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Countering ComEd’s “Minor Utility” Claims

A formal zoning accountability audit evaluating the core legal discrepancies surrounding ComEd’s attempt to bypass public hearings via historical definitions of scale.

A Legacy of Neighborhood Protection

The distinction between “Major” and “Minor” utilities was established in 2004 to protect the residential character of our neighborhoods from Industrial Encroachment.

This reform prioritized Transit-Oriented Development (TOD)—a mission strengthened by the Connected Communities 2022 ordinance. It ensures land remains walkable and vibrant, not occupied by regional hubs.

2004: Neighborhood Scale
2004 Neighborhood Substation
Scale: ~5,000 sq. ft.
Voltage: 12kV (Local Distribution)
Impact: MINOR UTILITY: “Few if any impacts on surrounding areas”
2026: Industrial Scale
2026 TSS 35 Proposal
Scale: 47,000 sq. ft. (1.08 Acres)
Voltage: 138kV (Regional Transmission)
Impact: MAJOR UTILITY: “Substantial land use impacts on surrounding areas”

Classifying a football-field-sized regional node as a ‘Minor Utility’ ignores twenty years of zoning progress. It creates a permanent dead zone that violates modern ordinance metrics.

ComEd claims this 138kV Regional Substation is a “MINOR” Utility. But that label hides the truth: SCALE and IMPACT MATTER.
Would an even larger 765kV Substation be considered “Minor” just because ‘substation’ is an example in the definition?
Full scale evidence comparison of substations
🔍 Click Image Above for Full Scale View
The Principle of Qualitative Impact
CONTEXT OVERRULES EXAMPLES.
IMPACT DEFINES THE LAW.
This is not a “typical” neighborhood substation. Under the law, qualitative context overrides specific examples. This is a MAJOR UTILITY because it has “significant land use impacts on surrounding areas” and “transcends the usual restraints of the district.”

By replacing our residential and commercial potential with INDUSTRIAL USE meant for a regional “community-wide interest,” ComEd is attempting to bypass the public scrutiny that the law explicitly requires.
Whiteboard Analysis of Substation Impact
🔍 View Whiteboard Analysis

Demand Public Hearings and Transparency

Now that you have audited the legislative zoning scale, join the coalition in filing a formal public records protest with the ICC.

Take Action: File ICC Comment →

info@diverseycc.org

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