In general, Steelhead agrees with the changes that MISO is proposing to update the D1 study deposit. Due to the coordination, effort, and approvals needed from the financial side of our organization, we have some suggestions to enhance the existing proposal:
- Set a specific month/date each year when interconnection customers can expect updated deposit amounts.
- 30 Calendar Days for new deposits seems short if #1 is not known. If #1 is not set, we recommend a minimum of 60 Calendar Days for new deposits to become effective.
- The specific language proposed for Attachment X, Section 3.3.1 around the “month in which the posting takes place” was confusing, as this can be taken to mean when the deposit is ‘posted’ (paid) and not when the notification is ‘posted’ (added to the website). We suggest "month in which the notification takes place" as an alternative.
- There is no need to get the exact dollars and cents for a relatively small payment. Taking the largest inflation adjustment over the previous 12 months and rounding up to the nearest hundred would be sufficient (if performing this calculation annually).