Exelon Corp (EXC) — Q3 2023 Earnings Call Transcript

Thank you, Gigi, and good morning, everyone. We're pleased to have you with us for our 2023 third quarter earnings call. Leading the call today are Calvin Butler, Exelon's President and Chief Executive Officer; and Jeanne Jones, Exelon's Chief Financial Officer. Other members of Exelon's senior management team are also with us today and they will be available to answer your questions following our prepared remarks. Today's presentation, along with our earnings release and other financial information can be found in the Investor Relations section of Exelon's website. We would also like to remind you that today's presentation and the associated earnings release materials contain forward-looking statements, which are subject to risks and uncertainties. You can find the cautionary statements on these risks on Slide 2 of today's presentation or in our SEC filings. In addition, today's presentation includes references to adjusted operating earnings and other non-GAAP measures. Between these measures and the nearest equivalent GAAP measures can be found in the appendix of our presentation and in our earnings release. It is now my pleasure to turn the call over to Calvin Butler, Exelon's President and CEO.

Thank you, Andrew, and good morning, everyone. We appreciate you listening to our third quarter earnings call. Despite historically mild first nine months of the year and pressures from storms in August and September, we delivered earnings right in line with the expectations laid out in our last earnings call. For the quarter, as you can see on Slide 4, we earned $0.70 per share on a GAAP basis and $0.67 per share on a non-GAAP basis. With the critical summer season behind us, we have narrowed our guidance range to $2.32 to $2.40 per share for 2023. Jeanne will talk more about our results for the quarter and expected financial performance for the balance of the year. Operational performance across the platform remained very strong in the third quarter. With storms that brought 110-mile-per-hour wind gusts and 29 major event days that impacted almost 1.3 million customers, we not only kept our financial plan on track but we also continued our track record of top quartile reliability performance, and we continue to make progress in safety and customer satisfaction. The third quarter also brought continued execution of key milestones in our six active base rate cases underway in Illinois, Maryland, Delaware, New Jersey, and the District of Columbia. Beginning with ComEd, we received a proposed order from the ALJ on its multiyear rate and grid plan on October 23. We're encouraged that the proposed order recognizes that meeting the ambitious electrification and decarbonization goals set by Illinois' groundbreaking Climate and Equitable Jobs Act will require ComEd to make significant investments and it largely follows an investment plan that has alignment across a broad group of stakeholders. But the order does not recognize a fair cost of financing that investment. It provides a return on equity that is well below the national average. It does not recognize the significant investment we have made in our pension which supports ComEd's employees and has saved customers almost $1 billion to date with its returns and continues to generate savings for our customers. And it does not allow for a prudent capitalization of the business, having equity ratios below an appropriate level. So we are disappointed with elements of the proposed order, but we expect the commission will consider the full record developed when writing its final order. And we continue to make our case with stakeholders. As a reminder, we expect to receive the final order in mid-December. As it pertains to BGE, all parties have filed their briefs and we now await a final order from the Maryland Public Service Commission expected on December 14. We have put forward a strong investment plan to address the needs of our customers that is aligned with the state's ambitious goals to advance the energy transformation. We remain optimistic that the commission will reach a constructive outcome that appropriately supports our customers and the state's goals laid out in the Climate Solutions Now Act. As you will hear from Jeanne, we also made progress in the Atlantic City Electric rate case, where a stipulation of settlement awaits final approval. The Delmarva Power and Electric rate case is progressing as well, along with the Pepco DC and Pepco Maryland multiyear rate plans. On our longer-term outlook, we continue to reaffirm our existing guidance. We expect to be at the midpoint or better of our 6% to 8% annualized earnings growth ranges and to grow the dividend in line with those earnings. The capital we are investing across our jurisdictions to support the needs of our customers in their energy transformation is what drives that growth. On Tuesday, PJM selected project proposals submitted for the competitive transmission proposal Window 3. Exelon's proposed transmission projects were among a set of solutions to maintain reliability in the Maryland, Pennsylvania, and Virginia areas, driven by significant load increases in Northern Virginia. Specifically, PJM has recommended a suite of solutions that include a scope of work for Exelon that is estimated to cost approximately $850 million, with portions assigned to BGE, PECO, Pepco, and Delmarva Power. As this spend is weighted toward the back end of the decade with expected completion dates of 2029 and 2030, that extend beyond the current guidance range, it provides another good indication of the trends in place and degree of work that the grid will require well into the future. I'll also note two additional exciting developments this quarter that support our jurisdictions' energy goals. First, ComEd, PECO, and Pepco were part of two coalitions receiving hydrogen hub awards in our service territories. These projects will go a long way toward accelerating access to clean and affordable hydrogen to meet the nation's ambitious carbon reduction goals and creating thousands of clean energy jobs in Exelon service territories. Second, the U.S. Department of Energy recommended two of Exelon's submissions in the grid resiliency and innovation partnership program for negotiation of a final award, totaling $150 million across our ComEd and PECO utilities. ComEd will direct its $50 million award to enable customers and partners to deploy next-generation technologies for growing solar installations and electric vehicles. And PECO is leveraging its $100 million award to enhance resiliency in vulnerable areas of the PECO service territory that are susceptible to severe weather events. When combined with the middle-mile grants that BGE and ComEd were awarded by the National Telecom and Information Administration, Exelon Utilities are approaching $200 million in total federally funded IIJA grant awards this year, not to mention the amount directed towards its jurisdictions through vehicles like the EPA's Clean School Bus program. The federal support is critical to supporting an affordable and equitable transition. The need for transmission expansion, the investment in new energy supply and the ever-increasing need for a more resilient grid all highlight the impact that an economy increasingly dependent on electricity will have on our investment plan. The energy transformation will last decades, not years, which is why we're confident that investment opportunities will continue to strengthen and lengthen our rate base growth. We look forward to incorporating these updates into our annual financial update on the fourth quarter earnings call next February. I'll now speak to our operating performance in the third quarter on Slide 5. Reliability remains outstanding. All four utility operating companies had top quartile performance in both reduced outage frequency and shortened ops duration. ComEd operated in the top decile for both metrics. In fact, ComEd and PHI again achieved the best on-record outage frequency and duration performance, which makes for the third quarter in a row for those two operating companies. Performance like this is particularly impressive when you consider the level of storm activity we experienced this quarter, which is a testament to the investments we're making in the system and the talented, dedicated employees working this system. As an example, in just one damaging storm, BGE crews replaced 32 miles of wire and 82 transformers, and they did it 36 hours faster than historical models predicted was possible. That commitment to operational excellence across the Exelon franchise is a key part of what makes us who we are. And our gas operations are keeping pace. All three gas utility operating companies continue to perform at top decile levels for gas response. As it pertains to customer satisfaction, while three of our utility operating companies continue to benchmark in the second quartile, PECO has progressed to the first quartile. Our improved benchmarking performance at PECO reflects the benefits of those efforts, and all utility operating companies did see increases in their scores. But as we have mentioned, overall satisfaction has been affected by inflation and sunsetting pandemic era relief relative to the benchmark year. The headwinds facing our customers are real, which is why we are focused on ensuring customers are aware of their options to manage their energy use and reduce their bills. We look to build on increasing satisfaction levels into 2024. Last, we saw improvement in our safety performance benchmark at PHI versus the second quarter. We continue to focus on the areas of underperformance and implement utility-specific action plans to address the higher OSHA rates. And you can see that with PHI scores, where our efforts to reinforce procedures, situational awareness, and crew communication have yielded results. We are also continuing in partnership with the industry to drive a more sophisticated discussion and set of tools around safety to focus employees on which behaviors will most impactfully improve safety and ensure we do our most important job: making sure each employee returns home safely after every shift. I assure you that we will continue to push for excellence across all areas of our operations as we close out 2023. I will now turn it to Jeanne to review our financial performance and regulatory updates.

Thank you, Calvin, and good morning, everyone. Today, I will cover our third quarter financial update, along with the outlook for the balance of 2023 and our progress on the 2023 rate case schedule. I will also highlight a recently completed transmission rebuild project by Delmarva Power & Light designed to further improve reliability for our customers in Eastern Maryland. Starting on Slide 6, we show our quarter-over-quarter adjusted operating earnings. As Calvin mentioned, Exelon earned $0.67 per share in the third quarter of 2023 versus $0.75 in the third quarter of 2022, reflecting lower results of $0.08 per share over the same period. Results of $0.67 in the third quarter represent 28% of our expected full-year earnings, which is right in line with the expectations provided on the prior earnings call. Earnings are lower in the third quarter relative to the same period last year, driven primarily by $0.07 from the impact of weather and storms and summer activity returning to normal in '23, $0.04 of higher interest expense due to the rise in interest rates and higher levels of debt at the holding company and at some of our utilities, and $0.03 of O&M tax and distribution formula rate timing expected to reverse in the fourth quarter. This was partially offset by $0.05 of higher distribution in transmission rates associated with incremental investments, net of depreciation, as well as the $0.01 up carrying costs related to the carbon mitigation credit balance at ComEd. Despite the summer storms and mild weather impacting our non-decoupled jurisdictions, we have delivered year-to-date earnings each quarter in line with indications, and we continue to offset the weather headwinds with a combination of O&M levers across the platform, higher treasury rates impacting ComEd's distribution ROE, favorable depreciation of PECO, and the full-year earnings impact of carrying costs associated with the CMC regulatory asset balance. With one quarter remaining in the year, we are narrowing our 2023 EPS guidance range to $2.32 to $2.40 per share from $2.30 to $2.42 per share. Our full-year guidance accounts for the absence of proactive de-risking that occurred in the fourth quarter of '22, the reversal of year-to-date O&M tax and distribution formula rate timing, and the anticipated one-time impact in December of BGE's reconciliation for the 2021 and 2022 under recovery. Through continued increase in rate base as we deploy capital for the benefit of our customers, along with managing work plans across the platform, we remain on track to deliver earnings within expectations. Recall, our goal is to achieve the midpoint or better of the guidance range. Lastly, we are reaffirming the fully regulated operating EPS compounded annual growth target of 6% to 8% from 2021 and 2022 guidance and plans through 2025 and 2026, respectively. Again, our expectation is to be at the midpoint or better of that growth range. Turning to Slide 7. As Calvin mentioned, we continue to execute in all six open distribution rate case proceedings this quarter, in line with the established procedural federal. Each rate case remains on track, and we are approaching the final key milestones in December, ComEd and BGE's multiyear rate plan rate cases. Let me begin with key developments since the last call. First, DPL Delaware received intermediary testimony and filed a rebuttal supporting the key elements of the company's proposed electric distribution revenue requirement increase of $39.3 million. DPL Delaware will continue to establish that the proposed plan is necessary to continue providing safe and reliable service, meet customer expectations, and support Delaware clean energy goals while balancing customer affordability. A final order is expected in the second quarter of 2024. Second, we are pleased with the progress in Atlantic City Electric's distribution rate case with the stipulation of settlement in place; the procedural schedule was suspended in early September. On October 21, ACE filed a stipulation of settlement with the New Jersey Board of Public Utilities, and on October 24, the administrative law judge presiding over the case recommended the settlement with all parties be approved. ACE anticipates final approval of the settlement from the BPU in the fourth quarter. Next, the procedural schedule in Pepco's DC multiyear rate plan filing has been adjusted to accommodate the commission's request for supplemental testimony from Pepco. Similar to the commission's request from its personal plan, this directive provides Pepco the opportunity to demonstrate the benefits afforded by multiyear rate plans relative to traditional rate-making. Pepco now expects to receive intervenor testimony on December 11, and evidentiary hearings will take place in March 2024, with the final order expected from the Public Service Commission of the District of Columbia by mid-2024. While still in the discovery phase of its second multiyear rate plan filing, Pepco Maryland continues to detail its proposed investment plan designed to advance the state's climate and clean energy goals. Upcoming milestones include intervenor testimony expected to be filed by the Maryland Public Service Commission staff on December 15 and the evidentiary hearing set to begin in March 2024. Briefs will be filed in April of 2024, and we expect a final order by June 2024. Additionally, in Maryland, evidentiary hearings were conducted and briefs filed in September and October, respectively, as part of BGE's pending multiyear electric and gas rate case. The hearings allow parties to share perspectives on the proposed investments, their alignment with the goals of the state, and how best to balance the state's goals around the energy transformation, affordability, and customers' interest. As expected, the Maryland Commission continues to prioritize safety, reliability, and affordability. It is also focused on addressing the goals of the Climate Solutions Now Act. We continue to believe BGE's proposed investment plans are well suited for Maryland to meet its aggressive clean energy goals in an affordable manner. The proceeding is expected to run its full course with the final order expected from the commission by December 14. Moving on to ComEd's multiyear rate plan proceeding. As you heard from Calvin, the administrative law judges presiding over the case issued a proposed order on October 23. While the ALJ's proposed order recognizes that ComEd must undertake significant infrastructure investments to meet the state's clean energy goals, it does not fairly recognize ComEd's cost of financing to do so, especially in the current interest rate environment. We continue to believe the evidence on record supports ComEd's requests on ROE, capital structure, and a return on its pension assets, among other factors, to provide a clear path in achieving a cleaner energy future for our customers and communities in Illinois. But while we are disappointed in the proposal, let me remind you that this is just another data point in the process and is nonbinding on the commission. Given the number of variables that play in the transition to a multiyear plan, our current plan contemplates a range of fair and reasonable scenarios in the final order to achieve the state's aggressive decarbonization and electrification goals. We look forward to the remaining steps in the process, including filing briefs on exception by November 8, reply briefs on exception by November 20, and participating in oral arguments, which we anticipate will occur in late November. Each of these avenues will provide ComEd the opportunity to demonstrate the facts on key elements that are supported on the record and advocate for our position, which we continue to believe is in the best interest of customers and aligned with the state's energy policy goals. A final order is expected at the last scheduled ICC meeting of the year on December 14, but due no later than December 20. Relationships across our jurisdictions remain constructive, and we remain steadfast in our engagement with key stakeholders across the regulatory bodies, the state legislators, and the communities to support our shared interest in the energy transformation. As a reminder, by next year, we expect to have a resolution on all four of the ongoing multiyear rate plans in Illinois, Maryland, and D.C., which will support their respective clean energy and climate goals while balancing customer affordability and equity. More details on the rate cases can be found on Slides 20 to 26 of the appendix. Moving to Slide 8. During the third quarter, we continue to deploy capital for the benefit of our customers and are on track to invest $7.2 billion expected for 2023. These investments are designed to deliver answers to an expanding set of needs for tomorrow's spread: enhance customer value, adapt to climate change, meet heightened resilience and reliability challenges, and modernize outmoded systems and equipment just to mention a few. These also support our communities. Today, I specifically would like to highlight how Delmarva Power's recently completed East New Market to Cambridge transmission upgrade project in Maryland is meeting those needs. Construction to rebuild the transmission equipment began in late fall of 2021. This $40 million project included upgrading more than 11 miles of existing transmission line with new wire and installing 189 galvanized steel poles, replacing wood poles with new, longer-lasting steel utility poles, which strengthens the local energy grid and reduces the number of transmission poles along the route. These more reliable structures are also designed to withstand severe weather conditions, a vital design element as climate change has contributed to the increased intensity of coastal storms. For perspective, steel poles can withstand 120-mile-per-hour hurricane-force winds in blizzard conditions, an increase of up to 20% compared to wood poles. Together, these important upgrades, which were placed in service in May 2023, are expected to help prevent outages and enhance overall reliability for more than 13,000 residents of Sirk County, Maryland. Projects such as this transmission rebuild contribute to the nearly 30% decrease in electric outage frequency our DPL Maryland customers have experienced over the last five years. The East New Market to Cambridge project is just one example of our broader strategic effort to strengthen and modernize the energy grid across all of our service areas. We continue to see significant need for transmission investments to support state and customer goals on renewable energy and electrification. This demand supplements more traditional transmission expansion needs, including congestion relief, operational performance requirements, infrastructure resilience, equipment, material condition, and customer service. As Calvin mentioned, we look forward to providing our annual financial update, inclusive of the newly awarded transmission upgrade spend from PJM, as well as the final rate orders in Illinois and Maryland on the fourth quarter earnings call in February 2024. I will conclude with a review of our balance sheet activity on Slide 9. As a reminder, we continue to project a 100 to 200 basis points of cushion on average of our guidance period for our consolidated corporate credit metrics above S&P and Moody's downgrade thresholds of 12%, demonstrating our commitment to maintaining a strong balance sheet. If the corporate alternative minimum tax is not mitigated through an inclusion of repairs in its calculation, we anticipate being at 100 basis points or at the lower end of that range. While our plan incorporates the assumption that the corporate alternative minimum tax will not allow for repairs, we remain optimistic that it will be implemented in a way that mitigates the cash impact. We continue to anticipate the treasury will issue more guidance on the corporate alternative minimum tax before year-end. From a financing perspective, I will remind you that we completed all our planned debt financing needs for 2023 as of the second quarter call, reducing earnings volatility in the second half of the year. In managing the interest rate volatility, we continue the pre-issuance hedging and floating rate cap programs that were initiated last year. In addition, we continuously monitor the capital markets and regularly assess our plans for future issuance timing, sizing, tenor, and tranching strategy to ensure we always achieve optimal outcomes. Additional detail on our earnings sensitivities reflective of our hedging activity to date is provided on Slide 18 in the appendix. Lastly, there have been no changes in our guidance to issue $425 million of equity at the holding company by 2025. As we work with our jurisdictions and identify needs for further investment at the utilities, including those assigned by PJM, we will continue to ensure that we maintain a strong balance sheet, consistent with the expectations of a premium T&D company while supporting our 6% to 8% annualized earnings growth rate. Thank you. I'll now turn the call back to Calvin for his closing remarks.

Thank you, Jeanne. With just a couple of months left to go in 2023, I'll conclude with a reminder of our goals and priorities for the year. First, our foundation is operational excellence, which benefits our customers and communities. As I mentioned, our employees rose to the challenges they always do for our summer storms, but we're ready to close out the year strong to prove we have the best operators in the business. Indeed, PA Consulting just awarded ComEd with its 2022 Reliability One National Reliability Award, one of the most prestigious honors in the electric utility industry, recognizing it for sustained leadership, innovation, and achievement in the area of electric reliability. This award highlights the value of a committed operating team executing on a sophisticated operating plan and investment strategy to provide the customers the grid that they deserve. I now want to take a moment to just recognize Terry Donnelley, COO of ComEd. Terry will be retiring at the end of this year after almost 12 years in that position. Terry, thank you for your continued steadfast leadership and also the selection between him and Gil Kiona of David Perez, who is stepping in as a longtime Senior VP into the role of Chief Operating Officer. We have high expectations of David that they will continue to deliver on the operational performance that Illinois customers have come to expect. We are also focused on completing a number of the rate cases we have underway, including BGE's multiyear plan for its gas and electric systems, as well as ComEd's multiyear rate and grid investment plans. We continue to believe that parties in both cases have a shared interest in reaching outcomes that align with the state's energy policy and equity goals while ensuring we have the certainty and confidence to make the investments needed to serve our customers reliably. The Climate and Equitable Jobs Act was passed in 2021, with the promise of making Illinois a leader in the energy transformation. The approval of these first electric multiyear plans is a key moment for the state to advance its clean energy goals in line with the thoughtful ambitious plan and process the state laid out in the Climate and Equitable Jobs Act. We are optimistic that the state of Illinois will seize the opportunity. Third, we will finish out the year meeting our financial guidance, narrowing our guidance range to $2.32 to $2.40 per share demonstrates the confidence we have in executing despite the historically mild weather this year, and we remain on track to invest $7.2 billion of capital and earn a consolidated ROE in the 9% to 10% range. Lastly, we never want to lose sight of our responsibility to our customers and communities as the premier transmission distribution utility. Just this past quarter, ComEd and PECO were two of only six utilities to partner with local governments and community-based groups to win DOE support from its Clean Energy to Communities program. Through this program, ComEd will help explore low-carbon transportation technologies for Chicago, like freight travel electrification, while PECO will assist in creating a regional hub to streamline procurement of the most impactful clean energy technologies for the Delaware Valley region. BGE awarded grants to 41 nonprofit organizations in Maryland to support environmental stewardship programs. And Pepco energized the first of three substations as part of its capital grid project, which is Pepco's forward-looking plan to upgrade or add substations and underground transmission cables to modernize and strengthen our nation's capital grid. In doing so, Pepco was able to provide $29 million to local suppliers and $30 million to diverse suppliers as part of the work to complete that substation. Those examples show whether it's providing direct support to our customers, our community organizations, facilitating access to support from federal or national organizations, or ensuring our work on the grid benefits our jurisdictions end-to-end, the Exelon team is focused on ensuring all of its actions are intentional in serving the greater purpose of leading the energy transformation. These goals are what make for a premier T&D utility, one that embraces the opportunity to lead the energy transformation, partners with its jurisdictions to achieve their goals, uplifts its communities, and meets the expectations laid out for the investment community, offering a total shareholder return of 9% to 11%. Thank you, as always, for your interest. I'll now turn it to Gigi for your questions.

So starting off, I guess, with the ALJ order in Illinois. Calvin, you mentioned your expectations that the commission will consider the full record. I guess, is the draft the final order? I realized you've been in a formula construct for a while, but is there any prior precedent for the ICC to make those kinds of departures from the ALJ? Just trying to understand the prospects here for vision and your confidence level.

Yes. First off, James, thank you for your question. There is precedent. The record is going to be considered by the full commission. But the commission definitely has leeway to look at the record separately, taking advisement with what the ALJ has said. Also keep in mind, this is the first time that this commission has come together under a multiyear rate plan and grid plan to consider how ComEd's proposals meet the state's goals. So I do believe there is a difference in opinion on how to approach this. I think they will consider that since we have three new commissioners who will lean into this discussion and look at what they need to do to achieve the state's goals, which are very specific. And I have Gil Ciona, the CEO, to comment with me. Gil, anything you'd like to add?

Yes, I think it's important to recognize that this is a key milestone in the process, but there are four additional milestones ahead, as both Calvin and Jeanne mentioned: the briefs to the commission and exceptions, replies to those briefs, and oral arguments before the final order. As Calvin noted, we strongly believe that the evidence available supports ComEd's requests. Based on the commissioners' past actions, we expect them to make adjustments and corrections before issuing a final order. We anticipate that the commission will not only consider the post-order but also the entire record in this case and the policies of the state. This represents a historic opportunity, and we are confident that the commission will rise to the occasion in furthering the ambitious goals of the Climate Equitable Jobs Act and the state's economic development objectives.

Does that answer your question, James?

Yes. I have a question for Jeanne regarding the remaining equity requirement in the current plan. If you don’t receive the minimum tax clarity you seek from the IRS, would you need to bring that requirement forward to 2024, or is it set for 2025? Can you provide any additional information on the timing?

Yes. No, everything we've given you assumes that we pay the corporate alternative minimum tax. So regardless of how that turns out, our commitment is to do the $425 million between now and 2025. That doesn't change, regardless of the outcome here.

Okay. And then just real quickly, the transition spend today, that is purely incremental to the $870 million you debuted on the last call related to stores, right?

Yes. There are two similar numbers, but two different projects.

Maybe on that same topic, with the transmission projects that have been selected. Could you elaborate a bit on which year the CapEx would start to flow into the spending plan? And also, just as you think about PJM and potential competitive opportunities going forward, are there future opportunities that you plan to bid into also?

Yes, David. I'll start, but then I'll turn it over to David Velazquez, who's here with me that has our transmission strategy group reporting up to him and working with all the opcos. As I mentioned, I believe our transmission buildout has tremendous opportunity to not only strengthen what we're doing but also lengthen our earnings growth and doing it in a way that ensures not only reliability but the ability to connect renewables to the grid. David and his team have put together a robust plan, and I'll let him take a moment to walk you through.

So David, this is Dave. On the transmission projects, just to give you a sense, we have brand insurers, which was the project we talked about by last quarter, which has an in-service date at the end of 2028. So you think about cash flows there, and again, you have to recognize we're in preliminary engineering yet, so this is liable to move a little bit. Typically, in the last couple of years, you might see around 40% to 50% of that expenditure spent. And then leading up to it, starting next year, you'd slowly ramp into it. In the first three years, you would spend somewhere again between 50% and 60% of the project. The Dominion project has an in-service date part of it in '29 and part of it in '30. I think you'd see a similar profile, where in the last couple of years, you probably see around 40% to 50% of the expenditures and three or four years leading up to that. Some of this will be within the current period, and some of it will be after the current period. I think on the broader question, as Calvin has said, there's a lot of opportunities out there. We look at every single competitive window that PJM puts out and make decisions on whether we think we can add value for our customers by presenting proposals and we will continue to do that. I think also there's other opportunities out there; offshore wind is one. In Maryland, the commission has to issue a solicitation to help bring on some of the additional megawatts by July of next year. We continue to see a lot of load growth in our regions around data centers. There are also some hydrogen hubs that have been awarded grants from the federal government in our territories. We also continue to see some generation retirements; PJM recently announced the retirement of a large Wagner unit in BGE's territory. So there are a lot of different opportunities that we're looking at to continue to invest in transmission.

Excellent. That's really helpful. And I guess as you think about some of this incremental upside CapEx, it sounds like some of which would hit the current plan, but then also looking ahead to the next 5-year CapEx plan, how do you think about financing the next year of kind of higher CapEx growth and rate base growth, specifically thinking about how you're thinking about equity needs from here?

Yes, it's Jeanne. I think it's how we've always thought about it. We rolled out the $31 billion on our last call. We talked about financing in a balanced approach with internal cash flows and a mix of debt and equity. To the extent we continue to see more and more work, which we know there will be, we'll finance it in a way that maintains that cushion on the balance sheet that we target but also ensures that we meet our 6% to 8% earnings growth.

And thank you for laying out all those transmission opportunities. Just as we think about the roll forward, not the current plan. You've been very clear, but the roll forward with these incremental opportunities, is there a good way to think about financing those incremental CapEx? Is it kind of like a 50-50 mix? Or should we be thinking of something different?

Yes, I think, as I mentioned with David's earlier question, we'll do it in a balanced way. We've got a lot that we're pulling together here. We've got some really exciting incremental transmission opportunities. We have incremental investments from the new rate cases that we've been filing. So we're going to pull all that together as we always do in the fourth quarter and give you a full update when all of that is final. We should have some more information by the end of the year on the corporate alternative minimum tax. We'll embed any additional cost savings that we're finding as we continue to get further out of separation. So as I mentioned, we'll fund any new incremental capital with a mix of internal cash flows reinvesting back into the business and to the extent necessary, do what we need to ensure we maintain that cushion on the balance sheet, while always also hitting our earnings target of 6% to 8%. So we'll do it in that balanced, thoughtful way.

Okay. Understood. And then shifting topics a little bit. Do you have an estimate for what the Illinois ComEd customer bill CAGR is like over the next 5 years for your rate case and then I know there's the carbon mitigation credit that rolls off. So just curious how the bill trajectory is.

Yes. I believe the customer bill compound annual growth rate is estimated to be between 4% and 5%. The second part of your question was regarding the impact as the carbon mitigation credits roll off.

Yes. Just overall, like, again, you're only part of the bill, like what an overall ComEd customer bill trajectory looks like over the next 5 years?

Yes. Over the next five years, the rate case request was approximately 4.5% to 5%.

But it's important to note, Paul, that ComEd starts below the national average in terms of overall rates. So as I like to think of the headroom within that utility to invest and move the state forward exists. One, because of the carbon mitigation credits, but also because they start from a position of strength and having some of the lowest rates in the country. I think it's roughly 23% below large city national average. That's where ComEd's in.

It is actually Aidan Kelly on for Jeremy. Just one quick question going back to ComEd. Curious how do you reconcile the differences between the ALJ's 9.28% ROE and staff's 8.91% ROE as well as the proposed equity ratio? And then could you just talk more about where the ultimate return on pension assets debate stands?

Yes. I would tell you that, as we talked about, I'll first start with one step, and this is just another step in the process, as Gil laid out. Coming off the World Series, I think we're in the sixth inning, right? We're in the sixth inning of a long game. That's just one step. Staff was one, and you saw they came in at 8.9%, talking about the formula rate, and then we get the ALJ, we were able to respond, then we get the ALJ's ruling of 9.28%. We will continue to respond to the evidence as presented and present additional data for this commission to work with. That includes not only ROE but also return on pension assets. As I talked about in my statement, it warrants a return, and we have even come to an agreement with the Attorney General of Illinois, where we are minimally getting a debt return. We continue to move forward and present the why. I think that's the powerful part of this, Jeremy, when we can articulate the why and frame how it's beneficial for all customers moving toward having a productive and efficient company that's moving the state's goals, we'll get there. Getting into the details of this or any other piece of this early in the process, I think would be inserting ourselves deeper before the full commission has a chance to hear the evidence. As Gil has laid out, we have our next filing due, and we'll present that to them. The brief on exceptions will be on November 8, and we’ll lay it all out fully, Jeremy, on November 8 as to the what and the why.

Appreciate the color there. And then just one quick question unrelated on the $425 million equity; would you consider ATM or follow-on there?

We have $1 billion ATM in place. We can always just leverage that in a kind of dollar cost average in as needed.

CJ, as always, thank you very much, and thank you to everyone for joining us today. We look forward to seeing many of you at the EEI Financial Conference in a week. Jeanne and the team and I are looking forward to just engaging with you in a more robust and deep manner at that conference. And with that, that concludes our call. Thank you very much. Have a great day.