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On March 19, 2026, the Illinois Commerce Commission issued a Final Order approving Commonwealth Edison (ComEd) tariff revisions for large load customers.

As previously reported on June 23, 2025 ComEd filed proposed changes to new service requests for large demand project applicants or customers (“LDPAC”) under its General Terms and Conditions (“GT&C”). Also on June 23, 2025, ComEd filed with the Commission the following revisions to its Rider DE – Distribution System Extensions (“Rider DE”) ILL. C. C. No. 10 tariff sheets: 3rd Revised Sheet No. 269, 3rd Revised Sheet No. 270, 3rd Revised Sheet No. 272, 1st Revised Sheet No. 272.1.

In its filing ComEd explains that “the changes it proposed in this proceeding are necessary to address a dynamic and ongoing transformation in the energy industry landscape. ComEd notes that in recent years it has experienced an unprecedented surge in service applications from new customers with exceptionally large service requests. ComEd Ex. 1.0 at 3, 5. ComEd further notes that this trend, which began in 2019, has accelerated at an exponential pace.”

Excerpts from Commission Analysis and Conclusion

Revisions Related to Definitions

“The Commission finds that ComEd’s proposed definitions, as clarified in its responses to the City, are appropriate and approved. The Commission directs ComEd to include the following language in addition to its definition of a “Large Demand Project Applicant or Customer” in the tariff: For purposes of this definition, (a) “retail customer” means the same as defined in the Definitions part of these General Terms and Conditions and consistent with the Act, 220 ILCS 5/16- 102; (b) “the project” means a single bona fide request for new or increased load, which request is to serve load that ramps up to 50 MW or more within ten (10) calendar years of being placed in service; (c) “load ramp” and “projected load ramp” both mean the anticipated monthly request of new or increased electrical usage in MW; (d) “change” means the replacement of facilities with facilities of a different size or voltage; and (e) “expand” means the installation of facilities of expanded capacity.”

“The Commission rejects NRG’s arguments in support of surety bonds. The Commission is not persuaded by NRG’s reliance on PJM’s OATT as an example of other contexts where surety bonds are accepted. PJM permits only cash or LOCs for FTRs, its highest-risk market activities due to the scale of historical defaults. Likewise, it would not be reasonable or prudent for the Commission to permit surety bonds here with the estimated scale of future Large Load Projects.”

“The Commission finds that ComEd’s proposed definition of “Acceptable LOC” and its underlying requirement that it be issued by a U.S.-chartered bank with long-term, unsecured credit ratings of at least A3 (Moody’s) or A- (S&P) are reasonable and necessary to ensure financial protection for ComEd and its customers in light of the significant financial risks posed by LDPACs. Therefore, the Commission adopts ComEd’s proposed definition of “Acceptable LOC” and declines to adopt NRG’s suggested modifications.”

Revisions Related to Analysis of and Deposits of Large Demand Projects

Deposits for Large Demand Projects

“The Commission agrees with Staff and finds that ComEd’s proposed revisions to the deposit requirements for LDPACs, except as noted below, are reasonable and are a better match for the increasing scale of large load projects than the current flat fee collateral requirements. Specifically, a deposit structure tied to the MKD in a customer’s projected load ramp more accurately aligns the customer’s deposit with the engineering and planning resources required to evaluate the request. This sliding-scale approach provides appropriate incentives for customers to submit realistic and supportable demand forecasts and helps mitigate the risk of speculative or inflated requests that could lead to inefficient planning or unnecessary system investment. The Commission also finds reasonable ComEd’s proposal to require customers to provide an Acceptable LOC for any portion of an engineering deposit that exceeds $2,000,000.”

“The Commission finds ComEd’s revision to require a deposit sufficient to cover the cost of long-lead materials properly accounts for the unique commitments and resources needed to serve LDPACs. The proposed deposit to cover long-lead materials is approved to ensure that other customers are not exposed to stranded costs or unnecessary upgrades should an LDPAC not proceed.

The Commission further finds that ComEd’s existing process for refunding the GT&C deposits is reasonable. The Commission approves codifying the process in tariff language to improve clarity for customers.”

“ComEd proposes to amend its GT&C to clarify that each LDPAC will be subject to two deposits: (1) a security deposit to cover the costs ComEd will incur to conduct preliminary planning and engineering analyses, inclusive of the Cluster Study; and (2) a deposit sufficient to secure the costs of procurement of long-lead materials required for the project. ComEd Ex. 2.0 at 9-10; ComEd Ex. 1.01 at 12, 16. Currently, the Company requires a flat $1,000,000 deposit for all large load applications. However, the Company sufficiently demonstrated this requirement is no longer adequate given the scale and frequency of LDPACs in its service territory. ComEd Ex. 1.0 at 12-14 (currently, 500 MW projects are subject to the same deposit requirement as 1,000 MW projects). The Commission agrees with ComEd that deposits should be relative to the size of the LDPAC’s needs. See id. Under the revised tariff, the security deposit for projects requesting 50 MW or more will be based on the maximum kilowatts delivered (“MKD”) in the customer’s load ramp starting at $1,000,000 “plus an additional $500,000 for each whole 100 MW increment above 200 MW.” ComEd Ex. 2.0 at 9. The LDPAC must also provide an Acceptable LOC for any amount exceeding $2,000,000.”

“The Commission agrees with Staff and finds that ComEd’s proposed revisions to the deposit requirements for LDPACs, except as noted below, are reasonable and are a better match for the increasing scale of large load projects than the current flat fee collateral requirements. Specifically, a deposit structure tied to the MKD in a customer’s projected load ramp more accurately aligns the customer’s deposit with the engineering and planning resources required to evaluate the request. This sliding-scale approach provides appropriate incentives for customers to submit realistic and supportable demand forecasts and helps mitigate the risk of speculative or inflated requests that could lead to inefficient planning or unnecessary system investment. The Commission also finds reasonable ComEd’s proposal to require customers to provide an Acceptable LOC for any portion of an engineering deposit that exceeds $2,000,000.

The Commission finds ComEd’s revision to require a deposit sufficient to cover the cost of long-lead materials properly accounts for the unique commitments and resources needed to serve LDPACs. The proposed deposit to cover long-lead materials is approved to ensure that other customers are not exposed to stranded costs or unnecessary upgrades should an LDPAC not proceed.”

PROPOSED REVISIONS TO RIDER DE – DISTRIBUTION SYSTEM EXTENSIONS (“RIDER DE”)

“The record indicates parties in this proceeding widely recognize the need to protect existing ratepayers from costs and risks posed by new large load projects. While many intervenors argued ComEd’s proposal is insufficient to fully address the risks associated with the extraordinary costs of LDPAC projects, several parties acknowledged ComEd’s revisions represent an initial step toward addressing the novel issues presented by provision of service to large load customers. See Staff Ex. 2.0 at 3; JNGO IB at 18. The Commission agrees and adopts ComEd’s revisions to Rider DE as part of that initial step.”

“ComEd’s Rider DE determines if a deposit is needed from a new customer prior to ComEd constructing any extensions necessary to provide standard service. ComEd Ex. 2.0 at 17. Rider DE provides the conditions “under which the Company requires a deposit, letter of credit, or nonrefundable payment,” the amount of that deposit, and the refunding mechanism available to the new customer. ComEd Ex. 1.04. ComEd proposes three changes to Rider DE to address issues related to LDPACs: (1) modify which facilities are subject to a deposit if ComEd requires a deposit for large load projects; (2) specify the mechanism for deposits equal to or over $2,000,000; and (3) define the requirements for an Acceptable LOC.”

“Rider DE will now include standard facilities installed on premises and “additional construction or investment in [ComEd’s] existing distribution system necessary to provide standard electric service to the premises.”

“The Commission finds ComEd’s proposed modifications to Rider DE are necessary to strengthen deposit and collateral protections for new, large load projects. The Commission agrees with Staff that the expanded deposit requirements provide important protections and represent a key first step toward serving large load projects while preventing undue cost shifts.

NRG asks the Commission to consider the proposed changes in an upcoming rate case, multi-year rate case, or rate design proceeding so that the Commission can issue a more informed, data-based decision consistent with cost-causation principles. The Commission finds that it is not precluded from approving ComEd’s revisions to Rider DE here but agrees with NRG that there should be continued consideration of these issues as addressed in Section VII.A.8. below.”

“The Commission shares the AG’s and JNGO’s concerns about ratepayers bearing the costs for LDPAC projects but finds this proceeding and this record do not provide an adequate basis for the requested changes. The record and scope of this proceeding are constrained by the revisions to Rider DE and GT&C proposed by ComEd. The Commission is tasked with determining whether the revisions proposed in this proceeding are just and reasonable. 220 ILCS 5/9-201(c). The Commission is concerned that pertinent questions remain unanswered by this record, including the cost and consequences of adopting the alternative proposals. For example, the Commission notes a more robust discussion is needed regarding cost causation specific to LDPACs and how to identify and allocate costs of certain upgrades and new system equipment that may provide benefits to other customers. While the Commission declines to adopt the AG’s and JNGO’s proposals based on this record, it is not precluded from considering and adopting similar proposals in the future. The Commission agrees many valid and important issues have been raised by the AG and JNGO. Accordingly, the Commission directs parties to participate in a broader discussion of LDPACs in the future proceeding directed by the Commission in Section VII.A.8. of this Order.”

Read full Final Order here.