Download ICEA’s Regulatory Advocacy History – December 2019… (PDF)

Initial Brief on Behalf of the Illinois Competitive Energy Association

The Illinois Competitive Energy Association, pursuant to Section 200.800 of the Illinois Commerce Commission’s (“Commission”) Rules of Practice (83 Ill. Admin. Code § 200.800), respectfully submits this Verified Initial Brief in the above-captioned Docket. The Commission should reject ComEd’s proposed Rate RTOUPP, reject ComEd’s proposed Integrated Distribution Company (“IDC”) rule waiver, and adopt ICEA’s proposed data access approach.

I. INTRODUCTION

While ARES face multiple barriers to offering time variant supply products and services, no barrier is more important than inadequate access to interval data for pricing customers. Whether because of that or other barriers, the record in this docket reflects that the competitive retail market for time-variant products and services has not developed the way any stakeholder would have liked.

The best solution to this problem is to identify and eliminate barriers to ARES offering time-variant products and services. The Commission has repeatedly stated its desire for an investigation into barriers if the competitive retail market does not develop as hoped. ICEA has already identified a significant barrier: challenges to ARES accessing interval data in an efficient or cost-effective manner. ICEA proposes a limited, but practical, solution to that barrier in the present docket: require ComEd to use AMI interval data as the standard for billing and settlement data.

Read the FULL Initial Brief here… (PDF)

Initial Brief | Reply Brief | Final Order
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Response Comments on Behalf of the Illinois Competitive Energy Association

The Illinois Competitive Energy Association, pursuant to the Administrative Law Judge’s (“ALJ”) Ruling dated May 3, 2018 (“Ruling”), respectfully submits these Verified Response Comments in response to Supplemental Initial Comments filed on July 13, 2018. ICEA specifically responds to CUB/EDF, Elevate, Mission:data, Ameren, and ComEd. No party has adequately addressed or ameliorated the fatal legal shortcomings raised by the AG and ICEA in their respective motions to dismiss (collectively “Motions to Dismiss”), by Ameren in response to the Motions to Dismiss, or ComEd in Supplemental Initial Comments. While CUB/EDF, Ameren, and Mission:data have proposed alternatives in Supplemental Initial Comments, none of these alternatives sufficiently address the fatal legal shortcomings raised by the AG or ICEA.

In light of the continued shortcomings of the proposals in the record, ICEA recommends that the Commission reconsider granting the Motions to Dismiss. In the alternative, ICEA recommends that the Commission enter an order finding that no proposal before it sufficiently meets the legal standard set out in ICC Docket No. 15-0073 for adopting a non-RES third party bulk warrant process.

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Response Comments | Reply Comments | Surrebuttal Comments | Final Comments | Position Statement
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Initial Brief on Behalf of the Illinois Competitive Energy Association

The Illinois Competitive Energy Association, pursuant to Section 200.800 of the Illinois Commerce Commission’s (“Commission”) Rules of Practice (83 Ill. Admin. Code § 200.800) and the case schedule set by the Administrative Law Judge, respectfully submits this Verified Initial Brief in the above-captioned Docket. The Commission should protect the integrity of the competitive retail electric market and its own functional separation rules by stopping ComEd from using interval data without customer consent in a manner that is inconsistent with law and policy.

ICEA has two recommendations: First, the Commission should reject ComEd’s proposed changes to Rate RRTP because ComEd is proposing an anti-competitive program whose justifications do not withstand scrutiny. The proposed program’s fatal legal and policy flaws are independently sufficient for the Commission to reject ComEd’s proposal.

Second, the Commission should order ComEd to use interval data from AMI meters for billing and settlement of all customers. ICEA expects this step to remove the primary barrier to alternative retail electric suppliers (“ARES”) offering more time-of-use and dynamic-priced retail energy products that allow customers to get value from their advanced meters.

Read the FULL Initial Brief here… (PDF)

Initial Brief | Reply Brief | Brief on Exceptions | Final Order
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