AND PROTEST OUT OF TIME

	Pursuant to Rule 212 of the Commission's Rules of Practice and Procedure, 18 C.F.R. §§ 385.212, the California Independent System Operator Corporation (“ISO”), hereby moves for leave to file a Protest out of time in the above-entitled proceedings.  	
	In these dockets, Williams Energy Services Company (“Williams”) seeks, inter alia, blanket market-based rate authorization for sales of four ancillary services -- Regulation, Spinning Reserve, Non-spinning Reserve, and Replacement Reserve, each as defined in the ISO Tariff (collectively, the Regulation and Reserve Services).  The Commission has only recently issued its first grant of authority for the sale of Regulation and Reserve Services at market-based rates.  See AES Redondo Beach, L.L.C., et al., 83 FERC 61, 358, (June 30th  Order).  Subsequently, the Commission has granted such authority to additional applicants.   El Segundo Power, LLC et al., 84 FERC ¶ 61,011 (1998); Ocean Vista Power Generation, LLC et al., 84 FERC ¶ 61,013 (1998) (July 10th Orders).
	Events subsequent to the June 30th and July 10th Orders have demonstrated that an unconditional grant of the market-based rate authority requested by Williams would have enormous adverse consequences for the California market.  The ISO therefore seeks to intervene in this proceeding and to protest Williams’s filings at this time.  The ISO should be granted leave to protest out of time to present to the Commission data bearing directly on the untoward consequences of granting the unconditional market-based rate authority sought in these dockets, which data were not available at the time specified for intervention and protest in this proceeding.  
CONCLUSION
	WHEREFORE, the ISO respectfully requests that the Commission grant it leave to file a Motion to Intervene and Protest out of time in the above-entitled proceedings.
			Respectfully submitted,

														________________________________
			N. Beth Emery
			Vice President and General Counsel
			Roger E. Smith, Regulatory Counsel
			The California Independent
				System Operator Corporation
			151 Blue Ravine Road
			Folsom, CA  95630
			Tel: 916-351-2334
			Fax: 916-351-2350
									Edward Berlin				Kenneth G. Jaffe				Michael E. Ward				Swidler & Berlin, Chartered
			3000 K St., NW #300
			Washington, DC 20007
			Tel: 202-424-7588
			Fax: 202-424-7645

Date: July 17, 1998

CERTIFICATE OF SERVICE

	I hereby certify that I have this day served the forgoing document upon each person designated on the official service list compiled by the Secretary in this Docket No. ER98-3106-000 in accordance with the requirements of Rule 2010 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. §385.2010 (1997). 

Dated at Washington, D.C. on this 17th  day of July, 1998.

																	___________________________
						Michael E. Ward

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