From my sources:

CA ISO is filing jointly with SCE and SDG&E.  The comments begin with a tyrade that FERC has no right to condition price caps on joining an RTO.  Apparently, they weakly support regional organizations and note agreement to work with the other RTOs that are now forming.

PG&E is filing separate comments "because of its bankruptcy." PG&E will note concern about the CA ISO "independence" and talks about other RTOs as potentially good options.

The CPUC ordered and berated PG&E to file its comments with the CPUC BEFORE submitting them to FERC.  PG&E initially protested, but was threatened with fines.  It finally filed yesterday under seal.

Bottomline:

I believe that the joint ISO/IOU filing is structured to provide the minimal needed to meet the FERC test. Therefore, FERC's price caps will remain in effect.

Sue Mara
Enron Corp.
Tel: (415) 782-7802
Fax:(415) 782-7854