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ALJ Issues Proposed Order on Electric Utility’s Grid Plan

On October 14, 2026, an Illinois Commerce Commission (ICC) Administrative law Judge (ALJ) issued a Proposed Order in ComEd’s 2028-2031 Multi-Year Integrated Grid Plan (MYIGP, or Grid Plan).

Among other things, the Proposed Order would:

(1) remove “the CEJA Decarbonization program and its associated $124.3 million budget,” finding that the program “misses the mark by using faulty forecasting and failing to consider NWAs”;

(2) approve ComEd’s DER Integration investment, finding that it enhances “DER hosting capacity that ComEd identified to be lacking,” but noted “concerns that this investment is not cost effective” and that Joint Solar Parties (JSP) urges adoption of “a Massachusetts-style cost allocation approach to ensure that the specific DER that benefit from hosting capacity upgrades such as the DER Integration program pay a pro rata share of costs based on hosting capacity benefits for their interconnection”;

(3) approve ComEd’s Interoperability Control Framework (ICF) investment as narrowed on surrebuttal to focus “the demonstration on two specific areas of anticipated coordination conflicts between DERMS flexible interconnections, demand response and VPP programs operating on the same constrained feeders or stations,” and direct ComEd to “propose a program harmonization framework in its 2027 VPP filing because it addresses the broader issue of whether those programs should be redesigned to reduce conflicts in the first place”;

(4) approve ComEd’s “Interconnection and Hosting Capacity Automation program [which] seeks to modernize ComEd’s interconnection study process and hosting capacity analysis through advanced automation,” but find that “ComEd has only partially complied with” ICC’s prior directives and direct it “to implement a plan to use interconnection studies to identify substations and feeders that need upgrades; every time ComEd generates an interconnection study that returns a cost greater than $0.75/W, then that substation (and, if more than $0.20/W of upgrades are attributable to the feeder, also the feeder) is automatically put into ComEd’s queue of assets to be upgraded under its grid plan”;

(5) direct ComEd to “collaborate with interested parties to consolidate investments to expand on Dynamic Flexible Interconnection where possible and propose a more streamlined, cost-effective data solution… with the impact on ratepayers as the central focus of discussion” and to report on the outcome by 7/1/27;

(6) approve ~24% of ComEd’s proposed smart meter investment, providing “funding for approximately 60,000 units per year to support new business installations, corrective maintenance, and mandatory meter exchanges”, given the pace of meter replacement,” given: (i) “recent meter replacement rates”; and (ii) that “ComEd has not shown that its originally proposed quantity of 250,000 meter replacements is required at this time or even in the near future”;

(7) approve ComEd’s Distributed Intelligence (DI) Pilot “to provide a small-scale test of edge computing capabilities on the next-generation meter platform”;

(8) regarding the Data Access Platform, direct ComEd: (i) ensure “any new data access platform be Green Button Alliance-certified”; (ii) pursuant to its memorandum of understanding, continue engagement with Joint Non-Governmental Organizations (JNGO) “to develop a platform roadmap, implement the data requirements developed through the 2024 stakeholder workshops, and provide ongoing input into the development of the platform”; (iii) “continue to work to ensure that the platform can share data externally with third parties as well as support internal utility functions including the Interconnection and Hosting Capacity Automation program”; and (iv) develop a cost-benefit analysis “to support the data platform, including the consideration of further ways to streamline the project”; and

(9) approve ComEd’s proposed investments in Green Button Connect (GBC) and direct “ComEd to provide all data required for wholesale market participation and regulatory reporting through the GBC or to respond in a compliance filing whether it will be able [to] utilize EDI instead of GBC or until the GBC platform is operational.”

Exceptions to the proposed order are  due by October 28, 2026; and replies to exceptions due by November 10, 2026.