UNITED STATES OF AMERICA
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION

)
Pacific Gas and Electric Company		) 	Docket Nos. ER98-495-000
							) 		    ER98-1614-000
							)			         ER98-2145-00
							)			         ER99-3603-000
							)			

To:  Hon. Judge H. Peter Young

MOTION TO INTERVENE OF THE CALIFORNIA INDEPENDENT SYSTEM 
OPERATOR CORPORATION

Pursuant to Rule 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“Commission”), 18 C.F.R. § 385.214, the California Independent System Operator Corporation (“ISO”) hereby moves to intervene in the above-captioned proceeding.  In support thereof, the ISO states as follows:
I.	COMMUNICATIONS
Please address communications concerning this filing to the following persons:
Roger E. Smith, Senior Regulatory 		Edward Berlin
	Counsel					J. Phillip Jordan
	Deborah Le Vine, Director of			Michael E. Ward
	Contracts & Compliance			Swidler Berlin Shereff Friedman, LLP
The 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) 351-4436				

II.	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 Pacific Gas & Electric Company, San Diego Gas & Electric Company, and Southern California Edison Company.  The ISO is responsible for the reliability of electric transmission to be scheduled through the ISO control area. 
The ISO was previously granted intervention in Docket No. ER98-495-000, on December 17, 1997 (81 FERC ¶ 61,332), Docket Nos. ER98-1614-000 and ER98-2145-000, on March 30, 1998 (82 FERC ¶ 61,326), and Docket ER99-3603-000, on September 14, 1999 (88 FERC ¶ 61,213).  Recent correspondence from Judge Wagner to Sidney Jubien, Senior Staff Counsel for the California Electricity Oversight Board, suggests that parties may nonetheless need to file motions to intervene in the severed sub-dockets.  Therefore, in order to confirm its party status in this sub-docket, the ISO is filing this additional motion to intervene.  The ISO requests expedited consideration of this Motion since testimony in the above-mentioned dockets is due on December 22, 1999. 
As the purchaser of the energy and ancillary services offered pursuant to the RMR Contract at issue in this proceeding, the ISO has an interest in the proceeding that cannot adequately be represented by any other party.  Accordingly, the ISO requests that it be permitted to intervene herein with full rights of a party.

III.	CONCLUSION
Wherefore, for the foregoing reasons, the ISO respectfully requests that the Commission permit it to intervene, and that it be accorded full party status in this proceeding.

		Respectfully submitted,

							__________________________
Roger E. Smith, Senior Regulatory		Edward Berlin
Counsel					J. Phillip Jordan
Deborah Le Vine, Director of			Michael E. Ward
	Contracts and Compliance			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) 351-4436				Counsel for the California Independent
								System Operator Corporation

Date: December 16, 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 16th day of December, 1999.

_________________________________________
Michael E. Ward

	December 16, 1999

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

Re:  	Pacific Gas and Electric Company,
	Docket Nos. ER98-495-000 et al.

Dear Secretary Boergers:

Enclosed for filing are one original and 14 copies of the Motion to Intervene of the California Independent System Operator Corporation in the above-referenced proceedings. Two copies are being provided to Judge Young. 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.

				Respectfully submitted,

                                                                 
J. Phillip Jordan
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