UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION

Pacific Gas and Electric Company 		)	Docket No.   ER00-565-000 

SUPPLEMENTAL COMMENTS OF 
THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION

	The California Independent System Operator Corporation (“ISO”), hereby provides Supplemental Comments on the Scheduling Coordinator Tariff filed by Pacific Gas & Electric Company (“PG&E”) on November 12, 1999, in the above-captioned docket.  The ISO previously filed an unopposed  motion to intervene one day out-of-time in this docket.  At the time, the ISO raised no substantive issues, but noted that it might do so at a later date.  
	Upon further review of the proposed Scheduling Coordinator Tariff, the ISO has noticed that section 2.3(b) of the Scheduling Coordinator Tariff provides that, in the event of inconsistences between the Scheduling Coordinator Tariff and the ISO Tariff, the Scheduling Coordinator Tariff will prevail.  For the reasons stated below, the ISO strongly opposes this provision.  While the ISO hopes that the Commission may take these concerns into account in acting upon the Scheduling Coordinator Tariff, the ISO recognizes that the Commission may be required to act before that is possible.  Should the Commission set this matter for hearing, the ISO intends to pursue these concerns.  
	By section 2.3(b), PG&E is attempting in effect to assume the authority to revise operations under the ISO Tariff according to PG&E’s preferences.  The ISO does not believe that PG&E has the authority to do so.
	Moreover, allowing the Scheduling Coordinator Tariff to prevail over the ISO Tariff would be unsound policy.  The ISO is responsible for the nondiscriminatory operation of the ISO Controlled Grid, which comprises the transmission facilities of the three investor-owned utilities in California.  It is critical that the ISO be able administer its Tariff in a uniform manner.  The existence of separate, contradictory interpretations of ISO Tariff provisions would complicate, if not preclude, such uniformity.  
	Section 2.3(b) would set a precedent that could severely undermine the ISO’s ability to fulfill its responsibilities.  PG&E is just one of dozens of entities with whom the ISO has Scheduling Coordinator Agreements.  Each could follow PG&E’s example, causing multiple different interpretations of the ISO Tariff.
	WHEREFORE, the ISO respectfully requests that, should the Commission approve the Scheduling Coordinator Tariff, the Commission require that it be amended to provide that, in case of conflict with the provisions of the ISO Tariff, the ISO Tariff controls.

							Respectfully submitted,

						_____________________
	Roger E. Smith, Senior Regulatory		Edward Berlin
	Counsel					Kenneth G. Jaffe
Stephen T. Greenleaf, Director of			Michael E. Ward
	Policy						Swidler Berlin Shereff Friedman, LLP
California Independent System 			3000 K Street, NW, Suite 300
Operator Corporation				Washington, DC  20007
151 Blue Ravine Road				Tel: (202) 424-7500
Folsom, CA  95630					Fax: (202) 424-7643
Tel: (916) 608-7135
Fax:(916) 608-7222				Counsel for the California Independent
							System Operator Corporation

Date: January 10, 2000

	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 10th day of January, 2000.

_________________________________________
Michael E. Ward

	January 10, 2000

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

Re:  	Pacific Gas and Electric Company 
           Docket No.   ER00-565-000 

Dear Secretary Boergers:

Enclosed for filing are one original and 14 copies of the Supplemental Comments of the California Independent System Operator Corporation in the above-identified proceeding.  Two additional copies of the filing are also enclosed.  Please stamp the two additional copies with the date and time filed and return them to the messenger.

Thank you for your assistance in this matter.

				Yours truly,

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

Counsel for the California 
Independent System Operator Corporation