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BOMA/Chicago Prevails in Utility Rate Design Case to Lower Costs, Increase Transparency

Two BOMA/Chicago recommendations supporting large office buildings were adopted by The Illinois Commerce Commission (“ICC”) in its final order for ComEd’s Rate Design Case. The ICC’s order approves reduced Beneficial Electrification (“BE”) plan costs allocated to large office buildings compared to ComEd’s original proposal and greater transparency in ComEd’s application of the Nonstandard Rider (“Rider NS”) Tariff.

In 2024, ComEd submitted a proposal to the ICC regarding the distribution of ComEd’s costs across delivery classes. This includes the costs approved through the recent multi-year rate plan and grid plan proceedings for the four-year period from 2024 to 2027. BE Plan costs were a large driver of increased costs for large office buildings under ComEd’s proposal.

BOMA/Chicago intervened as a party to the case to represent large office buildings, leveraging BOMA/Chicago’s Industry Defense Fund for legal and other costs.

 

Greater Transparency and Accountability with Nonstandard Rider

In partnership with the City of Chicago, BOMA/Chicago presented concerns from building members about the lack of transparency and the fairness and accuracy of costs related to ComEd Rider NS billing. BOMA/Chicago filed recommendations to improve transparency, accountability, customer engagement, and cost calculation procedures. The ICC adopted the recommendations and directed ComEd to implement the following:

1. Preliminary Assessment Requirement
For nonstandard facilities and services exceeding $100,000:

  • Process Details:
    • Provide detailed descriptions of proposed services and facilities, explaining their qualification as nonstandard.
    • Assess whether portions of the services may serve other retail customers and identify those customers with cost estimates.
    • Deliver an itemized cost breakdown aligned with the tariff equation, including supporting documentation.
  • Transparency Enhancements:
    • Specify infrastructure and equipment classified as standard service with associated costs.
    • Disclose the nonstandard cost with detailed assumptions and inputs for the tariff equation.

2. Customer Engagement and Cost Monitoring
For projects with estimates exceeding $100,000:

  • Allow customers to decide whether to proceed after receiving cost explanations.
  • Formalize agreements in writing.
  • Require ComEd to:
    • Notify customers within 5 business days if costs exceed the estimate by 10%.
    • Compare estimated and actual costs.
    • Provide detailed documentation for NS COST components before payment.
    • Respond to additional customer requests about nonstandard services within 14 business days.

3. Annual Report Requirement

ComEd must provide Rider NS customers (upon request) with a report by March 1 each year, including:

  • The latest engineering review of peak usage and electric power requirements.
  • An effective Electric Facilities Service Acknowledgement detailing ComEd infrastructure on customer property and its classification (standard/nonstandard).
  • Total annual costs charged under Rider NS, including standard service credits.

4. Independent Audit

The ICC will appoint an auditor to review ComEd’s administration of Rider NS. The audit will evaluate:

  • Alignment of invoice line items with the NS COST equation.
  • Adequacy of documentation supporting cost items.
  • Adherence to tariff requirements.
  • Explanation and consistency of standard service credits.

Members interested in annual reports should contact their ComEd representative promptly to receive the first report by March 1, 2025. 

 

Beneficial Electrification Costs Reduced

The allocation of Beneficial Electrification (“BE”) Plan Costs to commercial and industrial customers was reduced as a result of support by BOMA/Chicago and others. During the proceeding, ComEd agreed to a reduction of BE costs falling on nonresidential customers, including BOMA/Chicago buildings, by 11% from ComEd’s initial filing.  In response to arguments raised by BOMA/Chicago and others, the Commission also acknowledged that future adjustments to the allocation of BE Plan Costs may be necessary as more data on their actual allocation becomes available. 

The final order also approved a revision to the frequency of ComEd’s Carbon Free Resource Adjustment to 3 times a year using more current market data.  

For more information, contact Amy Masters, BOMA/Chicago Director of Government and External Affairs, at amasters@bomachicago.org. 

 

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