UNITED STATES OF AMERICA
BEFORE THE
	FEDERAL ENERGY REGULATORY COMMISSION

)
San Diego Gas & Electric Company		) 	Docket No. ER99-2173-000	
							)

MOTION TO INTERVENE AND MOTION TO CONSOLIDATE 
OF THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION

Pursuant to Rules 212 and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“Commission”), 18 C.F.R. §§ 385.212 and 385.214, and the Commission’s March 17, 1999, Notice of Filing, the California Independent System Operator Corporation (“ISO”) hereby moves to intervene in the above-captioned proceeding.  The ISO also moves to consolidate the above proceeding with the ongoing proceeding in San Diego Gas & Electric, Docket Nos. ER98-496-000, et al.  In support thereof, the ISO states as follows:
I.	COMMUNICATIONS
Please address communications concerning this filing to the following persons:
N. Beth Emery					J. Phillip Jordan
Vice President and General Counsel		Mark R. Klupt
Roger E. Smith, Regulatory Counsel		Sara C. Weinberg
The California Independent System		Swidler Berlin Shereff Friedman, LLP
    Operator Corporation				3000 K Street, NW, Suite 300
151 Blue Ravine Road				Washington, DC  20007
Folsom, CA 95630					Tel: (202) 424-7500
Tel:  (916) 351-2334				Fax: (202) 424-7643
Fax:  (916) 351-2350
II.	BACKGROUND

On March 16, 1999, Cabrillo Power II LLC (“Cabrillo Power II”) tendered for filing pursuant to Section 205 of the Federal Power Act (16 U.S.C. § 824d), an amendment to the jurisdictional Reliability Must-Run Agreement applicable to 17 Combustion Turbines (the “Combustion Turbines RMR Agreement”).  The Combustion Turbines RMR Agreement was originally filed in Docket Nos. ER98-496-000 and ER98-2160-000 by the San Diego Gas & Electric Company (“SDG&E”) on October 31, 1997, and subsequently amended on March 11, 1998.  Pursuant to its filing, Cabrillo Power II proposes to adopt the Combustion Turbines RMR Agreement as its own.  Cabrillo Power II has requested that the amendment become effective as of the date it acquires the 17 Combustion Turbines, which will be on or about March 31, 1999.
III.	BASIS FOR MOTION TO INTERVENE

The ISO is a non-profit public benefit corporation organized under the laws of the State of California and responsible for the reliable operation of a grid comprising the transmission systems of SDG&E, Southern California Edison Company, and Pacific Gas and Electric Company, as well as for the coordination of the competitive electricity market in California.  
At issue in this proceeding is an RMR Agreement to which the ISO is a party and that could affect the reliability of the ISO Controlled Grid.  The ISO therefore has an interest in this proceeding that cannot be represented by any other party.  Accordingly, the ISO requests that it be permitted to intervene herein with full rights of a party.
The ISO raises no substantial issues at the present time but reserves the right to do so in any further aspects of the proceeding ordered by the Commission.  
IV.	BASIS FOR MOTION TO CONSOLIDATE

The ISO moves to consolidate this proceeding with the ongoing proceeding in San Diego Gas & Electric, Docket Nos. ER98-496-000, et al.  Consolidation is appropriate as the proceeding in Docket Nos. ER98-496-000, et al., has been established to resolve all outstanding issues regarding RMR Agreements. The ISO submits that in light of the related nature of the two proceedings, SDG&E’s assignment of the Combustion Turbines RMR Agreement should be subject to the resolution of Docket Nos. ER98-496-000, et al.
V.	CONCLUSION

Wherefore, for the foregoing reasons, the ISO respectfully requests (1) that the Commission permit it to intervene, and that it be accorded full party status in this proceeding, and (2) that the Commission consolidate this proceeding with Docket Nos. ER98-496-000, et al. 
		Respectfully submitted,

							__________________________
Sara C. Weinberg
Swidler Berlin Shereff Friedman, LLP
3000 K Street, NW, Suite 300
Washington, DC 20007
Tel: (202) 424-7500
Fax: (202) 424-7643
		Attorney for the California Independent
		    System Operator Corporation

Date: March 26, 1999

	CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing document upon each person designated on the official service list compiled by the Secretary in this proceeding.
Dated at Washington, DC, on this 26th day of March, 1999.

_________________________________________
Sara C. Weinberg

	March 26, 1999

The Honorable David P. Boergers
Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC  20426

Re:  	San Diego Gas & Electric Company
	Docket No. ER99-2173-000

Dear Secretary Boergers:

Enclosed for filing are one original and 14 copies of the Motion to Intervene and Motion to Consolidate of the California Independent System Operator Corporation in the above-referenced proceeding. An additional copy of the filing is also enclosed.  Please stamp the additional copy with the date and time filed and return it to the messenger.

Thank you for your assistance in this matter.

				Respectfully submitted,

                                                                 
Sara C. Weinberg
Swidler Berlin Shereff Friedman, LLP
3000 K Street, NW, Suite 300
Washington, DC  20007
Tel: (202) 424-7500
Fax: (202) 424-7643

					Attorney for the California 
Independent System Operator Corporation
3043102.1