I am advised that at yesterday's ISO Board meeting, the ISO announced that it 
would be filing with FERC today their circuit breaker proposal and tariff 
language under section 205 as required by FERC's Order last week granting the 
Mirant complaint, even though they will not have obtained ISO Committee 
approval of these documents. That approval, required for a 205 filing,  is 
anticipated to occur at the special meeting of the Management Committee 
that's been scheduled for May 23rd. My understanding is that the ISO intends 
to ask FERC to expedite approval of the circuit breaker plan and tariffs by 
June 13 but will not seek to have the circuit breaker applied prior to a 
final FERC ruling. 
IPPNY is likely to file tomorrow a response opposing the request for 
expedited treatment. We should oppose this request as well. Clearly, the ISO 
is making a mockery of FERC's remand of the circuit breaker back to the ISO 
to get approval and resolve a number of issues that had been raised by 
parties in the Mirant docket. However, those issues were only the tip of the 
iceberg, as most parties treated the Mirant complaint as a challenge to the 
ISO's authority to proceed without FERC approval and didn't raise substantive 
concerns with the specifics of the ISO's circuit breaker proposal when they 
filed in the Mirant docket. There are many such issues and parties thought 
they would get discussed in the Committee review process that FERC had 
clearly contemplated would occur.