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Reply Briefs and Draft Orders Filed Re: Utility’s Grid Plan
Parties filed reply briefs and draft orders on ComEd’s 2028-2031 Grid Plan.
Staff recommended ICC: (i) direct that “for the cost-benefit analysis ComEd uses to determine the cost-effectiveness of proposed system investments,” it use a “discount rate of 6.705%, the [ICC]-approved weighted average cost of capital” for 2027 from its initial MYIGP; (ii) “incorporate forward-looking wholesale energy price forecasts into the energy burden analysis for both residential and C&I customers as it is essential to producing an accurate affordability assessment.”; (iii) “reject all [projects] under ComEd’s proposed CEJA Decarbonization Program, all of which are Hosting Capacity (‘HC’) investments” and direct ComEd to move “the CEJA Decarbonization Program and any related projects… to the capacity investment category” for future plans; (iv) direct ComEd to “streamline and downsize [interoperable control framework (ICF) projects], focusing on an updated DERMS and control architecture to support DER distribution and bulk power grid services,” deploying “DERMS iteratively based on where it is most needed to address system constraints”; (v) require that “ComEd’s cost-allocation approaches should be revised before approving investments that directly benefit exporting customers with little to no financial contribution”; (vi) approve ComEd’s requested $280.6 million for Smart Meter Operations project and $2.3 million for its Distributed Intelligence Pilot project; (vii) remove the $5.6 million requested for ComEd’s Community of the Future project; and (viii) “direct ComEd to include an updated affordability analysis in its next rate plan filing that considers the impact of the approved Grid Plan on overall affordability.”
AG recommended rejecting the plan, noting that the $410 million per year increase in capital investments over the current plan “plus the return of and on these investments, would drive consumer rates up by 21% for delivery service alone” and arguing that it “contains billions of dollars of investment that is neither necessary nor cost-effective”
Constellation recommended ICC: (i) “find ComEd’s [non-wires alternatives (NWA)] Framework remains ‘too restrictive’ and direct ComEd to lower cost and lead-time thresholds; provide transparent, granular constraint information; and provide a more appropriate process and standard to evaluate unsolicited NWA proposals”; (ii) “eliminate any doubt that third-party NWA ownership is permissible and encouraged without awaiting conclusion of the [standard service offer (SSO)] rulemaking”; (iii) “order ComEd to engage in exploratory discussions with Constellation and Sparkfund regarding the [distributed capacity procurement (DCP)] model”; and (iv) “direct ComEd to publish transparent, standardized interconnection procedures for Large C&I Customers (50 MW+)—including timelines, cost methodology, decision criteria, and escalation procedures—or, alternatively, to file a large load tariff within 120 days.”
Joint Solar Parties recommended ICC “approve ComEd’s MYIGP, but” require that it: (i) “expand and modify hosting capacity investments”; (ii) “adopt a Massachusetts-style approach to ensure ratepayers are protected and DERs pay for their own portions of much-needed hosting capacity upgrades”; and (iii) “take into account federal and state tax benefits and REC sales (as applicable to projects with solar components) when estimating the cost of NWA solutions—specifically as revenues that reduce the amount required from the NWA contract to receive the same amount of money—and state clearly the extent to which net metering and/or the DG Rebate are allowable,” or, if it does not, to “direct ComEd to seek pricing from interested bidders for third-party or customer-owned NWAs that receive a [total reserve cost (TRC)] of at least 0.5 under ComEd’s current, flawed methodology.”

