Alice M. from Rochester here. I've got a client with a small dairy operation in northern Illinois served by ComEd. They've been trying to qualify for agricultural rates (Schedule A-1) for over a year but ComEd keeps rejecting the application. The property has 40 head of cattle, 80 acres in production, but ComEd says it doesn't meet their "primary agricultural use" test. Client is paying commercial rates that are killing them - about $800/month more than ag rates would be. Anyone dealt with ComEd's agricultural qualification process? Their tariff language is incredibly vague.
Agricultural Rate Qualification Nightmare - ComEd
Ruth from Columbus here. Had similar issues with AEP Ohio on ag rates. The key is usually proving that agricultural activity generates more than 50% of the property's revenue, not just acreage. Does your client have tax records showing farm income? Also check if ComEd requires the service to be directly connected to agricultural equipment vs general farm buildings.
Thanks Ruth. The revenue test might be the problem - they also run a small farm store that probably generates 60% of total property income. But the electric load is definitely agricultural - barn ventilation, milking equipment, grain dryers, etc. ComEd's tariff just says "premises used primarily for agricultural purposes" without defining what that means.
Randy Dawson here. ComEd's agricultural tariff interpretation has gotten much stricter over the past few years. They're looking at both revenue and electrical usage patterns. The farm store operation is likely disqualifying the account under their "mixed use" restrictions. However, you might be able to get separate metering for the agricultural loads vs the retail operation. This would require running the barn equipment, milking parlor, and grain handling on a dedicated agricultural meter while keeping the store on commercial rates. The infrastructure cost might pay back quickly given the rate differential. I'd also recommend getting a copy of ComEd's internal agricultural qualification guidelines through a FOIA request - they have detailed criteria that aren't in the public tariff.
Roy K. from Knoxville. Randy's right about separate metering. TVA has similar mixed-use restrictions but they allow agricultural meters for dedicated farm loads. Cost us about $3,200 for the separate service but client saves $650/month on the ag portion. Payback was under 6 months.
Separate metering might work but the electrical panel setup would be complex. Most of the big loads like the milking system and grain dryers are already on dedicated circuits. I'll get an electrician to quote the work. Randy, great idea on the FOIA request - didn't think of that. How long does ComEd usually take to respond?
Helen K. from Little Rock. Had good luck challenging agricultural denials by involving the state agricultural department. In Arkansas, the Ag Dept will write letters supporting legitimate farming operations when utilities are being unreasonable. Illinois might have something similar - worth a phone call.
Helen, that's brilliant! I'll contact the Illinois Department of Agriculture. This client has been farming for 20+ years so they should have good standing. ComEd can't argue with the state ag department's assessment of what constitutes a legitimate farm operation.
Alice, ComEd's FOIA responses usually take 15-20 business days. Make sure to specifically request their current agricultural rate qualification criteria and any internal memos or guidelines from the past two years. The separate metering approach combined with state agriculture department support should give you a strong case. Keep us posted on how it works out.
Ray C. from Louisville jumping in late here. Just wanted to add that LG&E has a similar revenue test for ag rates but they use a three-year average rather than single year. If Illinois allows this, might help smooth out years when the farm store did particularly well. Also, some utilities will grandfather existing agricultural customers even if they wouldn't qualify under current stricter rules - worth asking if this dairy was ever on ag rates historically.
Quick update everyone: The Illinois Dept of Agriculture came through! They sent a letter to ComEd confirming this is a legitimate agricultural operation that qualifies for farm rates. ComEd approved the application within a week of receiving it. Sometimes you need the right kind of pressure. Thanks for all the suggestions - saved my client about $9,600 annually.