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In this docket testimony has been filed in response to ComEd’s three new proposed tariffs – 

• Rider VPP (Virtual Power Plant Program), 
• Rider BYODLR (Bring Your Own Device Load Reduction Program) and 
• Rider CSS Community solar Plus Storage Program.)

Virtual Power Plant Program (VPP) – ComEd has proposed a tariff to offer customer enrollment in a virtual power plant that other parties argue restricts customer eligibility and participation and may not align with recently approved legislation that now awaits governor’s signature.  

Under ComEd’s proposal the VPP would be limited to customers who take generation and storage resources on ComEd’s Rate BESH that is an optional hourly pricing supply service for residential non-shopping customers yet mandatory for certain large non-shopping customers. 

Participants under ComEd’s proposal would be compensated at $10/kWh of nameplate capacity annually. 

Excerpts from selected filed testimony:

Staff Testimony  – “Q. What is your opinion of the Company’s proposed Rider VPP?

A.“I believe the proposal is overly restrictive. Additionally, I don’t believe the restrictions and minimal compensation will be successful at drawing participants. This is concerning because workshop participants agree that the focus of a VPP program should be encouraging customers to change their behaviors. As discussed below, I recommend the Company expand eligibility and include additional opportunity costs in its analysis.”

“Q. Do you agree with requiring Rate BESH to participate in the VPP program? 

1. No. ComEd is providing a flat fee for participation in the VPP program in advance of the summer. It is probably in the customer’s interest to enroll in Rate BESH to maximize the benefits of storage system discharge and even for a solar unit, but I do not see how being on a fixed price service leads to double compensation. I also find it odd that the Company argues that Rate BESH is necessary because that is how the Company analyzed the opportunity cost that needs to be compensated. A more sensical plan would be to conduct more analyses to determine the opportunity cost for a customer who switches from default service to hourly priced service. The analysis could also determine the opportunity cost of a customer on default service who remains on the same service and provides compensation that reflects the opportunity costs of actual customer behavior rather than ideal or anticipated customer behavior.”

“Q. Is it necessary to require a retail customer to have both generation and storage 156 to participate in the VPP program?

1. The Company has defined VPP to require both generation and storage, but I do not think that is appropriate. My understanding is that the ultimate goal is to have storage available to deploy when demand is likely to be high, so I do not understand why the Company would limit storage deployment to customers with generating capability. A customer with a battery backup system for its home could provide the same benefits in terms of net load reduction by using the storage for personal use and giving up the security of having a backup available rather than relying on the grid to supply power to the home regardless of whether the customer has generation. For a customer who has 5kW of backup power, each hour of personal use removes the need for 5 kW of power from the system while the backup system is in use. The net effect to the system is no different than a customer who dispatches 5 kW of power to the system for other customers to use.”

ELPC Testimony  – “I find that ComEd has complied with the Commission’s directive in the Order on Refiling to file tariffs addressing a Virtual Power Plant, Community Solar Plus Storage, and Bring Your Own Device Load Reduction program. However, in light of the enactment of the new law amending Sections 16-107.6 (the Distributed Generation and Storage Rebate) and creating a new 16-107.9 (Virtual Power Plant program), I recommend that ComEd propose how it intends to bring these tariffs into compliance with the new statutory requirements. 

In preparing tariffs to comply with the law, ComEd should: 

• ensure that participation in the scheduled dispatch program and any future Virtual Power Plant program is available to eligible residential customers receiving distributed generation or storage rebates, consistent with Section 16-107.6; 
• revise the proposed Rider VPP to eliminate unnecessary restrictions on customer eligibility and participation reflected in the new statute, and to align compensation and dispatch provisions with the amended Section 16- 107.6 Scheduled Dispatch Virtual Power Plant (SDVPP) framework; 
• revise the Community Solar Plus Storage tariff to be compliant with the new SDVPP framework; and 
• modify Rider BYODLR as needed to prevent overlap or double-counting of load-reduction events with other programs.

NEW LEGISLATION AND IMPACT ON THIS PROCEEDING 

Q: Did the General Assembly recently enact new provisions relating to VPPs that implicate this proceeding? 

A: Yes. Last week on October 30, 2025, the General Assembly adopted new provisions dramatically impacting the programs that are the subjects of this proceeding as part of a significant new energy law known as the Clean and Reliable Grid Affordability Act (CRGA). Governor Pritzker has already expressed his intent to sign the new law. The new law, expected to be effective June 1, 2026, will significantly advance and further define the requirements for the VPP Program, the CS+S program, and will impact the role of demand reduction and shaping technologies addressed in the BYODLR program in VPPs. While this legislation has not yet been signed by the Governor, I will assume for purposes of this testimony that the legislation will be signed by the Governor and become law next June.

Specifically, the new law amends Section 16-107.6 of the Public Utilities Act (Distributed Generation and Storage Rebate) and establishes a new Section 16-107.9”

“Q: Given these legislative changes, what do you recommend? 

A: I recommend that ComEd address in rebuttal testimony how it intends to modify its proposal in light of the newly enacted statutory framework. The substantial differences between the new law and ComEd’s filed tariffs indicate that Rider VPP and Rider CSS” 

Q: Given these legislative changes, what do you recommend? 

A: I recommend that ComEd address in rebuttal testimony how it intends to modify its proposal in light of the newly enacted statutory framework. The substantial differences between the new law and ComEd’s filed tariffs indicate that Rider VPP and Rider CSS will require significant amendments to align with the new statutory requirements. I observe that, to be compliant with the SDVPP program under the new law, ComEd would have to make amendments to reflect the differences highlighted in the table above. 

That said, the amended statute also clarifies that existing or parallel programs may continue. Specifically, the new language states:

“Nothing in this Section is intended to preempt or delay the implementation of other utility programs for devices that are not a part of the scheduled dispatch virtual power plant program that the Commission or utility may propose or require.”

New Section 16-107.6(e)(5). 

“Accordingly, ComEd’s proposed Rider BYODLR (Bring Your Own Device Load Reduction) could presumably continue to operate independently of the SDVPP, provided it does not overlap with or duplicate the functions of that program. While the future new VPP program will include technologies currently contemplated in the BYODLR program, it appears to me that the Rider BYODLR should proceed in this case in tandem with new SDVPP, subject to the amendments and revisions that my colleague JNGO Witness Andy Eiden recommends.”

Read all filed testimony at links below.

Staff Testimony  (11/03/2025)
ELPC Testimony (11/03/2025)
Advanced Energy United Testimony (11/03/2025)
Solar Energy Industries Association Testimony (11/03/2025)
US Solar (11/03/2025)
ComEd Testimony (09/30/2025)
Order – Resuspension  (10/29/2025)
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.)