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Exelon Corporation's Comments on Voltus Inc. and Mission Data v. PJM Interconnection, LLC

Strategic Insights

— 2 min read

In a recent submission to the Federal Energy Regulatory Commission (FERC), Exelon Corporation's affiliates, Commonwealth Edison Company, Potomac Electric Power Company, and PECO Energy Company, provided comments on the Complaint of Voltus, Inc. and Mission Data regarding data access issues in the electric distribution system. The Exelon Utilities argue that the Complaint misconstrues their positions and practices, and that state laws and regulations govern the access to customer data, including Critical Energy/Electric Infrastructure Information (CEII). The Exelon Utilities acknowledge the importance of data access but highlight the need for cost and security measures, which are the purview of state commissions.

Key Takeaways:

  • The Exelon Utilities adhere to state laws and regulations to safeguard customer data, including complying with CEII handling practices.
  • The Complaint concedes that regulation of customer data access is the province of the states.
  • The Exelon Utilities acknowledge the desire for data access but highlight the importance of cost and security measures.
  • The Exelon Utilities take no position on the requested relief but remain committed to working with third parties in a manner that conforms to regulatory requirements regarding data access.
  • The states, including the Illinois Commerce Commission, have evaluated and are actively evaluating the Green Button program and various data access provisions.
  • The Exelon Utilities estimate that implementing a Green Button Connect arrangement in Maryland would cost around $12.2 million over an initial five-year period.

Statistics:

  • 4% of potential customers were unable to complete the enrollment process due to ComEd's two-factor authentication (Complaint at 13).
  • Less than 20% of PECO accounts registered due to PECO's use of two-factor authentication (Complaint at 8).
  • $9.2 million: estimated upfront implementation cost for a Green Button Connect solution in Maryland (Exelon Utilities estimate).
  • $3 million: ongoing maintenance costs for a Green Button Connect solution in Maryland (Exelon Utilities estimate).
  • 50%: variability in estimated costs for implementing a Green Button Connect solution in Maryland.
  • 5-year: initial period for implementing a Green Button Connect solution in Maryland.

Sources:

  • Voltus, Inc. and Mission Data v. PJM Interconnection, LLC, Docket No. EL26-4, FERC.
  • Commonwealth Edison Co., ICC Docket Nos. 22-0486/23-0055/24-0181, Exelon Corporation and NGOs' MOU Update, December 23, 2024.
  • Exelon Corporation Comments on Voltus Inc. and Mission Data v. PJM Interconnection, LLC, FERC.
  • Illinois Commerce Commission, Docket Nos. 17-0123, 13-0506, 14-0507, 14-0701, and 15-0073.
  • Exelon Corporation, Senior Paralegal Geneva Kennedy, and Associate General Counsel Cynthia L.M. Holland.

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