MISO is requesting feedback on posted Cure Period Harmonization Draft Tariff Language.
Please provide feedback by May 4, 2022.
Clean Grid Alliance Comments on Cure Period Harmonization
May 4, 2022
Clean Grid Alliance appreciates the opportunity to provide comments on MISO’s proposal for Cure Period Harmonization. We would like to thank MISO for being flexible and responding to stakeholder concerns about the potential to be withdrawn from the queue on a technicality. The 3 days “cure period” MISO has proposed will help prevent projects being withdrawn from the queue due to unexpected delays by financial institutions and other unforeseen circumstances.
Sincerely,
Rhonda Peters, Ph.D.
Technical Consultant for Clean Grid Alliance
Pine Gate Renewables (“PGR”) appreciates the opportunity to provide comments on the Cure Period Harmonization proposed tariff language changes. PGR supports the addition of a 3-business day cure for milestone payments. While PGR supports the proposed changes to prevent duplicative cure periods, we also support Clean Grid Alliance’s former comments in February 2022, in that it is imperative for MISO to ensure:
1) The standard 15 business day period begins only after all parties have been notified; and
2) MISO provides timely feedback during the 10-day cure period and does not penalize interconnection customers for late communications from MISO.
ITC Holdings thanks MISO for the opportunity to provide comments on Cure Period Harmonization draft tariff language discussed at the IPWG. ITC supports the modifications to Attachment X to clarify the provision of the cure period to prevent duplicative use of a cure period (referred to as the “double cure”) within the interconnection request review. This will eliminate delays in DPP Study associated with some interconnection customers utilizing a “double cure” period. ITC also supports the addition of a 3 business day cure for milestone payments as a reasonable compromise to address issues without impacting the GIP timeline. These changes provide a balance to permitting a interconnection customer to resolve an error while not delaying study cycles and those ready and compliant projects.
Savion, LLC (“Savion”), a Shell Group portfolio company operating on a stand-alone basis, is an industry-leading utility-scale solar and energy storage project development company. Savion would like to thank MISO for bringing this topic back to the IPWG for discussion.
Savion previously submitted the below comments to the IPWG expressing our concerns to the proposed changes. Based on MISO’s latest presentation on this topic MISO has failed to respond to or address any of these issues at the April IPWG meeting. We would like to reiterate our concerns, especially in regard to section 3.3.3, and request MISO review and provide a response in turn.
Savion is generally in agreement with MISO’s proposed changes to modify Attachment X to eliminate the double cure provisions that may occur at Decision Point I & II assuming MISO has appropriately notified the parties. There have been instances where IC’s have not been notified of the start of a Decision Point and under these circumstances MISO must still allow the full (15) fifteen Business Days from the time ALL parties have been notified.
Upon review of the proposed changes to section 3.3.3 Savion has multiple concerns. While we find the instituted (10) ten Business Day cure period if implemented as intended acceptable, MISO has not demonstrated eliminating a second cure period under this section to be just and reasonable for the IC. We have experienced numerous issues with projects being flagged for issues during the application review process and being placed on the (10) ten Business Day clock. In the end most of the alleged deficiencies concerned information which had initially been provided and these alleged deficiencies were eventually removed. During Savion’s attempts to gain clarity on the nature of the alleged deficiency and thereby provide MISO with further evidence to meet its needs, MISO failed to respond within the cure period or waited until the very end of the cure period. In failing to respond in a timely manner, or by not responding at all, MISO never provided Savion with sufficient opportunity to cure alleged deficiencies.
There have also been instances under section 3.3.3 where MISO failed to timely respond to allow Savion time to address issues that were legitimately identified. Without clarification in many cases Savion isn’t sure what MISO is claiming needs correction and cannot work to locate what they are seeking. This communication feedback loop is critical and needs to be addressed by MISO.
In light of ongoing issues with MISO’s implementation of the Tariff Savion does not feel it appropriate at this time to eliminate the additional cure period under section 3.3.3.
Savion would appreciate MISO’s further consideration in this matter.