UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

     	)
California Independent System	     	)	   Docket No. ER00-800-000
   Operator Corporation		     	)
     	)

ANSWER OF 
THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION
 TO COMMENTS, PROTEST, AND
REQUEST FOR CLARIFICATION, HEARING AND CONSOLIDATION

On December 15, 1999, the California Independent System Operator Corporation (“ISO”) submitted, in accordance with the terms of its Tariff, an informational filing to present its calculation of the Grid Management Charge (“GMC”) for the year 2000 (“Informational Filing”).  In response to the Informational Filing, one party questioned whether the ISO had properly applied all factors in the formula rate governing the GMC and another party requested a hearing and consolidation of this proceeding with other proceedings governing the GMC.  Pursuant to Rule 213 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. § 385.213, the ISO submits its Answer to these filings.
DISCUSSION
Under the ISO Tariff, each December 15, the ISO is to file certain information with the Commission regarding the GMC to be applied for the next calendar year.  This was accomplished for the GMC for the year 2000 through the Informational Filing.  In accordance with the commitments the ISO had made in the original settlement governing the GMC, the ISO held meetings and provided information to the public well in advance of the December 15 filing regarding the data to be included in the Informational Filing as well as the projected GMC level.  It also requested comments on that data.  No comments were received.  Informational Filing Transmittal Letter at 3.  Two parties, however, the Metropolitan Water District of Southern California (“Metropolitan”) and Western Power Trading Forum (“WPTF”), raised questions or comments regarding the actual Informational Filing.
Metropolitan’s filing questioned whether the ISO had forgotten to include an amount in the category “Reserve Transfer” under the GMC formula.  See Metropolitan Motion at 5-6.  The answer to that question is that the Operating Reserve Transfer amount is zero (0) for the Year 2000 calculation because the Operating Reserve Transfer account has not yet been fully funded.  The Informational Filing was thus correct.
Turning to WPTF’s filing, WPTF simply rehashes issues that it has raised in earlier proceedings related to the GMC.  The ISO has responded to each of the claims raised by WPTF previously and it would not be productive to restate those arguments in this proceeding.  In any event, there is no need to examine those issues here because the Commission has made clear that the collection of the GMC is currently subject to refund and to the outcome of the proceeding that will examine the GMC to be made effective January 1, 2001.  The Informational Filing only changed the level of the GMC in accordance with the formula rate; it did not alter the fact that the GMC is being collected subject to these conditions.  WPTF thus will have the opportunity to raise its concerns in connection with the January 1, 2001, GMC filing.  No further relief is required.

CONCLUSION
	For the foregoing reasons, the Commission should accept the Informational Filing without modification.
Respectfully submitted,

_________________________		________________________
Roger E. Smith				Edward Berlin
Senior Regulatory Counsel			Scott P. Klurfeld
The California Independent		Bradley R. Miliauskas
  System Operator Corporation		Swidler Berlin Shereff Friedman, llp
151 Blue Ravine Road			3000 K Street, N.W., Suite 300
Folsom, CA  95630		 		Washington, DC  20007

Dated:  January 24, 2000