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ComEd Withdraws Proposed VPP Tariff
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Commonwealth Edison in Illinois has withdrawn a proposed tariff for a VPP program (Rider VPP), and also withdrew its proposed Rider Community Solar Plus Storage (Rider CSS) tariff, and Rider Bring Your Own Device Load Reduction (Rider BYODLR) tariff, citing the recent passage of legislation which still awaits action by the Illinois governor
As previously reported, Rider VPP would have been limited to customers taking ComEd's hourly priced default service (see background here)
ComEd noted that, on October 30, 2025, the Illinois legislature passed the Clean and Reliable Grid
Affordability (CRGA) Act, SB0025 Enrolled. The CRGA Act, which is pending action by the
governor, would be effective June 1, 2026.
ComEd said, "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."
ComEd said that, more specifically, the CRGA Act requires that applicable utilities, such as 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)).
ComEd said, "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."
ComEd said, "While the Governor has not signed the CRGA Act, ComEd believes that it is prudent and
reasonable for ComEd to consider the impacts of the CRGA Act’s provisions on ComEd’s
three proposed tariffs and determine if the programs need to be revised or merged, and/or
if new and materially different programs are needed, to comply with CRGA."
Upon termination of the ICC proceeding addressing ComEd's previously proposed tariffs, ComEd said that, "ComEd fully
intends to engage Staff and all parties and any additional stakeholders on a collective and,
as needed or warranted, individual basis to collaborate regarding new tariffed programming
that meets the requirements of the CRGA Act."
"More specifically, following the withdrawal and termination, ComEd intends to revisit and
revise its proposals in light of both the CRGA and feedback received on prior proposals
and present stakeholders in the case with an updated scheduled dispatch proposal in
February 2026," ComEd said
ComEd also said, "While CRGA does not require the filing of ComEd’s scheduled dispatch proposal until
June 1, 2026 and does not require the filing of a Bring Your Own Device or smart
thermostat program, upon withdrawal and termination of this proceeding, ComEd commits
to (1) file its scheduled dispatch program proposal under 107.6 no later than April 1, 2026;
and (2) including in such filing a revised Bring Your Own Device or smart thermostat
program either as a complement to or a part of ComEd’s scheduled dispatch proposal."
Docket 25-0678
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November 18, 2025
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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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