December 22, 1999

The Honorable David P. Boergers
Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C.  20426

Re:	Pacific Gas & Electric Company,  Docket No. ER98-495-000, et al.

Dear Secretary Boergers:

	Enclosed for filing are an original and seven copies of the Summaries of the Initial Testimony, as well as, the Initial Testimony of Brian Theaker and Eric Hildebrandt. in the above-identified dockets.  Also, enclosed please find an original and fourteen copies of a letter to the Presiding Judge regarding the issues in this proceeding. Two copies of each document are being provided to Judge Young.

	Also enclosed are two extra copies of the filing.  Please stamp the additional copies with the date and time, and return it to the messenger.  Thank you for your assistance.  

					Respectfully submitted,

					Edward Berlin
J. Phillip Jordan
					Swidler Berlin Shereff Friedman, LLP
					3000 K Street, N.W.
					Washington D.C.  20007

					Counsel for the California
					Independent System Operator

Enclosures
cc:	The Honorable H. Peter Young
	Restricted Service List

CERTIFICATE OF SERVICE

	I hereby certify that I have this day served the foregoing documents upon each person designated on the Restricted Service List compiled by the Presiding Judge in this proceeding.  

	Dated at Washington, D.C. on this 22nd day of December, 1999.

						_______________________
						Edward Berlin
J. Phillip Jordan
						Swidler Berlin Shereff Friedman, LLP
						3000 K Street, N.W.
						Washington, D.C.  20007

						Counsel for the California
						Independent System Operator