Comed Filing Packagepdf
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April 16, 2021 Kimberly Bose Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C., 20426 Re: Commonwealth Edison Company and Commonwealth Edison Company of Indiana, Inc., Informational Filing of Formula Rate Annual Update Docket No. ER09-1145-000 Dear Secretary Bose Attached for informational purposes in the above-referenced proceeding, please find the 2021 Annual Update of Commonwealth Edison Company (“ComEd”). This informational filing is required pursuant to the Settlement Agreement approved by the Federal Energy Regulatory Commission (“Commission”) on January 16, 2008 in Docket No. ER07-583,1 and Section 1(b) of the Formula Rate Implementation Protocols in Attachment H-13B of PJM Interconnection, LLC’s (“PJM”) Open Access Transmission Tariff (“OATT”). Under Attachment H-13B and the Settlement Agreement, on or before May 15 of each calendar year ComEd recalculates its Annual Transmission Revenue Requirement and submits an Annual Update for the upcoming Rate Year. See Attachment H-13B §§ 1(a)-(b). The Annual Update is to be submitted to the Commission as an informational filing each rate year.2 The March 12, 2010 Letter Order accepting ComEd’s 2009 Annual Update established the procedure for the Annual Update filings: This letter also advises ComEd that annual updates in the forthcoming years should be submitted, for informational purposes only, in Docket No. ER09- 1145-000. Upon receipt, the Commission will not act on or notice the informational filing because the formula rate implementation protocols provide specific procedures for notice, review, and challenges to the annual updates.3 1 Commonwealth Edison Co., 122 FERC ¶ 61,030 (2008) (“January 16 Order”) 2 The protocols require that ComEd submit the Annual Update by May 15 of each rate year, unless the date for making the Annual Update falls on a weekend, then the filing may be made on the next business day. See ComEd Protocols, § 1.c. 3 Letter Order Accepting Commonwealth Edison Company’s 5/15/09 filing of the 2009 Formula Rate Annual Update, Docket No. ER09-1145 (Mar. 12, 2010). 1 Attachment 1 to this Annual Update is a copy of the ComEd formula rate (Attachment H- 13A to the PJM OATT) populated with 2020 inputs. This populated formula rate will be used by PJM to determine charges for service to the ComEd zone during the June 1, 2021 through May 31, 2022 rate period. A copy of this document in Excel format is being provided along with service of this Annual Update to the persons on the official service list in ComEd’s last rate case, Docket No. ER07-583, as well as the Manager of Accounting of the Illinois Commerce Commission (“ICC”). ComEd has requested PJM to post this filing on the PJM website. As required by the implementation protocols, notice of an Annual Meeting to be held on June 5, 2020 also is being provided on the PJM website. The Annual Meeting will permit ComEd to explain the Annual Update and will provide interested parties an opportunity to seek information and clarifications about the Annual Update. I. Required Information ComEd has prepared the 2021 Annual Update in a manner consistent with its protocols, as set forth in Attachment H-13B of the PJM Tariff, and reflecting the guidance issued by Commission Staff on July 17, 2014.4 Section 1(g)(iii) and (iv) of the Protocols and Section 4.7 of the Settlement Agreement identify certain information that is to be provided in the Annual Update. This information is provided herein and in the referenced attachments. Consistent with Commission Staff guidance, in addition to the PDF package, ComEd is submitting the formula templates and attachments/workpapers in Excel format, with the formulas intact.5 Additional information provided to be consistent with the Staff Guidance is included as Attachment No. 15.6 A. 2020 FERC Form No. 1 In accordance with Section 1(g)(iii)(1), a copy of ComEd’s FERC Form No. 1 is available for download through the Commission’s elibrary, accessible at elibrary.ferc.gov. ComEd submitted the 2020 FERC Form No. 1 to FERC on March 26, 2021. B. Changes to Formula References to the FERC Form No. 1 In accordance with Section 1(g)(iii)(2), ComEd has identified one change in the formula references to the FERC Form No 1. Attachment 2, which serves as the placeholder for this protocol item identifying this change. The change relates to new depreciable asset sub- categories related to FERC Account 397 – Communications Equipment which was added to FERC Form 1. Accordingly, the instruction for the calculation on Attachment 5, Line 88 of the 4 See Staff’s Guidance on Formula Rate Updates, available at http://www.ferc.gov/industries/electric/indus-act/oatt- reform/staff-guidance.pdf. 5 See Staff Guidance at 1 (“Format”). 6 On November 21, 2019, the Commission issued Order No. 864 . Public Utility Transmission Rate Changes to Address Accumulated Deferred Income Taxes, Order No. 864, 84 Fed. Reg. 65,281, 169 FERC ¶ 61,139 (2019). The ER19-5 Settlement provides that the formula rate reflected in this Annual Update include all the information and rate modifications required in Order No. 864. ER19-5 Settlement, at P 3.4. 2 Formula Rate which includes FERC Account 397 – Communications Equipment has been updated to include the additional FERC line item. C. Adjustments to FERC Form 1 Data in Formula Inputs Section 1(g)(iii)(3) of the Protocols requires identification of any adjustments to FERC Form No. 1 data in determining formula inputs. In 2012, the Commission approved the merger of Exelon Corporation (“Exelon”), which is ComEd’s parent company, and Constellation Energy Group, Inc. (“Constellation”) and their respective public utility subsidiaries. Exelon Corp., 138 FERC ¶ 61,167 (2012) (“Constellation Approval”). On November 20, 2014, the Commission approved the merger of Exelon and Pepco Holdings, Inc. (“PHI”) and their respective public utility subsidiaries. Exelon Corp., 149 FERC ¶ 61,148 (2014) (“PHI Approval”). As part of their applications to the Commission for authorization to merge, the companies committed to hold transmission customers harmless for five years from costs related to the merger. The Commission accepted these hold harmless commitments. See Constellation Approval at P 118; PHI Approval at P 105. The five-year commitment to hold customers harmless from costs related to the 2012 Constellation merger expired in 2017, however ComEd has elected to continue to remove those merger related costs from the 2021 filing. Consistent with the hold harmless commitment for the PHI merger, no transaction-related costs or transition costs related to that merger are included among the costs to be recovered through the 2021 Annual Update. Accordingly, ComEd has adjusted inputs from the FERC Form 1 to remove merger-related costs. These adjustments are detailed in Attachment No. 15. Consistent with the Commission’s Orders, recovery of excluded merger costs will occur only upon the Commission’s acceptance of a filing seeking recovery of the costs made pursuant to the instructions in the Commission’s Orders. ComEd made an adjustment to the FERC Form 1 data reported on Appendix A, Line 60 (transmission lease payments). The FERC Form 1 entry includes the lease payments related to the distribution equipment housed in the Willis Tower. The amount reported in the FERC Form 1 is properly recovered from ComEd’s retail customers, and thus has been excluded from the transmission formula rate. The details of these adjustments are included in Attachment No. 15, which consistent with the Staff Guidance, also includes supporting documentation for the formula rate entry for Attachment 5, Line 65, which is not sourced from the FERC Form 1. Additionally ComEd has included adjustments required by the ER19-5 Settlement. The support for the ER19-5 Settlement adjustment is included in Attachment No. 15. D. 2020 ICC Annual Report In accordance with Section 1(g)(iii)(4) of the Protocols, a copy of ComEd’s 2020 Annual Report filed with the ICC (Form 21) is included as Attachment No. 3. E. Statement Regarding Certain Rate Filings with any Federal, State, or Other Regulatory Body that has Jurisdiction 3 Section 1(g)(iii)(5) of the Protocols requires a statement describing the extent to which operating revenues are subject to refund for the period covered by the Annual Update for each rate change filed with any federal, state or other regulatory body that has jurisdiction, as well as copies of any orders in which applications for a rate increase have been acted on by any regulatory body during the period covered by the Annual Update and a copy of any transmittal letter or equivalent written document by which ComEd summarized and submitted any pending applications that have not been acted upon. ComEd did not record any revenues subject to refund in 2020. F. Reconciliation of Monthly Peak Demands Section 1(g)(iii)(6) of the Protocols requires a reconciliation of monthly peak demands shown on FERC Form No. 1 and monthly peak demands used in the formula. The 2020 ComEd Zonal Peak Load reported by PJM is 20,220 MW and matches the peak load reported on page 401b of the 2020 FERC Form No. 1. No reconciliation is necessary. G. Uniform System of Accounts Itemization Section 1(g)(iii)(7) of the Protocols requires an itemization of each of the following accounts of the Uniform System of Accounts by sub-account: i. Account 165 – Prepayments. See Attachment No. 4. ii. Account 454 – Rent From Electric Property. See Attachment No. 5. iii. Account 456 – Other Electric Revenues. See Attachment No. 6. iv. Account 303 - Miscellaneous Intangible Plant. See Attachment No. 7. v. Account 397 - General Plant (Communications Equipment).