UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

						)
Regional Transmission Organizations	)	Docket No. RM99-2-000
						)

MOTION OF
THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION
TO FILE COMMENTS 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 (“Cal-ISO”), hereby moves for leave to file its Initial Comments on the Commission’s May 13, 1999 Notice of Proposed Rulemaking on Regional Transmission Organizations (“NOPR” or "RTO NOPR") four days out of time.  In support of this motion, the ISO states as follows:
	The additional time requested was necessary in order to present the Initial Comments on the RTO NOPR to the Cal-ISO Governing Board.  The Cal-ISO had prepared its Initial Comments in substantially the form submitted to the Commission today by Monday, August 23.  Because the Commission's RTO NOPR addresses and solicits comment on a wide range of issues relating to the structure and operation of regional transmission operators, such as the Cal-ISO, however, these Comments were presented to the Governing Board for review and approval prior to filing with the Commission.  The first meeting of the Cal-ISO Governing Board in the past two months was held yesterday, August 26.  At that meeting, the Governing Board approved the filing of the Initial Comments.  
The Cal-ISO does not believe that the modest delay in submitting its own Initial Comments will prejudice any interested party.  Nonetheless, the Cal-ISO would not oppose any party that requests a comparable extension, if necessary, to reply to the Cal-ISO's Initial Comments. 
	WHEREFORE, the ISO respectfully request that the Commission grant it leave to file its Comments four days out of time

				Respectfully submitted,

_______________________		___________________________
N. Beth Emery				Edward Berlin
Vice President and General Counsel	Kenneth G. Jaffe
Roger E. Smith, 				David B. Rubin
Senior Regulatory Counsel			Sean A. Atkins
The California Independent		Swidler Berlin Shereff Friedman, LLC
  System Operator Corporation		Washington, DC 20007
151 Blue Ravine Road			Tel: 202-424-7500
Folsom, CA  95630				Fax: 202-424-7643
Tel: 916-351-4400
Fax: 916-351-2350

Date: August 27, 1999