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ComEd's $3 Billion Data Center Hookup Bill: Who Pays the $2 Billion Gap?
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ComEd's $3 Billion Data Center Hookup Bill: Who Pays the $2 Billion Gap?

Ryan Cook•

ComEd expects to spend more than $3 billion upgrading its grid to hook up 30 large-load projects like data centers, and what those projects have put up covers just under 25% of it. That's the finding of expert testimony filed in Illinois Commerce Commission Docket 26-0364 by the Citizens Utility Board and four other groups, which CUB made public on October 22, 2026. Their math leaves a potential gap of more than $2 billion, and the ICC now has to decide whether the rest of ComEd's customers end up covering it.

Nobody's bill changed this week. But this case decides who pays for substations and power lines being built right now, and grid costs stay on bills for decades. Here's what's in the filing, what ComEd's current rules actually cover, and when a decision should come.

The numbers in the filing

What Figure Source
Large-load projects on the ComEd list reviewed 30, interconnected or requesting service 2021–2031 Testimony in ICC Docket 26-0364 (CUB release, Oct. 22, 2026)
Transmission and distribution upgrades they need More than $3 billion (ComEd's estimate) Same
Deposits data centers have paid About $720.9 million CUB release, Oct. 22, 2026 (citing ComEd's records)
Share covered by deposits and advance payment commitments Just under 25% Same
Potential shortfall More than $2 billion Same
Newer large-load projects not on that list 60 more Same
ComEd's large-load pipeline in March 75 applications whose combined maximum demand tops ComEd's all-time peak ICC press release, Mar. 20, 2026
ComEd's large-load rules In effect since Mar. 31, 2026 (ICC Dockets 25-0677/25-0679) ComEd tariff, General Terms and Conditions
ComEd price to compare 6.612¢/kWh (Oct. 2024) → 10.103¢/kWh (Oct. 2026), about +53% ICC historical price table

The testimony's author, energy consultant James Fine, put it bluntly: "This leaves a very large gap." He added that the $3 billion "is an estimate—the actual number could be much larger as a result of cost overruns or facilities that ComEd did not include in its total."

One fairness note. These are the advocates' reading of ComEd's records. ComEd gets to respond in the same case, and I haven't seen its answer yet.

Doesn't ComEd already make data centers pay deposits?

It does, and it's worth knowing what those deposits actually cover.

The ICC approved ComEd's large-load rules in March, and the tariff sheets took effect March 31, 2026. They apply to any project expected to reach 50 megawatts or more within ten years. Here's what ComEd's own tariff requires:

  • An engineering deposit of $1 million, plus $500,000 for each additional whole 100 MW above 200 MW. Anything over $2 million has to be backed by a letter of credit.
  • A materials deposit covering long-lead equipment ComEd orders for the project.
  • A Transmission Security Agreement guaranteeing the customer's transmission payments won't fall below its promised load ramp for ten years. If they do, the difference is collected from that customer and credited back to transmission customers in the ComEd zone.

The catch: both deposits come back. ComEd refunds the engineering deposit when service starts or when the customer posts its line-extension deposit under ComEd's Rider DE, whichever comes first, and the materials deposit once permanent service begins and any Rider DE deposit is posted. Either way, ComEd keeps only the costs actually charged against them. They protect ComEd and its customers if a project is canceled midway. They aren't built to pay for a substation. The advocates' "just under 25%" already counts every deposit and advance payment commitment together. That's how a $1 million deposit and a $3 billion buildout can sit side by side.

My take: the ten-year transmission guarantee is the strongest protection in there, and it's a real one. But substations and high-voltage lines last a lot longer than ten years.

The ICC saw the gap too. Its March 20 release said the new investigation would cover "costs and benefits of infrastructure attributable to large load projects and facilities, including proper cost allocation." Chairman Doug Scott called it "a first step toward investigating how Illinois' largest electric utility can serve large load customers while preventing undue cost shifts."

How data center costs could reach your bill

There are two roads, and they're easy to mix up.

The wires. Utilities don't bill a grid upgrade all at once. They recover it over many years through delivery and transmission rates. If a data center doesn't fully pay for its own hookup, what's left can end up in the rates everyone pays. That's the risk this case is about, and CUB says ComEd's customers are already paying for at least part of the $3 billion.

The power itself. This one is already on your bill. ComEd's price to compare went from 6.612¢ in October 2024 to 10.103¢ in October 2026, about 53% higher, per the Commerce Commission's price table. CUB ties that jump to projected data center demand. My data centers and your electric bill breakdown walks through the capacity-auction side.

For a sense of scale, CUB puts ComEd's customer count at more than 4 million. Split $2 billion evenly and it's roughly $500 per account. That isn't what any household would actually pay. Costs get divided among residential, business and industrial customers and spread over decades. But it shows why this docket is worth watching.

What the advocates want

The filing came from CUB, the Environmental Law & Policy Center, the Natural Resources Defense Council, Vote Solar and the Union of Concerned Scientists. Their main asks:

  1. Data centers pay 100% of their grid-connection costs up front.
  2. A large-load tariff that's "fully protective of existing customers," with minimum monthly fees and exit fees.
  3. Interruptible service: a data center that doesn't bring its own new clean energy could have its power reduced when demand peaks.

I agree with the first one. If a project needs a $100 million substation, the people asking for it should pay for it. Ask any homeowner who's paid for their own driveway.

When it gets decided

The ICC said it would open the investigation by April 23, 2026 and finish within eight months of opening it. If that holds, expect a decision around the end of 2026. That's my estimate, not a date the ICC has published. ComEd also owes the ICC its first annual large-load compliance report on February 1, 2027.

The statehouse is the other track. The POWER Act, House Bill 5513 and Senate Bill 4016, would require utility tariffs to make sure the investments needed to serve hyperscale data centers, including lines above 100 kilovolts, "are allocated to those customers and are not socialized to other rate classes." It hasn't passed. My POWER Act and FERC post covers the bill and the fall veto session.

What you can control while regulators argue

You can't vote in Docket 26-0364. What you can decide is how much of your power you buy from ComEd at all.

Solar won't stop a data center from plugging in, and it won't erase your delivery charges. What it can do is replace a big share of the supply side of your bill, the part that's already up about 53% in two years. A $0-down solar lease swaps much of that for a predictable rate as low as $0.10/kWh, with your full 25-year rate schedule written into the contract before you sign. If you'd rather own, I'll price a cash system next to it, and income-qualified households can look at Illinois Solar for All. Whether any of it beats your bill depends on your roof and your usage, and every figure here is an estimate until it shows up on a real bill.

Current numbers live on my ComEd rates page, and why your ComEd bill is so high breaks down every line. For November's bill specifically, see the 3.758¢ November charge. Run your numbers on the savings calculator, or call me at (618) 217-2001 or use the contact page. I'll update this post when the ICC rules.

Sources

Frequently Asked Questions

Partly, according to consumer advocates, and the Illinois Commerce Commission is now deciding how much. Testimony filed in ICC Docket 26-0364, made public by CUB on October 22, 2026, says ComEd's records show 30 large-load projects needing more than $3 billion in transmission and distribution upgrades. Deposits and advance payment commitments from those projects cover just under 25% of that, which leaves a potential gap of more than $2 billion. The groups behind the filing, led by the Citizens Utility Board, say ComEd's customers are already paying for at least part of it through their rates. Data centers do pay deposits under rules the ICC approved in March 2026, but those deposits are mostly refunded once service starts. ComEd can respond to the testimony in the same case. Until the ICC rules, treat the $2 billion as the advocates' reading of ComEd's numbers, not a final finding.
It's the set of rules ComEd uses for customers expected to reach 50 megawatts or more within ten years, which in practice means mostly data centers. The ICC approved it in Dockets 25-0677 and 25-0679, and ComEd's tariff sheets took effect March 31, 2026. The rules require an engineering deposit of $1 million plus $500,000 for each additional whole 100 MW above 200 MW, backed by a letter of credit above $2 million. A separate deposit covers long-lead materials ComEd orders for the project. A Transmission Security Agreement guarantees the customer's transmission payments won't fall below its promised load ramp for ten years. Both are refunded minus actual costs: the engineering deposit when service begins or a line-extension deposit is posted, the materials deposit after permanent service begins and any line-extension deposit is posted. In announcing the approval, the ICC called it a first step and ordered a broader investigation into cost risks; CUB identifies that case as Docket 26-0364.
They already affect it on the supply side, and the open question is the delivery side. ComEd's price to compare rose from 6.612 cents per kWh in October 2024 to 10.103 cents in October 2026, about 53%, per the Illinois Commerce Commission's price table, and the Citizens Utility Board ties that increase to projected data center demand. The new testimony is about the wires. If more than $2 billion in data center hookup costs isn't covered by the data centers themselves, advocates warn it could flow into the delivery and transmission rates every ComEd customer pays. Those costs would be recovered over many years, not in one bill, and nobody has calculated a per-household figure. The ICC's investigation and the POWER Act at the statehouse will decide how much of that risk stays with data centers and how much lands on everyone else.
There's no fixed date yet, but the ICC's own timeline points to around the end of 2026. In its March 20, 2026 release, the Commission said it would open a docketed investigation by April 23, 2026, and that the investigation should be completed within eight months of its start. CUB identifies that case as Docket 26-0364, where the advocates' testimony was filed. If it holds to that schedule, a decision would land late this year or early next, though that's my estimate, not a date the ICC has published. Separately, ComEd has to file its first annual large-load compliance report on February 1, 2027. At the statehouse, the POWER Act, House Bill 5513 and Senate Bill 4016, could move in the fall veto session in November and December. Either path could change who pays for future hookups, but neither changes your current bill right away.
They want data centers to pay the full cost of connecting to the grid, up front. The testimony filed in Docket 26-0364 on behalf of the Citizens Utility Board, the Environmental Law & Policy Center, the Natural Resources Defense Council, Vote Solar and the Union of Concerned Scientists recommends that large customers pay 100% of their grid-connection infrastructure in advance. It also calls for a large-load tariff that is fully protective of existing customers, using minimum monthly fees and exit fees so a project that shrinks or leaves still covers its share. Separate testimony asks for interruptible service, meaning a data center that doesn't bring its own new clean energy could have its service reduced at peak demand. The groups also back the POWER Act, which as introduced would require utility tariffs to assign the cost of serving hyperscale data centers, including high-voltage lines, to those customers instead of socializing it to other rate classes.

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A family of four can earn $97,200 in Cook County and still qualify. Here are the county numbers.Will Illinois Have Rolling Blackouts? What ComEd's 'Critical Level' Alerts Mean (2026)ComEd told parts of Chicagoland the grid hit a 'critical level' during the July heat wave. Here's the honest answer on rolling blackout risk in Illinois — and what you can control.Freedom Forever Filed for Bankruptcy — What Illinois Solar Customers Should Do NowFreedom Forever filed Chapter 11 in April 2026. If your Illinois solar system is installed, unfinished, or under quote — here's exactly what to do next.ComEd & Ameren Want Another Rate Hike — CUB Found $1 Billion in Questionable SpendingComEd filed a $15.3B grid plan and Ameren wants millions more — CUB found over $1 billion in questionable spending. What the next IL rate hikes mean for you.What Solar Panels Really Cost in Illinois in 2026 (Honest Numbers, No Lead-Selling)What solar panels actually cost in Illinois in 2026 — real per-watt and per-system numbers, what changed this year, and why we don't sell your info to five callers.Illinois Electric Rates Keep Climbing — Does Solar Finally Make Sense in 2026?Ameren and ComEd rates are up ~90% in five years and still climbing. Here's how to see what you're on track to overpay — and whether solar finally makes sense.Illinois Net Metering Changed in 2025 — What It Costs You and How to Protect Your SavingsIllinois ended full retail net metering on Jan 1, 2025. Here's what the switch to net billing actually costs solar owners — and how to protect your savings.The 30% Solar Tax Credit Ended — Here's How Illinois Homeowners Still Get It in 2026The 30% federal tax credit ended for homeowner-owned systems on Dec 31, 2025. Here's how Illinois homeowners can still capture federal solar value in 2026.How Much Does a Solar Lease Cost Per Month in Illinois? (2026)What does a solar lease actually cost per month in Illinois? Real 2026 numbers, what's included, and how a predictable lease rate compares to a rising utility bill.Ameren vs ComEd 2026: Which Costs More Per kWh? (ComEd Runs ~1.5¢ Higher)ComEd averages ~17¢/kWh, Ameren Illinois ~15.5¢/kWh. See the full 2026 breakdown: supply charges, delivery fees, summer spikes, and how much it costs per month.Ameren Rate Increase 2026: Summer Rate Ends — Oct 1 Price to Compare Is 10.441¢ (ComEd 10.103¢)Updated September 30, 2026: the Ameren rate increase put the summer Price to Compare at 11.326¢/kWh (ComEd 10.399¢) through September 30; from October 1 it is 10.441¢ (ComEd 10.103¢). See the average Illinois electric rate now, why bills jumped June 1, and what changed October 1.The Iran War Is Sending Oil Prices Through the Roof — Will Your Illinois Electric Bill Follow?Oil is at $112/barrel after the Strait of Hormuz blockade. Here's how the Iran conflict could push Illinois electricity rates even higher — and what you can do now.Why Your Ameren Bill Keeps Going Up (and What MISO Has to Do With It)Ameren bills jumped 18-22% in summer 2025 and rose again June 1, 2026. Here's why MISO capacity auctions are driving your rates up and what you can do about it.The Real Cost of Solar Panels in Illinois: 2026 BreakdownWhat do solar panels actually cost in Illinois in 2026? Real numbers for cash purchase, lease, and Solar for All — from an installer who gets prices below the state average.Selling a House With Leased Solar Panels in Illinois (2026 Guide)Selling a house with leased solar panels in Illinois? Here's how the lease transfer works, what buyers actually think, and why it's not the problem most people expect — owned systems too.Solar Lease vs Buying Panels: I Did the Math for IllinoisShould you lease or buy solar panels in Illinois? I broke down the real numbers for both paths using current 2026 prices, incentives, and Ameren/ComEd rates.Data Centers = 70% of Illinois's Rate Spike (Here's What It Costs You)Data centers drove 70% of Illinois's capacity-cost spike in 2026. See the PJM/MISO mechanism, the per-household cost impact, and what to do to protect your bill.ComEd Rate Increase 2026: Oct 1 Supply Drops to 10.103¢, but Delivery Didn'tUpdated Oct 2026: ComEd's 2026 rate increase put the Price to Compare at 10.399¢/kWh through September 30; from October 1 it is 10.103¢/kWh. What changed June 1, what reset October 1, the ICC delivery increases that didn't reset, and your all-in cost per kWh.Illinois Electricity Rates Have Nearly Doubled Since 2021 — Here's What That Means for Your BillIllinois electricity rates have surged 90%+ since 2021. Here's what's driving the increases, what to expect next, and how to protect your household.Illinois Solar Incentives 2026: 7 Programs Worth $12,000-$18,000+Illinois solar incentives 2026: Illinois Shines RECs, the new $20/REC customer-owned adder, $300/kW DG rebate, battery rebate, net metering, and property tax exemption — worth $12,000-$18,000+ on an owned system. Plus no-cost Solar for All for income-eligible households.Solar Battery Backup in Illinois — What It Actually Powers and Whether It's Worth ItWhat does a solar battery actually run during an outage? How much does it cost with the $300/kWh rebate? Here's the honest breakdown for Illinois homeowners.
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