MICHAEL D. MACKNESS, 119998
2244 Walnut Grove Avenue, Suite 353
Rosemead, CA  91770
Telephone:  (626) 302-2863
Fax: (626) 302-1935

RICHARD L. ROBERTS
STEPTOE & JOHNSON
1330 Connecticut Avenue, N.W.
Washington, D.C.  20036-1795
Telephone:  (202) 429-6756
Fax:  (202) 429-3902
            AMERICAN ARBITRATION ASSOCIATION
Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY
RELIANT ENERGY POWER GENERATION, INC., a Delaware Corporation; RELIANT ENERGY ETIWANDA, LLC, a Delaware Limited Liability Company; RELIANT ENERGY MANDALAY, LLC, a Delaware Limited Liability Company; and RELIANT ENERGY SERVICES, INC., a Delaware Corporation,
Claimants,
v.
CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION, a California Nonprofit Public Benefit Corporation; and DOES 1-500,
Respondents.	)
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	CASE NO. 71 198 00295 99

SUMMARY OF CLAIM FOR DAMAGES AND DECLARATORY RELIEF
	
SOUTHERN CALIFORNIA EDISON COMPANY, a California corporation,
Claimant,
v.
RELIANT ENERGY POWER GENERATION, INC., a Delaware Corporation; RELIANT ENERGY ETIWANDA, LLC, a Delaware Limited Liability Company; RELIANT ENERGY MANDALAY, LLC, a Delaware Limited Liability Company; and RELIANT ENERGY SERVICES, INC., a Delaware Corporation, CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION, a California Nonprofit Public Benefit Corporation; and DOES 500-600,
Respondents.	)
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Claimant, Southern California Edison Company (“Edison”), has submitted claims against the Respondents California Independent System Operator Corporation (“ISO”), Reliant Energy Power Generation, Inc., Reliant Energy Etiwanda, LLC, Reliant Energy Mandalay, LLC, and Reliant Energy Services, Inc. (collectively, “Reliant”) for damages and declaratory relief.  Edison’s claim states that the ISO Tariff, Protocols, and the FERC-jurisdictional Reliability Must-Run Agreements (“RMR Contracts”) provide that market revenues associated with the provision of ancillary services under RMR contract dispatches should be paid to Edison as the Participating Transmission Owner in whose service territory the Reliant Must-Run Generators are located.  Edison also states that the RMR Contracts specify the compensation to be provided to Reliant for ancillary services supplied under RMR Contract dispatches.  Market revenues are not part of that compensation.  Therefore, Edison claims that the approximately $8 million of such revenues currently held by the ISO should be paid to Edison.  Edison also requests a declaration that the ISO shall (1) review the Reliant RMR Contract invoices, (2) calculate the amount due based on the information available to it and the ISO Tariffs and Protocols, (3) deduct from the Reliant RMR contract invoices the market revenues for energy and ancillary services provided pursuant to Reliant RMR Contract dispatches if not already deducted by Reliant or pay such revenues directly to Edison, and (4) pay to Edison the approximately $8 million held by the ISO on deposit for the period April through September, 1998.
DATED:  July 30, 1999	
By:		
Michael D. Mackness
Attorney for 
SOUTHERN CALIFORNIA EDISON COMPANY