Most tariff riders tell you what you will be paid. ComEd's Rider VLR does not, and that absence is the most important thing on the page.
The Voluntary Load Response and System Reliability Program pays nonresidential customers to reduce demand when ComEd asks. The filed rider describes the events, the measurement, the eligibility and the payment schedule in detail. On the rate, it says compensation may be offered in an amount greater than zero dollars per kilowatt hour, determined by ComEd based on its assessment of the circumstances at the time of the event.
That is the whole rate provision. Greater than zero, decided later, by the counterparty.
What the rider does commit to
The unpriced compensation is unusual. The rest of the terms are specific and several of them are favourable.
A 10 kW minimum. You must commit to reducing at least ten kilowatts, and you are not eligible for payment on an event unless you meet that minimum. For most commercial sites this is a low bar; for a small retail unit it may not be.
Half-hour interval metering, or a waiver. You need meter facilities capable of recording kilowatt hours and the half-hourly kilowatt rate, or a written ComEd waiver where another acceptable measurement method is in place. This is the same infrastructure that produces your demand charge.
Events run two to eight hours, with about an hour of notice. The rider sets a floor of two hours and says events are generally no more than eight, though they may run longer to relieve localized congestion.
No penalty for not delivering. This is the clause that changes the risk profile completely. The rider states that ComEd does not assess noncompliance charges to a participant that fails to provide its committed reduction after being notified. You commit to ten kilowatts, and if an event lands during your busiest hour of the year and you cannot respond, nothing happens to you.
You can leave at any time, and you can negotiate. The rider expressly permits a participant, or a group acting through a common representative, to hold a customized load reduction agreement with mutually agreed terms accommodating operating limitations and providing for payments consistent with the nature of the reduction.
Payment arrives once a year. A single payment by December 31, covering accrued compensation for events in the twelve months ending September 30. Treat it as an annual rebate rather than as cash flow.
You do not have to buy your electricity supply from ComEd to participate.
The provision that catches aggregated sites
If your load is already committed somewhere else, it does not count here.
The rider excludes from the compensation determination any portion of your load reduction already committed to ComEd, to PJM, or to another curtailment service provider under other tariffs or contracts. If you have signed with a demand response aggregator who bids your site into PJM's capacity or demand response markets, that committed capacity is not payable again under Rider VLR.
This matters because aggregators sell participation as additive, and it is not. Establish what you have already promised before signing anything new; the aggregator's contract will say what capacity you registered.
How to decide when the price is not published
You cannot compute a return on an unnamed rate. So the decision has to be made on the shape of the deal rather than on its value, and on those terms it is more attractive than it first looks.
The downside is bounded and small. No penalties for non-performance, termination at any time, no supply relationship required, and the metering you need is metering you probably already have. The realistic cost of enrolling is the administrative time and the nuisance of the notifications.
The upside is unknown but not unbounded. Compensation multiplies a rate you do not know by your total energy reduction, which you can estimate. Work out how many kilowatt hours you could realistically shed across a two to eight hour window, and you have the quantity. Ask ComEd what per-kilowatt-hour amounts have actually been offered in recent events, and you have a defensible estimate of the product. That is a fair question to ask before enrolling and the answer is not confidential to you.
Ask about frequency, not just price. A generous rate on one event a year is worth less than a modest rate on eight. Ask how many events were called in each of the last three years and how long they ran.
What to establish from your own data first
Two numbers, both of which come from your interval record rather than from your bill.
How much you can actually shed, in kilowatts, sustained for two hours. Not nameplate, not the sum of what could theoretically be switched off. What you have historically been able to drop and hold. If that number is below ten kilowatts you are not eligible for payment, and finding that out now is cheaper than finding it out during an event.
Whether shedding conflicts with your own demand charge. These usually align, since ComEd's on-peak demand window and its system stress hours overlap heavily, but they are not the same thing. An event called outside your billed demand window costs you production and saves you nothing on the demand charge, so the response payment is the only compensation. An event inside it does both, and the demand charge saving may well exceed the payment.
If you already know your load shape at half-hour resolution, both numbers fall out in an afternoon.
How much does ComEd Rider VLR pay?
The filed rider does not set a rate. It states that compensation may be offered in an amount greater than $0.00 per kilowatt hour, determined by ComEd based on its assessment of the circumstances at the time of the event, multiplied by your total energy reduction. Ask ComEd what has actually been offered in recent events.
Is there a penalty if I do not reduce load during a Rider VLR event?
No. The rider states that ComEd does not assess noncompliance charges to a participant that does not provide its committed load reduction after notification.
What is the minimum size to participate?
A commitment to reduce at least ten kilowatts. You are not eligible to receive compensation unless you meet that minimum load reduction.
Can I be in Rider VLR and a PJM demand response program at the same time?
You can be enrolled in both, but load already committed to ComEd, PJM or another curtailment service provider is excluded from the Rider VLR compensation calculation. The same reduction is not paid twice.
When does ComEd pay Rider VLR compensation?
As a single payment by December 31 each year, covering accrued compensation for events during the twelve month period ending September 30.