United States Of America
Before The
Federal Energy Regulatory Commission

California Independent System Operator	)		Docket No. ER98-211-000
	Corporation				)			
California Power Exchange Corporation	)		Docket No. ER98-210-000
						)		(Consolidated)
						)	
Southern California Edison Company	)		Docket No. ER98-462-000
Pacific Gas and Electric Company		)		Docket No. ER98-556-000
						)		Docket No. ER98-557-000
						)
Southern California Edison Company	)		Docket No. ER98-441-000
Pacific Gas and Electric Company		)		Docket No. ER98-495-000
San Diego Gas & Electric Company		)		Docket No. ER98-496-000
						)
Pacific Gas and Electric Company		)		Docket No. ER97-2358-000
Southern California Edison Company	)		Docket No. ER97-2355-000
San Diego Gas & Electric Company		)		Docket No. ER97-2364-000
						)		Docket No. ER97-4235-000
					)		Docket No. ER97-497-000

	MOTION TO CHIEF JUDGE FOR APPROVAL OF 
PROTECTIVE ORDER

	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) and the California Power Exchange Corporation (PX), hereby file this motion seeking an order approving the attached Protective Order.  The protective order will govern production of confidential documents in the above captioned proceedings.
	On December 17, 1998, the Commission set for hearing the above-captioned proceedings, which are all related to the restructuring of the California electricity market.   The Chief Judge held prehearing conferences on January 8 and 9, 1998 and ordered procedural schedules for each proceeding.  At the end of the prehearing conference in Docket Nos, ER98-210-000 and ER98-211-000, it was suggested that there be one Protective Order to govern all the California restructuring proceedings set for hearing.  The attached Protective Order is the result of a collaborative process among all parties. 
	A technical conference is scheduled for January 28, 1998.  At that conference the ISO intends to initiate settlement discussions.  In order that these settlement discussions be fruitful, it is imperative that participants to the above proceedings have an opportunity to review Protected Materials prior to the conference.  Accordingly, notwithstanding any discovery dates set at the January 8th and 9th prehearing conference the ISO and PX have agreed to make available certain protected materials to intervenors.
	The  PX and ISO prepared an initial protective order covering these protected materials and circulated it for comments.  While not all participants filed comments, the protective order filed does reflect many of  the comments we received.  Not all comments received are incorporated; however, the ISO and PX attempted to fairly address the various comments and we believe the majority of participants now support this motion.  Thus, while we apologize for filing this motion on such short notice, given the circumstances outlined above, we ask that the Chief Administrative Law Judge approve the attached Protective Order as expeditiously as possible.  
This motion is presented to the Chief Administrative Law Judge so that a single Protective Order will govern all the above-captioned proceedings.  Such an approach is preferable, given these multiple proceedings in which the parties are not identical.  To continue this approach paragraph 29 provides that any motion to change the provisions of the Protective Order shall be made with and determined by the Chief Administrative Law Judge.  A Party filing such a motion shall serve it on all parties on the restricted service list in all the captioned proceedings. This will ensure that the provisions of the Protective Order will remain consistent in each of the proceedings. 	 
WHEREFORE, the parties hereby request an order from the Chief Judge approving the attached Protective Order to govern each of the above-captioned proceedings.  The ISO and PX state that this motion and the attached Protective Order have been served on all parties 
on the restricted service.	

						Respectfully submitted,

				Stephen Angle
						Linda L. Walsh
					Michael R. Gartman
						Howrey & Simon
  						1299 Pennsylvania Avenue, N.W
						Washington, D.C.  20004
						(202) 383-6924
						(202) 383-6610 fax

N. Beth Emery
Vice President and General Counsel		Scott Rasmussen
California Independent System Operator	California Power Exchange Corporation 
  Corporation					1000 South Freemont Avenue	
151 Blue Ravine				Building A-9 West, Fifth Floor
Folsom, CA  95630				Alhambra, CA  91803	
(916) 351-2334				(626) 537-3100
(916) 351-2350 fax				(626) 537-3191 fax

Dated: January 23, 1998 

CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing document upon each party designated on the restricted  service list in this proceeding.

Dated at this 23rd day of January, 1998.

				____________________________
Michael Gartman