In the June 22, 2022 meeting of the Planning Advisory Committee (PAC), stakeholders were invited to submit feedback on Cure Period Harmonization draft tariff language.
Comments are due by July 13.
Vistra Corp. (“Vistra”) appreciates MISO providing parties with the opportunity to submit comments on the Cure Period Harmonization proposed tariff language. Vistra encourages MISO to clarify that the recommended changes in Attachment X referencing a ‘three business day cure period for failure to submit a milestone payment,’ means customers are given three full business days to cure a deficiency. As currently written, the language could be interpreted as providing parties with less than three business days. For example: If an Interconnection Customer receives a written notice from a Transmission Provider for failure to submit a milestone payment at 3:00 pm on a Monday, the customer should have until close of business on Thursday to correct the deficiency; this represents three full business days.
Vistra also supports the 5/2/2022 comments filed by Savion, LLC., that address Attachment X, Section 3.3.3, “Review of Interconnection Request and Cure of Deficiencies.” In other jurisdictions, Vistra has experienced situations where we attempt to gain clarity on the details of an alleged deficiency, but the response doesn’t come until the end of the cure period, leaving Vistra with almost no time to correct or fully address the alleged deficiencies. Because of this not uncommon situation, the additional cure period in Section 3.3.3 is still needed.