As Illinois families brace for another season of high energy bills, ComEd’s parent company, Exelon, has been working hard to convince the public it is standing up for customers.

In February, Exelon launched “The Exelon Promise,” pledging to protect customers “regardless of market conditions” and ensure large energy users like data centers “pay their fair share of the grid investments needed to support them,” in the words of CEO Calvin Butler.

ComEd’s own filings before the Illinois Commerce Commission tell a different story.

Expert testimony filed by the Citizens Utility Board in the case over ComEd’s proposed $15.3 billion, four-year grid plan has identified more than $1 billion in spending that CUB says is inflated, unjustified or mislabeled to dodge legal scrutiny.

That should concern every Illinois customer. This is on top of a plan that already represents a 21% spending increase over ComEd’s last one, a plan the Illinois Commerce Commission rejected outright in 2023 for failing to prove it was affordable.

CUB’s expert testimony points to a familiar pattern for ComEd: It chooses higher-cost utility spending over lower-cost customer protection. CUB says ComEd overstated summer peak-demand investments by about $238 million, largely by skipping lower-cost options like demand-response programs in favor of an overall budget hike.

The utility also wants to spend $209.4 million replacing smart meters that are still operational and haven’t even been fully paid off yet. Customers would ultimately cover those replacement costs through higher bills. To top it off, ComEd wants to do it without competitive bidding and without guaranteeing customers real-time access to their own usage data.

Then there are electric vehicles. ComEd inflated its EV-charging cost estimates by $124 million, CUB said, by assuming worst-case scenarios that don’t hold up, like counting on electric school buses to strain the summer grid, when school isn’t even in session.

The most troubling finding is not just how much ComEd wants to spend, but how it is trying to classify the spending. CUB identified $96 million in capital spending, plus $18 million more in operating costs, that ComEd labeled “mandatory” even though it’s clearly discretionary. That distinction matters under the Climate and Equitable Jobs Act, known as CEJA. CUB found that “ComEd hid these expenses in the mandatory category to skirt the CEJA mandate of having to prove that the benefits of discretionary spending outweigh the costs.”

Regulators already flagged this exact move in ComEd’s last plan, when 72% of proposed spending was declared “mandatory.” ComEd’s response wasn’t to fix it. The new plan pushes that figure to 75%.

This is typical behavior for monopoly utilities like ComEd. Consumer advocates cut $2 billion, about a quarter, from ComEd’s last grid plan before the Illinois Commerce Commission would approve it. Once again, it’s outside experts who are catching more than a billion dollars in questionable costs headed for Illinois customers.

That’s the gap Exelon needs to close. A company cannot promise to protect customers “regardless of market conditions” while seeking approval of a grid plan filled with premature equipment swaps, capacity built on unverified projections and spending mislabeled to sidestep a state law designed to protect ratepayers.

The Illinois Commerce Commission is expected to issue a proposed order in October and a final order by the end of the year. That gives ComEd time to bring its filing in line with what Exelon promised the public in February: making data centers put real money down before they plug in, and an end to disguising discretionary spending as mandatory.

Exelon made a public promise to Illinois ratepayers. Now, they have a duty to ensure ComEd keeps it, in a case that will decide how high their bills are set to soar.

State Rep. Angie Guerrero-Cuellar, D-Chicago, represents the 22nd Illinois House District.