ComEd’s $300 per Kilowatt-Hour Storage Rebate Requires Grid-Only Charging; NYSERDA’s $350 Block Requires a Qualifying Critical-Facility Host

ComEd begins paying $300 per kilowatt-hour for commercial batteries under 100 kilowatts on October 19. The rider caps eligible duration at five hours, so a 99 kilowatt system collects roughly $148,500 and stops there.

Two of the largest per-kilowatt-hour storage subsidies currently documented in the US market sit in Illinois and New York. Both pay on installed capacity. Neither gates eligibility on what the battery does to a utility bill.

The Illinois terms. ComEd’s rebate rider, created under the Clean and Reliable Grid Affordability Act, pays $300 per kilowatt-hour for batteries under 100 kilowatts and $250 per kilowatt-hour at 100 kilowatts and above, with eligible duration capped at five hours and energy capped at 25 megawatt-hours, producing a $6.25 million ceiling per battery computed at the larger-system rate. Eligible systems are standalone, rated 5 megawatts or less, interconnected to ComEd’s distribution system after June 1, 2026, and charge solely from the grid. Applications open January 1, 2027, and ComEd pays within 60 days of a complete application on an operating battery, per Modo Energy’s reading of the rider.

The charging condition. A battery wired to on-site generation falls outside a rider written for standalone assets that charge solely from the grid, which excludes solar-coupled systems from the rebate as reported. The rider text summarized by Modo does not state a rationale for the condition, and any reading of intent, including the inference that the rule keeps the rebate separate from generation compensated elsewhere, is interpretation rather than sourced fact.

The energy charge. Illinois built both of its new instruments around it. The companion net metering rider took effect September 14 and nets hourly charge and discharge at the full retail supply rate. The rebate pays per installed kilowatt-hour. A commercial customer’s demand charge, billed on a peak interval, sits outside both mechanisms as reported.

A separate ComEd rebate channel. The utility said in its October 12 announcement with Richardson Electronics that its Distributed Generation Rebate Program has paid out more than $350 million to date. That program is distinct from the new CRGA storage rider, and the available reporting does not establish that the storage rebate will run on the same administrative machinery. What the figure documents is the scale a mature ComEd rebate channel can reach, not the pipeline the storage rider inherits.

The New York block. NYSERDA’s Retail Inclusive Storage Incentive allocates $15.75 million to a single statewide block of 15 megawatts and 45 megawatt-hours at $350 per kilowatt-hour, covering Con Edison and National Grid territory. Long Island is excluded. Eligible projects sit at critical facilities inside disadvantaged community census tracts: medical facilities, affordable housing properties, food banks, homeless and emergency shelters, and community cooling centers. A project takes either the ISI rate or the market-rate retail incentive, which was set at $125 per kilowatt-hour in the Con Edison and Westchester blocks and $175 per kilowatt-hour in the rest of the state.

The host test runs on facility type and address. Two urgent-care clinics on the same block with identical load profiles and identical hardware can receive different money. A clinic that qualifies as a critical facility inside a disadvantaged community tract draws $350 per kilowatt-hour. A clinic outside the tract, or one that does not fit the eligible facility list, draws whatever market-rate block is open: $125 per kilowatt-hour in Con Edison territory. The gap between the two rates is a factor of 2.8 on identical equipment.

The block is small. Forty-five megawatt-hours at $350 per kilowatt-hour exhausts the $15.75 million allocation exactly, which means the funding and the energy cap bind at the same moment. At 250 kilowatt-hours per system, the block funds roughly 180 projects across two utility territories. NYSERDA does not publish a per-project duration or sizing rule in the material reviewed here, so project counts move with whatever sizes actually enter the queue.

Stated benefits versus stated tests. NYSERDA’s own framing of retail storage requires that a project deliver customer value such as demand charge offset. The eligibility screen that sits on top of the enriched rate tests geography and facility type. The two sit alongside each other rather than feeding into one another: a project qualifies for the higher rate on where it is and what it serves, then demonstrates bill value separately.

Both programs pay on installation. ComEd pays once on a complete application for an operating battery. NYSERDA pays per installed kilowatt-hour against a block. A system that cycles three hundred times a year and one that cycles thirty collect the same amount in both states.

That design choice is defensible on its own terms. A known amount at a known date is easier to finance than a ten-year performance stream, and a capacity rebate costs a utility little to administer once the interconnection record exists. It also means the subsidy carries no information about whether the asset is doing anything useful after the check clears.

What is not verified here. This analysis rests on Modo Energy’s summary of the ComEd rider and on NYSERDA’s December 2025 launch material plus its published incentive pages. Neither the filed ComEd rider text nor NYSERDA’s Retail Program Manual was read directly. NYSERDA’s December 2025 deck set a first-quarter 2026 launch for the Retail ISI; the live Retail Incentive Dashboard returned an HTTP 403 on October 13, so current block status is unconfirmed. Documentation requirements, application procedure, and per-project sizing rules for the ISI are not established by the sources behind this piece and are not asserted in it.

ComEd’s rider takes effect October 19. Applications open January 1, 2027. A 99 kilowatt battery at the Illinois five-hour cap draws about $148,500 in northern Illinois. New York’s figure cannot be computed the same way, because the ISI terms reviewed here set a block-level energy cap rather than a per-project duration limit; what is fixed is the rate of $350 per kilowatt-hour against a 45 megawatt-hour pool.

The allocation rules in both states sit apart from the operating case. Illinois sorts on charging source, New York on host facility and census tract, and a battery’s commercial economics are measured in avoided peak kilowatts, which neither rule reads.

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