In the September 21, 2021 Interconnection Process Working Group (IPWG) meeting, stakeholders were invited to submit feedback on Cure period applicability to Decision points and any other areas of the GIP that IPWG should explore for applicability.
The deadline for feedback is Tuesday, October 12.
EDFR supports MISO moving to explicitly disallow cure period in some specific instances - especially during decision points. EDFR may support cure period in some other areas but those may depend on the specifics after reviewing with stakeholders. If possible to move quickly towards making the change regarding the decision points, EDFR would support.
A cure period is needed to address circumstances where an unforeseen incident occurs and disrupts an IC's ability to meet some requirement. Perhaps defining a separate cure period for decision points would be one possibility; for instance 5 business days rather than 15 to meet obligations of decision points.
ITC appreciates the opportunity to submit feedback on the Cure Period Harmonization Proposal and has the following comments:
ITC supports MISO in its effort to enforce deadlines for interconnection customers in maintaining the queue. ITC supports providing the 15-day window for an IC to cure a deficiency in meeting an obligation when they provided data and met the deadline but inadvertently had errors in their data. Providing an IC 15 days to correct their data, is acceptable. Providing an IC 15 days because they failed to provide any data should no longer be acceptable. This provides a disincentive to everyone in the queue to perform in a timely manner and causes numerous delays.
Alliant Energy cautions against the complete removal of cure periods in the GIP. Unforeseen circumstances can and do occur which may prevent a GIP deadline or requirement from being met (e.g., family emergencies, technology/communication issues). Rather than seeking to eliminate cure periods Alliant Energy supports potentially reducing the cure period allocated in order to balance the ability to address legitimate issues and not slowing down the GIP process.
Transmission Owmer Sector Comments on DPP Cure Period Harmonization
October 12, 2021
The MISO Transmission Owners Sector provides the following feedback on MISO's initial responses to questions and provide additional comments regarding DPP Cure Period Harmonization, as requested at the September 21, 2021 Interconnection Process Working Group (IPWG) meeting.
The Owners support MISO’s efforts to address concerns with the current Cure Harmonization provisions that allow deficiencies in a limited number of projects in the DPP to delay other projects from moving forward as MISO allows the 15 day cure period to pass or for the deficiencies to be cured and move forward with ready projects. The Owners agree with MISO that the current cure period for projects in breach at the decision points exacerbates the delay in cycles and unduly penalizes ready and compliant projects.
The Owners thank MISO for the opportunity to comment and look forward to continued discussion on this topic.
Clean Grid Alliance Comments on Cure Period Harmonization
Oct 12, 2021
Clean Grid Alliance appreciates the opportunity to provide comments to MISO on Cure Period Harmonization. We support MISO’s effort to ensure that the Decision Point deadline is the same and fair for all Interconnection Customers.
Sincerely,
Rhonda Peters, Ph.D.
Technical Consultant for Clean Grid Alliance