Cheryl B. from Indianapolis. Working with a grain drying operation that should qualify for ComEd's Agricultural Rate Schedule Ag-1, but ComEd keeps pushing back saying it's not 'primary agricultural production.' The facility processes grain from local farms - drying, storage, some basic processing. They're currently on Schedule 4M paying about $12,000/month with 200 kW demand. The agricultural rate would save them roughly $2,800/month. Has anyone successfully gotten ComEd to approve Ag rates for processing operations versus just farming?
Agricultural Rate Qualification Nightmare - ComEd Being Difficult
Greg L. here. I've had mixed success with ComEd on agricultural classifications. The key phrase in their tariff is 'agricultural production or processing.' Processing should qualify, but they're notoriously strict about it. Did you submit documentation showing the percentage of locally sourced grain? That helped in one case I had.
Randy Dawson here. Cheryl, this is a common issue across many utilities, not just ComEd. The agricultural rate definitions vary significantly between utilities, and many have tightened their interpretation over the years. For ComEd specifically, you'll need to demonstrate that the grain drying is part of the agricultural production process, not a separate commercial operation. Document the percentage of grain that comes directly from farms versus purchased from elevators or commodity markets. If more than 75% is direct from farms, you have a stronger case. Also check if the facility has any USDA certifications or participates in agricultural programs - that helps establish the agricultural nature of the operation. You may need to escalate to the Illinois Commerce Commission if ComEd continues to deny the classification.
Wendell T. from Billings. Different utility but similar situation with Northwestern Energy. Grain elevator operation, mostly drying and storage. What worked for us was getting a letter from the county agricultural extension office confirming the facility's role in local agricultural production. Utilities seem to respect third-party agricultural authority opinions.
Great suggestions everyone. Greg, about 85% of their grain comes direct from local farms within 50 miles. Wendell, I like the extension office idea - hadn't thought of that approach. Randy, should I file with the ICC immediately or give ComEd one more chance with additional documentation?
Cheryl, try one more formal appeal with ComEd first. Include the farm sourcing percentages Greg mentioned, get that extension office letter Wendell suggested, and ask for a written explanation of their denial citing specific tariff language. If they deny again, then you have a stronger case for the ICC complaint. Document everything - every phone call, email, letter. The ICC will want to see that you exhausted the utility's internal processes first.
Jim W. from Youngstown. Cheryl, one more thing to check - does the facility have a Farm Service Agency number or participate in any USDA crop programs? That's another piece of documentation that helps establish agricultural status versus pure commercial processing.
Jim, yes they do have FSA numbers for the storage programs. That's excellent documentation I hadn't considered. Putting together the complete package now with farm sourcing data, extension office letter, and USDA program participation. Will let everyone know how it goes.
Final update: SUCCESS! ComEd approved the agricultural rate classification. The combination of farm sourcing percentages, extension office letter, and USDA program documentation did the trick. The reclassification is effective April 1st with no retroactive adjustment, but the $2,800/month savings going forward makes the client very happy. Thanks everyone for the guidance - this forum is invaluable.