25-0514

Key events and scheduled submissions in this proceeding include:

- May 21, 2025: Commonwealth Edison (ComEd) filed its petition to approve proposed performance and tracking metrics and submitted direct testimony and supporting materials 1.
- June 25, 2025: ComEd direct testimony deadline 2, 2.
- July 11, 2025: Staff and intervenor direct testimony deadline 2, 2.
- July 28, 2025: Rebuttal testimony due from ComEd 2, 2.
- August 5, 2025: Staff and intervenor rebuttal testimony due 2, 2.
- August 12, 2025: ComEd surrebuttal testimony due 2, 2.
- August 27, 2025: Evidentiary hearing scheduled 2, 2.
- September 9–10, 2025: Initial and reply briefs due 2, 2.
- September 30, 2025: Draft order or position statements due 2, 2.
- October 10, 2025: Proposed order (estimated) due 2, 2.
- October 17, 2025: Simultaneous briefs on exceptions due 2, 2.
- October 30, 2025: Target date for final order at the regular open meeting 3, 3.

Data request turnaround times are set at 14 days, and status hearings have been scheduled as needed throughout the proceeding 4, 5.

Illinois Commerce Commission Docket 25-0514 concerns Commonwealth Edison Company's (ComEd) petition for approval of its second multi-year Performance Metrics Plan (PM Plan 2) for 2028-2031, as required under Section 16-108.18(e) of the Public Utilities Act. The plan outlines seven performance metrics related to reliability, equity, affordability, supplier diversity, peak load reduction, interconnection timeliness, and customer service. Each metric includes a description, calculation method, baseline, targets, and a schedule of incentives/penalties, generally up to ±5 basis points annually, with a linear calculation approach 1, 1.

Key issues in the docket include:

- ComEd's failure to provide complete net-benefit analyses or cost-benefit analysis (BCA) for several metrics, especially regarding affordability and reliability, limiting the Commission's ability to verify claimed benefits 2, 3, 2, 3.
- The affordability metric (PM5) aims for a 10% annual reduction in disconnections in 20 high-risk zip codes but lacks detail on the specific programs and their associated costs or benefits to achieve this target 4, 3.
- For certain reliability and resiliency submetrics, ComEd cites quantifiable and qualitative benefits but does not present monetized estimates or necessary cost data 2.
- There are recommendations for ComEd to provide detailed program plans and BCAs in the current docket rather than future filings, to allow for a complete evaluation of metrics' effectiveness and compliance with statutory requirements 3, 3.
- The docket also discusses future scheduling for PM plan updates and workshops to align metric adoption with rate plan and grid plan filings, aiming to ensure metrics remain relevant and data-driven 5, 5.

Overall, the docket reviews, critiques, and seeks improvements to ComEd’s proposed performance metrics framework for 2028-2031, emphasizing the need for transparency, detailed cost/benefit analysis, and structured planning to support the statutory goals of affordability, equity, and reliability for customers.

The docket raises several financial and timeline risks and concerns:

Financial risks and concerns:
- The penalty and reward structure for performance metrics may not be truly symmetric in practice, potentially making it easier for ComEd to earn incentives than to be penalized. The structure may not allow for the full penalty to be assessed if the baseline for load reductions is not sufficiently high at the start of the period, limiting downside risk and potentially leading to lower total reductions and higher administrative costs 1.
- The absence of a benefit-cost analysis (BCA) or net benefit methodology for affordability performance metrics creates uncertainty for the Commission and stakeholders, as it forces reliance on ComEd’s unsubstantiated assertions of net benefits, rather than verifiable, data-driven analysis. This lack of transparency and rigor increases the risk that approved metrics may not deliver genuine customer or societal value 2, 2.

Timeline risks and concerns:
- There is a concern that performance metrics (PMs) are being adopted years in advance of when they take effect. This reliance on outdated historical data can limit the relevance and effectiveness of metrics for driving performance improvements, as targets and incentives may not align with current system conditions or evolving utility practices 3.
- The process sequencing for updating PMs, grid plans, and rate plans can result in gaps between metric approval and implementation (three to seven years), making it difficult to ensure metrics remain meaningful and aligned with utility operations and customer needs over time 3.

Stakeholders in Commonwealth Edison Company's performance metrics docket (ICC Docket No. 25-0514) include:

Utility:
- Commonwealth Edison Company (ComEd) – The petitioner seeking approval of its proposed performance metrics under the Public Utilities Act 1.

Government/Regulatory:
- Illinois Commerce Commission (ICC) staff – Multiple staff members review, critique, and provide recommendations on ComEd’s proposals, including basis points, net benefit analyses, and customer service metrics 2.

Consumer and Advocacy Groups:
- Community Organizing and Family Issues (COFI), represented by the National Consumer Law Center (NCLC) – Intervened on behalf of low-income and working families impacted by utility policies 3.
- Environmental Defense Fund (EDF) – Intervened to promote clean energy, safety, reliability, affordability, and environmental protection in Illinois 4, 5.
- Environmental Law and Policy Center (ELPC), Natural Resources Defense Council (NRDC), and Vote Solar – Intervened to advocate for clean energy, affordability, DER deployment, reliability, and energy burden reduction, and were active in prior related dockets 6.

Other Intervenors (from context and excerpted lists):
- Citizens Utility Board (CUB) and Environmental Defense Fund (EDF) – Provided joint recommendations, particularly on load management and peak load reduction metrics 7.

Positions on Key Proposals:
- ICC Staff: Criticize ComEd for not providing sufficient benefit-cost analysis or details regarding how existing programs will achieve the affordability performance metric, and recommend ComEd provide detailed program, cost, and benefit information in the current docket rather than future ones. Staff also oppose proposals to assign zero basis points to supplier diversity metrics and recommend maintaining financial incentives/penalties 8, 8, 9.
- COFI/NCLC: Advocate for policies that benefit low-income and working families, likely supportive of strong affordability and equity measures 3.
- CUB-EDF: Recommend that ComEd’s load management metrics explicitly address energy efficiency and demand response co-deployment, and suggest tracking additional metrics related to peak load savings 7.
- ELPC, NRDC, Vote Solar: Support strong performance metrics that advance climate, equity, and affordability goals, and emphasize the importance of DER deployment and energy burden reduction 6.
- ComEd: Argues that a cost-benefit analysis is not statutorily required for the affordability metric, asserts no incremental costs for certain metrics but does not provide sufficient supporting detail according to staff critiques 8, 8.

Summary:
- ICC staff and several intervenors criticize ComEd’s lack of detail and analysis for certain metrics, especially affordability and supplier diversity, and recommend more robust documentation and continued financial incentives.
- Consumer and environmental groups generally advocate for stronger affordability, equity, clean energy, and data-driven approaches.
- ComEd maintains that some analyses are not required or that existing programs suffice, but faces opposition for not providing sufficient transparency or detail.

Based on the provided excerpts, the following areas of growth are identified in this docket, along with their key considerations:

1. Affordability Performance Metric (PM5) and Supporting Programs
- Growth Area: Expansion and improvement of programs to reduce disconnections for nonpayment in high-risk zip codes, with the aim of achieving annual reductions and equitable outcomes for lower-income and environmental justice communities.
- Key Considerations:
- ComEd did not provide a benefit-cost analysis (BCA) or a detailed net benefit methodology for its affordability metric, nor did it specify which existing programs will be used or if they will be available throughout the performance period. This lack of information makes it unclear how the company plans to achieve the metric and whether the proposed programs will deliver net benefits as required by statute.
- The Commission recommends that ComEd, in rebuttal, provide the specific programs, along with their costs and benefits, necessary to achieve the affordability metric so that parties and the Commission can properly evaluate their effectiveness and net benefit. Staff will oppose introducing essential programs for achieving the metric in future dockets if they are not included now 1, 1.

2. Net Benefits Analysis for Performance Metrics
- Growth Area: Enhancement of methodologies to quantify and verify the net benefits of performance metrics, including customer and societal costs and benefits, and impact on delivery rates.
- Key Considerations:
- The statute requires a methodology to calculate net benefits, but does not mandate a full cost-benefit analysis. Nevertheless, the Commission expects utilities proposing metrics to provide at least a net benefit methodology and, where possible, a BCA to support their metrics.
- The absence of verifiable cost and benefit data for proposed metrics forces the Commission to rely on the utility’s assertions without sufficient evidence. Future proceedings are expected to provide more robust net benefit methodologies, but current filings do not show improvement in this area 1, 1.

3. Customer Service and First Contact Resolution (FCR)
- Growth Area: Improvement in resolving customer inquiries on first contact, extending measurement to both residential and non-residential customers.
- Key Considerations:
- ComEd’s customer service metric currently excludes non-residential customers, even though they account for a significant number of contacts. Recommendations suggest expanding the metric to include all customer classes for a more comprehensive measure of service quality.
- The baseline and targets for improvement, as well as symmetrical incentives and penalties, are set based on previous years’ performance. This encourages ongoing incremental improvement year over year 2, 2.

4. Power Quality (PQ) Monitoring and Metrics
- Growth Area: Development of performance metrics and frameworks for tracking and improving grid power quality, specifically voltage and harmonic excursions.
- Key Considerations:
- Currently, ComEd lacks a consistent system-wide framework for monitoring power quality issues. Interim tracking is recommended to address gaps and risks to customers and grid efficiency.
- Future dockets should consider PQ performance metrics that allow for year-over-year trend verification and net benefit analysis under statutory requirements 3, 3.

5. Performance Metric Update Scheduling and Planning Integration
- Growth Area: Synchronizing the timing of performance metric (PM) updates with grid planning (MYIGP) and rate plan (MYRP) processes to ensure metrics remain relevant and actionable.
- Key Considerations:
- Challenges arise when PMs are adopted years in advance of their effective dates, leading to reliance on outdated data and reduced ability to incentivize meaningful improvements. Proposed solutions include aligning future PM workshops and dockets with MYIGP and MYRP filing cycles for better integration and responsiveness 4, 4.

In summary, the docket identifies growth in affordability metrics/programs, net benefit analysis, customer service metrics, power quality monitoring, and coordinated scheduling of performance metric updates. Key considerations for each area include data transparency, program specificity, comprehensive measurement, alignment with statutory requirements, and timely integration with planning processes.