ComEd Files to Offer Peak-Time Rebate to Customers, Seeks Guidance on Sharing Info with Retail Suppliers

Commonwealth Edison has filed with the Illinois Commerce Commission tariffs to implement a peak-time rebate (PTR) program for residential customers.

The peak-time rebate program, required by statute, would be an opt-in demand response program that will provide bill credits to participating residential customers for kilowatt-hours of estimated energy reduction (versus a baseline) achieved by such customers during specific periods of time.

PTR participants that elect to curtail their electric usage during a called event will receive a bill credit of $1.00 per reduced kWh on a subsequent ComEd bill. There is no penalty for not taking any curtailment action, and the customer's generation rate is not affected.

ComEd will fund the bill credits with compensation from participation in PJM's demand response programs, including bidding into the Base Residual Auction.

ComEd's peak-time rebate program will be available to all residential customers with AMI meters on a competitively neutral basis, meaning the customer may participate regardless of whether they are receiving electric power and energy supply from ComEd or a Retail Electric Supplier.

However, in order to participate in ComEd's PTR program, the residential customer must not be participating in a third-party demand response program or energy curtailment program that is coordinated with PJM.

ComEd reported that during stakeholder discussions, it received requests to disclose to a customer's retail electric supplier whether that customer has elected to participate in ComEd's peak-time rebate program. This disclosure would occur through a posting on ComEd's PowerPath website.

ComEd noted that, pursuant to Section 16-122 of the PUA, ComEd is required to provide, upon request, to any customer or to a retail electric supplier, acting as the agent for a customer, the customer's billing and usage data. However, that same section prohibits ComEd from providing any customer-specific billing, usage or load shape data without customer authorization.

ComEd said that it is unclear as to whether the PTR participation information constitutes customer billing information that ComEd is prohibited from providing under Section 16-122 except with the authorization of the customer.

ComEd noted that access to such information on the PowerPath website is only available to a retail supplier that knows the confidential customer identification number of the customer and which the retail supplier presumably obtains voluntarily from the customer.

Therefore, ComEd sought clarification from the ICC as to whether it may post on its PowerPath website information concerning the decision of individual customers to participate in ComEd's PTR program notwithstanding the restrictions of Section 16-122.

Furthermore, ComEd would require retail suppliers to identify to ComEd any retail customer that is participating in a PJM-coordinated electric (a) demand response program or (b) energy curtailment program offered by such retail supplier.

ComEd said that, initially, it will recover the costs of the startup and administration of the PTR program from all residential customers through rates for delivery service. ComEd reserves its right to propose alternative cost recovery and cost allocation methodologies in the proceeding required by Section 16-108.6(g) of the PUA to evaluate ComEd's PTR program.

ComEd is seeking Commission approval of its PTR program no later than March 1, 2013, in order for ComEd to participate in PJM's Base Residual Auction to be held in May 2013 for the 2016-2017 delivery year.