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Responses Sought On Utility’s Motion To Withdraw VPP, CSS & BYODLR Tariffs & Terminate Proceeding
In an Illinois notice of administrative law judge ruling suspended further action in the docket in response to ComEd’s motion to withdraw the tariff filings and terminate proceeding. Responses to ComEd’s Motion are due December 5, 2025, and replies to responses are due December 12, 2025.
In its motion to withdraw ComEd relies on the recent passed and enrolled legislation (previously reported upon) that awaits the governor’s signature approval. Specifically, in its motion, ComEd notes that “[o]n October 30, 2025, the Illinois legislature passed the Clean and Reliable Grid Affordability (CRGA) Act, SB0025 Enrolled. The CRGA Act, which is pending the Governor’s signature approval, would be effective June 1, 2026.”
In light of the pending law, ComEd seeks “to withdraw each of the proposed tariffs and moves to terminate the proceeding as moot.”
As previously reported, ComEd had filed three separate tariffs with supporting testimony to its proposed Virtual Power Plant (Rider VPP), Rider Community Solar Plus Storage (Rider CSS) tariff, and Rider Bring Your Own Device Load Reduction (Rider BYODLR) tariff.
Excerpts from ComEd’s motion for withdrawing tariffs and termination proceeding:
“The CRGA Act directly touches on many of the subjects currently at issue in this proceeding, including both VPP and CSS programs and their specific components of those programs including, but not limited to, device eligibility, compensation levels, and measurement of participant performance.”
“More specifically, the CRGA Act requires that applicable utilities, which includes ComEd, propose both a Scheduled Dispatch VPP program by June 1, 2026 (amendments to Section 16-107.6 of the Public Utilities Act (“PUA”), 220 ICS 5/16-107.6) and an additional VPP program by December 31, 2027 (amendments to Section 16-107.6 and new Section 16- 107.9 of the PUA, 220 ILCS 5/16-107.9).”
“Further, Section 107.9 of the CRGA specifically requires that any VPP program proposed pursuant thereto, shall incorporate programming in which “eligible devices” is defined to include, among other things, “behind-the-meter storage systems, smart–thermostats, electric vehicle batteries, including fleets, and distributed renewable energy devices paired with one or more energy storage systems.” (Section 16-107.9(a)).”
“The passing of the CRGA Act calls upon ComEd to consider the impacts of the CRGA Act’s provisions on ComEd’s three proposed tariffs and potentially revise the design of each of the proposed tariffs at issue in this proceeding as well as possibly merging programs.”
“Therefore, in tandem with the withdrawal of each of the proposed tariffs, ComEd moves to terminate this proceeding as moot.”
“ComEd believes that withdrawal of the proposed VPP, CSS, and BYODLR programs is proper for the reasons noted above and can and should be granted, without prejudice.”
Motion to Withdraw Tariffs & Terminate Proceeding.
2025-0678
(ComEd proposing three new tariffs, Rider BYODLR (Bring Your Own Device Load Reduction Program), Rider VPP (Virtual Power Plant Program), and Rider CSS Community solar Plus Storage Program.)
