UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION

AES Redondo Beach, L.L.C.				)	Docket Nos. ER98-2843-001
							)	and ER98-2843-002

AES Huntington Beach, L.L.C.			)	Docket Nos. ER98-2844-001
							)	and ER98-2844-002

AES Alamitos, L.L.C.					)	Docket Nos. ER98-2883-001
							)	and ER98-2883-002

El Segundo Power, L.L.C.				)	Docket Nos. ER98-2971-001
							)	and ER98-2971-001

Long Beach Generation, L.L.C.			)	Docket Nos. ER98-2972-001
							)	and ER98-2972-002

Ocean Vista Power Generation, L.L.C.		)
Mountain Vista Power Generation, L.L.C.		)	Docket Nos. ER98-2977-001
Alta Power Generation, L.L.C.			)	and ER98-2977-002
Oeste Power Generation, L.L.C.			)
Ormond Beach Power Generation, L.L.C.		)

Williams Energy Services Company			)	Docket No. ER98-3106-001
Duke Energy Oakland, L.L.C.			)	Docket No. ER98-3416-001
Duke Energy Morro Bay, L.L.C.			)	Docket No. ER98-3417-001
Duke Energy Moss Landing, L.L.C.			)	Docket No. ER98-3418-001
Southern California Edison Company		)	Docket No.     EL98-62-000

SUBMISSION OF REQUEST AND MOTION
OF THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION
FOR EXTENSION OF TIME
FOR THE FILING OF THE REPORT OF
THE MARKET SURVEILLANCE COMMITTEE

	The California Independent System Operator Corporation (“ISO”) submits the request of the Market Surveillance Committee (“MSC”) for an extension of time for the filing of the Report on the Ancillary Services Market now due from the MSC on March 1, 1999, and on its own behalf moves for a two-week extension, allowing the Report to be filed on March 15, 1999.
	In making this request, both the ISO and the MSC are mindful that when the Commission deferred the filing date to March 1st, it indicated that it did not expect to entertain requests for further postponements.  Order of January 29, 1999.  In these circumstances, the ISO and MSC would be loathe to request any further delay, even for the limited period that is the subject of this Motion, were they not convinced that it was necessary to permit the Committee’s contribution to be most useful.  Three considerations contribute to this conclusion.  First, the ISO is in the process of finalizing modifications to its Tariff and Protocols for the redesign of the Ancillary Services markets for filing with the Commission on March 1, 1999.  The Committee believes that it should have the benefit of that filing before finalizing its Report.  Second, over the past two months the Committee unexpectedly has been called upon, including by the Chief Administrative Law Judge, to undertake analyses in connection with the negotiations relating to the Reliability Must Run Agreements (“RMR”).  That undertaking, not expected when the commitment was made to file its Report by March 1st, has required the Chairman of the Committee, in particular, who is also the principal investigator for the Report, to spend an extensive and unanticipated amount of time on RMR-related activities.  As a consequence, time that both he and the Committee had intended to devote to the preparation of the Report, has been diverted to the RMR effort.  Third, progress is being made in the RMR negotiations and in a recently-executed “Memorandum of Agreement to Finalize Settlement,” incorporated by Chief Judge Wagner in an Order issued on February 5th, the ISO agreed that it would not release MSC reports relating to RMR contracts prior to March 15th.  The ISO would like to be able to honor that request and agrees that the RMR settlement process would be advanced by deferring until March 15th the filing of the MSC Report.
	Accordingly, the ISO and MSC believe that, notwithstanding the Commission’s earlier admonition, good cause exists for the modest extension, to March 15, 1999, of the filing date for the MSC Report required by the October 28, 1998 Order of the Commission in this docket.
						Respectfully submitted,

						_____________________________________________
						Edward Berlin
						Sean A. Atkins
						SWIDLER BERLIN SHEREFF FRIEDMAN, LLP
						3000 K Street, N.W.
						Suite 300
						Washington, D.C.  20007
						(202) 424-7504

						Attorneys for the California Independent System
							Operator Corporation

February 12, 1999

cc:	Service List
	Market Surveillance Committee
	California PX