The GSR reporting service reported today that a new complaint (California 
Electricity Oversight Board v. All Sellers of Energy and Ancillary 
Services/California Independepent System Operator/California Power Exchange 
Corporation, EL00-104-000 (08/29/00)) was filed yesterday that requests the 
Commission to direct the CAISO too maintain bid caps of $250/MWh for energy 
and ancillary services, and $100 for replacement reserves until the 
Commission has completed its investigation of California markets.  The 
complaint also requests consolidation with the existing investigation in 
Docket Nos. EL00-95-000 and EL00-98-000.

Although I have not seen the complaint as yet (we'll get a copy to you as 
soon as it is available), this strikes me as largely a frivolous complaint 
that adds nothing to what is already going on.  In addition to the existing 
investigation, the ISO has indicated that it will file (sometime in 
mid-September) for authority to impose a price cap on ancillary services 
beyond 11/15/00, when the existing authority terminates.   The Oversight 
Board's complaint thus strikes me as a politically motivated public relations 
filing that is designed to maintain pressure on the ISO and to shift blame 
away from California and onto FERC if things really go bad in the state.

Moreover, the Commission has held that the price cap is a "purchaser's cap" 
that simply establishes the price that the ISO, as a purchaser of ancillary 
services, is willing to pay.  Thus, the Commission has held that it is not 
establishing a maximum rate by approving the ISO's ability to impose a price 
cap.  By requesting the Commission to direct the ISO to maintain a price cap, 
rather than allow the ISO to do so on its own, however, the Oversight Board's 
complaint seems inconsistent with the Commission's theory on this matter.

I'll send you FERC's notice as soon as I get it.  I assume that I should 
prepare a plain vanilla intervention for EPMI/EES at the minimum.  Please 
advise if you would like me to include any comments, such as those indicated 
above.

Ron