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ComEd Summarily Rejects NRG’s Support Of Constellation’s Motion To Reopen Record Re: Revisions to Large Demand Project Applications

ComEd Reply – ComEd argues that “reopening the record to address this Order is both unnecessary and likely to harm Illinois customers.”

Constellation Reply –  “[T]he Commission should reopen the record and require ComEd to revise its tariff filing to account for the new types of transmission service that FERC has ordered. ComEd has responded that the rates for the new types of service are not yet in effect.2 But that is not a reason to require a TSA reflecting only NITS service. Instead, at the very least, the Commission should suspend any TSA requirement for customers who are unsure whether they will seek NITS service; only once new rates are in effect, and ComEd revises its TSA to reflect these new rate options, should such customers be asked to sign a TSA. If these changes are not considered and accounted for in this proceeding, ComEd’s proposed tariff and Transmission Security Agreement (“TSA”) will discriminate against LDPACs that wish to exercise their new choices for transmission service by requiring the posting of collateral that is substantially excessive relative to the transmission rates they ultimately will be charged.”

As such “Constellation requests that the Commission:

  • Direct ComEd to adopt a provision in its General Terms and Conditions that allows a LDPAC to select the new transmission rates that have been directed by FERC, to be used in calculating the required transmission security; and 
  • for LDPACs that may desire to take advantage of new transmission service offerings, adopt a tiered collateral approach and/or permit the LDPAC to await greater clarity regarding the new transmission services and associated rates and security requirements before signing any TSA; or
  • reopen the evidentiary record and direct ComEd to make a supplemental filing explaining how its proposed General Terms and Conditions referring to the TSA as well as TSA terms and conditions themselves will accommodate and reflect FERC’s recent order requiring new transmission services.”

2025-0677
(ComEd proposed changes to new service requests for large demand project applicants or customers)
25-0679
(ComEd Proposal for revisions to Rider Distributed System Extensions)