Re: File No. ER-2026-0291, In the Matter of Union Electric Company d/b/a Ameren Missouri’s Tariff to Adjust Its Revenues for Electric Service
Commissioners:
I represent the 96th House District in south St. Louis County, which includes Crestwood, Sunset Hills, Fenton, Sappington and Oakland. Every household I represent is an Ameren Missouri customer. I write to oppose the approximately 10% increase, about $343 million in annual revenue, requested in this case.
My constituents absorbed a 12% increase in June 2025. This request would be the third increase in five years and would add roughly $13 a month, or $156 a year, to an average residential bill. I ask the Commission to apply the full scrutiny the General Assembly intended when it passed Senate Bill 4 in 2025, including a line-by-line review of the grid and generation investments the company cites, and to hold the company to the consumer protections in that law: the 2.25% limit on annual growth in average overall rates under Section 393.1656, the refund conditions attached to construction work in progress under Section 393.135, and the pass-through of federal tax savings to customers under Section 393.138.
I also ask the Commission to independently verify the company’s large-load assumptions. The direct testimony of Steven M. Wills acknowledges approximately $2.8 million in costs associated with large-load customers in this case (Wills Direct, pp. 13, 18) and relies on approximately $13.4 million in projected annual large-load revenue to offset those costs (pp. 23-24), for a projected net reduction to the request of approximately $10.6 million a year, of which approximately $5.2 million is attributed to residential customers. Those projections should not be accepted at face value. I ask the Commission to verify the underlying load forecasts, the cost allocations, and the revenue projections, and to confirm on the record that no cost of serving large-load customers is recovered from residential and small business customers, consistent with the Commission’s large-load tariff.
Finally, Mr. Wills testifies that Ameren expects annual electricity sales to grow by more than 60% in the next five years, driven overwhelmingly by large-load customers, and that by the end of 2029 these customers are expected to consume more than half as much electricity as all of Ameren’s other customers combined (Wills Direct, p. 5). He further testifies that the cost of generation added or accelerated to serve large loads should be figured into the cost-of-service calculation once it comes online. Section 393.130.7 requires large-load rates to reflect a representative share of the costs incurred to serve those customers and prohibits shifting unjust or unreasonable costs to other classes. The approved large-load tariff directly assigns interconnection and interim capacity costs to the large-load customer and provides for direct assignment of any transmission shortfall. It does not, however, directly assign the cost of new generation built to serve large loads. In File No. ET-2025-0184, the Office of Public Counsel recommended that incremental generation and transmission costs be directly identified and assigned to large-load customers. I support that recommendation. I ask the Commission to state in this case that, as generation added or accelerated to serve large loads comes online, its cost will be directly assigned to the large-load class, so that the families I represent are never asked to finance a power plant built for a data center.
My constituents are not asking for a free ride. They are asking that a third double-digit increase be earned, explained, verified, and limited to what the law allows.
Respectfully,
Rep. Brad Christ, 96th District