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Q1 2023 Exelon Corp Earnings Call

Participants

Andrew C. Plenge; VP of IR; Exelon Corporation

Calvin G. Butler; CEO, President & Director; Exelon Corporation

Carim V. Khouzami; President and CEO of Baltimore Gas & Electric Company; Exelon Corporation

David M. Velazquez; EVP of Utility Operations; Exelon Corporation

Gil C. Quiniones; CEO of Commonwealth Edison Company; Exelon Corporation

Jeanne M. Jones; Executive VP & CFO; Exelon Corporation

David Keith Arcaro; Executive Director & Lead Analyst of Utilities; Morgan Stanley, Research Division

Jeremy Bryan Tonet; Senior Analyst; JPMorgan Chase & Co, Research Division

Paul Andrew Zimbardo; VP in Equity Research & Research Analyst; BofA Securities, Research Division

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Shahriar Pourreza; MD and Head of North American Power; Guggenheim Securities, LLC, Research Division

Steven Isaac Fleishman; MD & Senior Analyst; Wolfe Research, LLC

Presentation

Operator

Hello, and welcome to Exelon's First Quarter Earnings Call. My name is Gigi, and I will be your event specialist today. (Operator Instructions) Please note that today's webcast is being recorded. (Operator Instructions) It is now my pleasure to turn today's program over to Andy Plenge, Vice President of Investor Relations. The floor is yours.

Andrew C. Plenge

Thank you, Gigi. Good morning, everyone. We're pleased to have you with us for our 2023 first 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.
You may have seen that we issued our earnings release this morning. That release, along with the presentation being used for today's call, can be found in the Investor Relations section of Exelon's website.
As a reminder, the earnings release and other matters that we will discuss during today's call contain forward-looking statements and estimates that are subject to various risks and uncertainties. As a result, actual results could differ from our forward-looking statements based on factors and assumptions discussed in today's material and comments made during this call. You can find in today's 8-K and Exelon's other SEC filings for discussions of risk factors and other factors that may cause results to differ from management's projections, forecasts and expectations.
In addition, today's presentation includes references to adjusted operating earnings and other non-GAAP measures. Both the appendix of our presentation and our earnings release contain information on reconciliations between the GAAP measures and the nearest equivalent GAAP measures. We've scheduled 45 minutes for today's call. And it is now my pleasure to turn the call over to Calvin Butler, Exelon's President and CEO.

Calvin G. Butler

Thank you, Andy, and good morning, everyone. We appreciate you joining us for our first quarter earnings call. Our team of 19,000-plus employees have entered this first full year of operations after the separation, excited to lead the energy transformation as a premier T&D utility, and it shows in our results. We are delivering our plan on course.
I'll start on Slide 4, covering our key messages. We delivered strong year-over-year growth in the first quarter, earning $0.67 per share on a GAAP basis and $0.70 per share on a non-GAAP basis. These results keep us on track to deliver earnings within our guidance range of $2.30 to $2.42 per share for 2023. This is despite the impact of mild weather, which is a testament to the stability offered by the progressive largely decoupled rate-making mechanisms in our jurisdictions.
Operationally, we have our best on record reliability performance at all 4 of our utilities with ComEd continuing to operate in the top decile. As it pertains to our rate cases, we are well underway in a number of jurisdictions with 3 new filings initiated since the fourth quarter earnings call, building a stronger, smarter, resilient and cleaner grid requires investment. We are engaging with our stakeholders to align on our shared goals and ensure this investment is compensated fairly as it is integral to our strategy.
On February 15, Atlantic City Electric filed a distribution base rate case with the New Jersey Board of Public Utilities to support investments in infrastructure to maintain safety, reliability and customer service for our customers. It also includes initial recovery for ACE's smart meter deployment which brings a host of benefits that Jeanne will highlight shortly.
BGE filed its second multi-year plan on February 17 and Pepco D.C. filed its second MYP on April 13. Both MYP rate cases incorporate investments that enable the energy transformations guided by jurisdictional policy whether it be the Climate Solutions Now Act in Maryland or D.C.'s transformative energy policies like the D.C. Climate Action Plan.
Finally Pepco expects to file its second MYP, our final anticipated base rate filing for the year with the Maryland Public Service Commission later this month. Jeanne will take the time to highlight the next steps across our open rate cases and provide additional details on the regulatory calender shortly. Now in working through these rate cases, we have several new commissioners expected across our jurisdictions including new chairs in placed or pending in Illinois, Maryland and Pennsylvania. And new appointees in Illinois and Maryland.
We appreciate the service of the outgoing commissioners and are excited to begin working with the newest members on this next phase of the energy transformation.
Given this transformation will be measured in decades, it reinforces the importance of building a shared forward-looking understanding of priorities and needs across a variety of stakeholders, which is accomplished through transparency and collaboration. This kind of approach supports continuity through the inevitable evolution in legislative and regulatory bodies over time.
Lastly, we continue to reaffirm our existing expectations to be at the midpoint or better of our 2021 to 2025 and 2022 to 2026 6% to 8% annualized earnings growth ranges with dividend growth to match underpinned by the investments we are making on behalf of customers and earning an annual consolidated ROE in the 9% to 10% range during that time.
Our diverse deconcentrated capital expenditure plan and predictable investment recovery frameworks contribute to the compelling risk-adjusted total shareholder return of 9% to 11% that we offer investors between our dividend and earnings growth through 2026. Our results are built on an operating philosophy that relentlessly pursues excellence, as is highlighted on the next slide.
Slide 5 reviews our operating performance for the start of 2023. Beginning first with reliability. You can see that our utilities continue to operate at industry-leading levels, both in terms of outage frequency and outage duration. Both ComEd and PHI achieved best on record outage frequency performance. And all 4 utilities achieved best on record system outage duration performance.
Now consistent with our focus on continually improving operations and customer value, we are now using total system outage time versus average customer outage duration as one of our reliability metrics. This refined metric better ensures we are comprehensively capturing the customer experience on an equitable basis in each of our service territories. This performance is a testament to the hard work that our employees put in each and every day. It also speaks to the effectiveness of the investments in reliability and resiliency that our utilities have made providing a great foundation as we discuss with our stakeholders the next phase of investments to support their energy transformations.
As it pertains to safety, PHI is now operating at top decile levels and PECO is in the top quartile, both up from the second quartile last year, while BGE improved to second quartile from third quartile.
Now while we are encouraged by the progress we have made on the safety front in the company, we have a safety-focused zero tolerance culture. We are using targeted training at each of our utilities, such as ergonomics awareness training at ComEd in light of its moved out to second quartile to address the areas driving underperformance.
Gas odor response continues its run of top decile performance with all 3 utilities performing at world-class levels in 2023. PHI responded to all gas orders in less than an hour, achieving a perfect rating.
Lastly, I want to spend a moment talking about customer satisfaction. As you can see, our 4 utilities are operating in the second quartile after 3 out of the 4 closed out 2022 in top quartile. While each operating company has unique areas to address, there are a few common trends. For instance, the block for communicating with customers around outages and reliability continues to be raised. As our customers increasingly rely on the grid, whether it be working remotely or charging their cars, they need access to information real time.
We are excited about the investments we have made in the tools they already have at their disposal, such as mobile apps, and we will continue to invest in enhancements focused on improving communications. Although another area of focus is new technology through upgrades to our customer care and billing software. These investments will allow us to provide more options to meet customer needs around billing and other services and enhance self-service options for those experiencing slower turnaround times.
But perhaps the primary driver of lower customer satisfaction scores relative to the latest available benchmark as of 2021 is one that is not unique to Exelon. While the inflationary environment has shown signs of abating recently, particularly around energy supply costs that are a pass-through for us, customers have been impacted by increased costs in many aspects of their lives and businesses. That's why we will continue to focus on maintaining more than average rates and overall bill levels.
Again, rates in our cities are 23% below the average rate in the largest cities in the United States. And we have connected customers to increasing amounts of assistance as well, totaling over $1 billion the last 2 years, but we have to continue to articulate the value customers are receiving, and we will maintain focus on managing our own cost to live -- to deliver our product as efficiently as possible.
We also addressed bill impacts in our approach to rate cases. Our proposed deferral of 35% of ComEd 2024 rate increase to 2026 is just one example. At this, PECO D.C. proposed expansion of the Residential Aid and Arrearage Management Programs. In short, we are leading the industry and customer satisfaction remained a top priority for us.
Now Jeanne will provide an update on our financial performance for the first quarter. Jeanne?

Jeanne M. Jones

Thank you, Calvin, and good morning, everyone. Today, I will cover our first quarter financial updates and progress on our 2023 rate case schedule. And I will also highlight the ways in which our utilities are advancing us smarter, stronger and cleaner energy grid to better serve all customers.
Starting on Slide 6, we show our quarter-over-quarter adjusted operating earnings [loss]. As Calvin mentioned, Exelon earned $0.70 per share in the first quarter of 2023 versus $0.64 in the first quarter of 2022, reflecting growth of $0.06 per share over the same period. The earnings growth was driven primarily by $0.10 of higher distribution and transmission rates associated with incremental investments and completed rate cases including the uplift from higher treasury rates impacting ComEd's distribution ROE.
We also benefited $0.03 from(inaudible) other onetime items from 2022, including the discontinued operations adjustment from the separation and the customer refund in Illinois. These items were partially offset by $0.05 of lower earnings due to the sustained warmer than normal temperatures throughout the winter impacting our non-decoupled jurisdictions in Pennsylvania and Delaware as well as $0.02 of higher interest expense due to the rising interest rates and higher level of debt at the holding company.
Results of $0.70 per share in the first quarter reflecting approximate 30% contribution at the midpoint of our projected 2023 operating earnings guidance range. Historically, we have earned on average 28% of full year earnings in the first quarter. Heading into the 2023, we expected Q1 to be slightly ahead of historical patterns due to the completion of rate cases at PHI and PECO, rising treasury rates impacting ComEd's ROE relative to 2022 and the absence of the onetime items from separation.
However, we are also seeing -- we were also seeing the impact of unfavorable weather at PECO and DPL Delaware.
While the weather tempered some of that upside, we still delivered earnings ahead of expectations due to timing at PHI and the recognition of carrying costs related to the carbon mitigation credit balance at ComEd.
Looking at it as a next quarter, after factoring in some PHI and year-over-year timing items, the relative EPS contribution in the second quarter is expected to moderate at approximately 17% of the midpoint in our projected full year earnings guidance range. The combination of Q1 and Q2 will result in achieving approximately 47% for projected full year earnings through the first half of 2023. This puts expected results for the first half of 2023, in line with how we performed last year, delivering 48% of our full year earnings in the first half of 2022.
On a full year basis, we expect the $0.05 of unfavorable weather experienced in the first quarter to be offset with the combination of O&M levers across the platform, favorable depreciation of PECO and the full year earnings impact of the carrying costs associated with the carbon mitigation credit regulatory asset balance.
With this continued increase in rate base as we deploy capital for the benefit of our customers and our disciplined approach to cost management, we remain on track to deliver expected earned returns at the utilities within our 9% to 10% targeted range by year-end and are from our full year operating earnings guidance of $2.30 to $2.42 per share in 2023.
In line with past practice, we would not expect to revisit projected 2023 guidance until the third quarter. And recall, our goal is always to achieve the midpoint or better of that range.
Lastly, we are reaffirming the fully regulated operating EPS compounded annual growth target of 6% to 8% and from 2021 and 2022 guidance midpoint through 2025 and 2026, respectively, with the expectation to be at the midpoint or better of that growth range.
Turning to Slide 7. As Calvin mentioned, there have been some important developments on the regulatory front since the last earnings call.
Let me start by reminding you of 2 electric distribution rate cases in progress. First, Delmarva Power Delaware has revised the revenue request for $47.8 million increase based on an updated tax period in its electric distribution rate case with full proposed rates going into effect on July 15, subject to refund. We expect a decision in the second quarter of 2024.
Additionally, as discussed previously, ComEd filed its electric distribution multiyear rate plan in January. And we expect intervenor testimony from the Illinois Commerce Commission staff on May 22, and the evidentiary hearing to be held in late August as the next key milestones. A final order in the ComEd multi-year plan case is expected no later than December 20.
ComEd also filed its 2022 formula rate reconciliation, seeking recovery of $247 million in rates effective January 1, 2024. A key driver of the increase is the impact of U.S. Treasury yields starting to increase from their depressed levels experienced during the COVID-19 pandemic, which, as you'll recall, was reflected in 2022 earnings. First, fact sheet and order is expected on the reconciliation by December 17.
Since the last earnings call, there were 3 new rate cases filed. First, on February 15, Atlantic City Electric filed a distribution base rate case with the New Jersey Board of Public Utilities, seeking a revenue increase of $105 million, reflecting an ROE of 10.5%. The filing supports critical investments to enhance service and deliver safe, reliable and sustainable energy for customers through key programs, including the company's EV Smart Electric Vehicle Program, and deployment of the smart energy network program, which I will highlight later in the presentation.
Because of these sustained efforts to modernize the energy grid, ACE customers experienced the most reliable energy service ever in 2022, with the lowest frequency of electric outages on record.
As permitted by New Jersey Law, ACE may implement full proposed rates on November 17, subject to refund and a final order is expected in the first quarter of 2024.
Next, BGE filed its second multiyear plan with the Maryland Public Service Commission on February 17, which we provided preview into on our fourth quarter earnings call. Covering the years 2024 through 2026, the multi-year plan details how BGE will invest nearly $2.3 billion annually in the electric grid and natural gas system and nearly $400 million total in electric vehicles and building efficiency programs. These investments will inject nearly $36 billion into the local economy and support an estimated 72,000 jobs as indicated in a study performed by Towson University.
Importantly, BGE's infrastructure plan includes more than 300 projects and maintenance programs designed to continue meeting customers' needs and lay the foundation for the state of Maryland to reach its goal of net 0 emissions by 2045. An order is expected on the proposed plan in December of 2023.
As you've noted, we also requested that the commission provided an order on the proposed reconciliation of 2021 and 2022 cost totaling $77 million of under-recovery in parallel with the order on the second multi-year plan.
That brings me to Slide 8, where I want to take a moment to highlight Pepco DC's Climate Ready Pathway multiyear plans that was filed with the Public Service Commission of the District of Columbia on April 13. Pepco is requesting $190.7 million revenue increase over the 2024 to 2026 period to recover planned capital investments that are intended to enhance the reliability, resiliency and security for the local energy grid and to further support the district's goal to be carbon neutral by 2045. One of the most ambitious climate goals for the nation.
Specifically, this will be done through investments in equipment and infrastructure that will enable the integration of more renewal energy, such as solar. They will also help customers access and adopt cleaner energy technologies, like electric vehicles. And they will allow Pepco to manage load to ensure the electric service customers depend on is available when they need it. Of the many maintenance programs included in Pepco's proposed multiyear plans, one involves replacing nearly 24 miles of aging power cables with newer and more modern cable so that all customers experience high quality of service and high reliability.
It is the customers and communities that are at the forefront of Pepco Climate Ready Pathway plans, with a central focus on improving the social equity and advancement of affordability of electric service. As part of that commitment, the company is hoping that planned filing proposes several measures to address affordability, including expanding enrollment for the Residential Aid Discount Program to include any customer who qualified for any low-income program in the district as well as enhancing the Arrearage Management Program.
Expansion of these programs would help to further extend the reach of valuable energy assistance, which in 2022 alone provided approximately 21 million to nearly 30,000 Pepco customers in D.C. or on average, $700 per customer.
Pepco's low-fare plans comprehensively works to keep service affordable, foster a cleaner energy future and improve reliability, resiliency and security through significant investments. This influx of resources directed towards accommodating the next phase of D. C.'s energy transformation is expected to inject more than $580 million in the local economy and support more than 3,800 full-time jobs.
An order is requested from the DC PSC by February 2024 based on a proposed 10-month procedural schedule. All our ongoing rate cases are proceeding in line with expectations, and you can find further detail on Slides 20 through 24 of the appendix.
Moving to Slide 9. During the first quarter, we continued to invest capital for the benefit of our customers and are on track to meet our $7.2 billion commitment for 2023. These investments in energy infrastructure are vital to maintaining the high standards of service that we have in serving our customers, while also preparing the grid for the clean energy transformation.
Today, I'm going to talk about how Atlantic City Electric is enhancing the customer experience in South Jersey through the Smart Energy Network Program, the last major initial smart meter deployment program planned for Exelon utilities. Smart meters are foundational to a smarter power grid. They enable customers to better understand real-time energy usage in homes and businesses, and they provide enhanced information to make our systems more efficient and resilient. With the broad installation beginning in September of 2022, ACE employees and their contract partners have been steadily upgrading approximately 30,000 meters per month, and all of 568,000 meters are expected to be replaced by mid-2024.
When fully installed and operational, the Smart Energy Network is expected to deliver $416 million in operational and customer benefits over the next 15 years.
Most notably, these benefits include the ability to restore power faster and more efficiently. And they provide tools that help customers use less energy and save money as well as the reduced need for estimated billings and the capability to provide more detailed outage information when outages occur.
They also allow for better integration of new clean energy technologies, including solar, which has experienced the highest penetration in ACE's territory relative to all of our other jurisdictions at approximately 25% of net peak demand.
To put a stand of benefits into perspective, on an annual basis, ACE expects to eliminate 134,000 truck rolls, reduce major store operations and cost by 10% and save $4.5 million in annual contracted meter reading costs. The Smart Energy Network is a critical step in advancing a cleaner energy future for South Jersey and helping the state meet its climate goals. Leveraging expertise from its sister utilities, ACE is committed to using its collective resources to ensure all customers realize the full benefits of this meter upgrade initiative. This is the power of Exelon platform.
I was in place with a discussion on our balance sheet on Slide 10. As covered on our last earnings call, we project a 100 to 200 basis points of cushion on average over our guidance period for our consolidated corporate credit metrics above S&P and Moody's downgrade thresholds of 12% over the guidance period, demonstrating our commitment to maintaining a strong balance sheet. If the corporate alternative minimum tax was not mitigated through an inclusion of repairs in its calculation, we anticipate being at the lower end of that 13% to 14%. We continue to await guidance from the treasury, which we are optimistic they will issue before year-end and we remain encouraged by the engagement they have in understanding how its implementation can impact energy infrastructure providers like Exelon.
From a financing perspective, we have successfully raised $2.5 billion at corporate and approximately $2 billion for ComEd and the PHI entity. To date, we have completed over 80% of our planned 2023 long-term debt financing needs. This positions us well for any unrespected market volatility in the balance of the year. We continue to see strong investor demand for our debt offerings, which is a testament to the strength of our balance sheet and to our value proposition as a premier T&D utility with low-risk attributes.
To reiterate our equity needs, there has been no change in our guidance to issue $425 million of equity at the holding company by 2025. We'll continue to update you as we make progress on that plan.
Thank you. And I'll now turn the call back to Calvin for his closing remarks.

Calvin G. Butler

Thank you, Jeanne. Let me conclude our prepared remarks with a reminder of our priorities and commitments for 2023 and as the premier T&D utility. It starts with operations, operating safely and reliably is our core mission, And you can count on us to focus on that every hour of every day.
Secondly, as you heard from Jeanne, we have a full set of rate case proceedings well underway that will set our path for the next 3 to 4 years, given our multiyear plan frameworks. The transformation of our energy system requires a lot of coordination and alignment and we welcome the opportunities to engage with stakeholders on the most effective and efficient means to meet our jurisdictional goals.
And third, we are focused on executing financially. We're looking to deploy $7.2 billion of capital this year more than ever before while maintaining earned ROEs in the 9% to 10% range and delivering on our 2023 earnings guidance range of $2.30 to $2.42 per share. We have made great progress on our financing plan for the year while also laying groundwork for future financing needs, and we continue to focus on ensuring our balance sheet is strong.
Last, we continue to focus on maximizing the value we provide our customers and ensuring we are serving them in an equitable manner. As an example of how we are innovating to support a more affordable energy transformation.
I'll point to BGE's recent partnership with the City of Baltimore. Specifically, BGE will share responsibility for improving the city's 700-mile conduit infrastructure, reducing the amount of city paid for maintenance capital improvements and allowing BGE to take advantage of its contracting and construction efficiencies, all while ensuring a healthy conduit system to provide more reliable and affordable power. And beyond our direct operations, we will continue to support our communities beyond providing cleaner, more reliable energy such as through our more than 75 workforce development programs across our 6 utilities. Indeed, investments like ACE's Smart Energy Network that Jeanne highlighted benefit greatly from those programs. In anticipation of this investment program, a 6-year $6.5 million job training program was established in 2018 to educate the workforce needed to fill the energy jobs of the future in New Jersey.
14 of our talented employees deploying the smart meter technology are graduates of that development program established 5 years ago, and we expect to hire more than 15 additional graduates by the end of June, reinforcing our vision of facilitating an energy transformation that will stretch over generations of thoughtful planning and coordination. We look forward to building on the progress made in these first 3 months and meeting our commitments in 2023. We are delivering on course.
Thank you, and we welcome your questions.

Question and Answer Session

Operator

(Operator Instructions)
Your first question comes from the line of Shar Pourreza from Guggenheim.

Shahriar Pourreza

Just if we could maybe start with Illinois. I mean, we obviously saw the trial outcome last night. I realized you guys have taken a lot of steps since 2020 to improve. But any sort of high-level read-throughs to the regulatory construct at this point or anything remaining for ComEd from a legal or even judicial standpoint?

Calvin G. Butler

Yes. Thank you, Shar. So first, from the start, as you know, Shar, we have cooperated fully with the investigations conducted by the government and our regulators. The deferred prosecution agreement signed in 2020 resolved the Justice Department's investigation into ComEd. But we want to be clear that we have done much more than that. We have made substantial changes to our contracting lobbying and compliance operations to ensure that the conduct that was at issue in the trial does not happen again at all levels, from my office and throughout the leaders of the organization and the 6,300 employees who keep the lights on every day in Illinois. We are committed to the highest standards of integrity and ethical behavior for our business. We have the privilege and the responsibility of roughly well over 10 million customers, and we do not take that lightly.
But I want to have Jeanne spent some time talking about the other issues that have come as a result of this. And then I'm going to ask Gil, CEO of ComEd, to kind of walk through to your question, the regulatory and legislative proceedings as we move forward. Jeanne?

Jeanne M. Jones

Yes. Thanks, Calvin. So as Calvin mentioned, the deferred prosecution agreement and this resolved our model of the Department of Justice. But there have been a couple of things, as we've outlined in our 10-Ks and Qs that were legal matters surrounding the advanced leading (inaudible). And I'll just touch briefly on this. And again, these will all be disclosed when the Q comes out and they continue to be updated, and you'll see it when the Q comes out later today. But we did have a security suit derivatives and derivatives suits and consumer fraud suits and then there was the [FCC] investigation.
So just checking through those. The security suit was filed in '19, and there's is a next court status for that, that's late in June. But based on recent developments, we have booked a probable loss in this matter of $173 million. But that is expected to be fully recovered by insurance. So there is no earnings or cash impact from that. There are 3 derivatives suits pending, including one filed in '21, and there were a couple of new ones filed in April and May of this year. They all assert similar claims, and there's no update from a financial perspective on those. But I would remind you that, that one is a little bit different than that, any amount recovered were resovled in cash reciept to the company and those types of lawsuits.
And then there were 3 consumer fraud cases filed, 2 of which have been dismissed, and we just argued our motion to dismiss the remaining case in late April.
And then lastly, the FCC investigation continues, we continue to cooperate fully, but no update on that. And so that's just kind of the status update. But again, we give kind of the play-by-play in the Q for those.
And so maybe I'll turn it over to Gil to talk through the multiyear plan.

Gil C. Quiniones

Our proposed grid modernization plan and multiyear rate plan support and its in 100% alignment with the goals of the Climate Equitable Jobs Act and the Illinois Energy and Environmental Policy goals of an orderly and equitable energy transition here in our state. It is a product of extensive stakeholder process with multiple parties over the past couple of years. As you know, we filed our proposed rate case in January of this year and we look forward to continue working with all parties openly and collaboratively. As Jeanne mentioned before, the intervenors are scheduled to file their testimony this month. Hearings will be in August and the order in December of this year.

Calvin G. Butler

So Shar, we're on course, and I appreciate that question.

Shahriar Pourreza

Perfect. And then just lastly, Maryland, obviously, Calvin set a pretty aggressive offshore wind target last month, 8.5 gigs by '31. I guess as we look at the plan today, could we see incremental transmission opportunities at Delmarva, I guess, put differently, what do you embed in plan at this point?

Calvin G. Butler

So if I can, what you're asking is that from Maryland's offshore legislation that they just recently passed, could that have a spillover that's happening along in Delmarva. Is that the question there, Shar?

Shahriar Pourreza

Perfect. And as we're thinking about transmission opportunities, yes. correct.

Calvin G. Butler

Yes. I think, first and foremost, Shar, the legislation does present an opportunity for Exelon to participate in transmission. The amended legislation, as you know, requires that PJM conduct a study of the transmission system and taking a more holistic approach with that but it will look nice about it, it will prioritize leveraging existing infrastructure, permitting risks and grid challenges, use of open access of collective transmission systems and avoiding any single contingency items. So this all goes to how Exelon can differentiate itself from others. And as you know, the state has a goal of reaching 8,500 megawatts of offshore wind energy capacity by 2031, and I think we are well positioned to be a part of that. And I have David Velazquez next to me, who oversees our transmission. David, is there anything to add there?

David M. Velazquez

Sure, just to add -- yes, we do think that they're potential for incremental opportunities on transmission there. We've not included anything in the current plan for opportunities that are there. And the way the legislation reads by the beginning of July in 2025, the PSC or the -- the PSC will direct PJM to issue kind of a competitive transmission solicitation for the transmission that's needed to support the offshore wind.

Operator

Our next question comes from the line of Paul Zimbardo from Bank of America.

Paul Andrew Zimbardo

Great. If you could -- could you discuss the O&M savings drivers you mentioned in the script and just at what segments you're expected to realize the offsets for unfavorable weather. I think you said across the platform, it sounds broader than, I believe is PECO and Pepco where the impacts were from weather?

Jeanne M. Jones

Yes. I'll hit on it and then Calvin feel free to add, too. So when you think about the $0.05, it's a combination of levers. And I'll start with what we did to sort of enter this year in a conservative and substantial matter. So we -- you may remember, we had the weather and storm favorability last year, and we did some derisking at the end of the year to help us in '23 and beyond. And so that's helpful heading into the year.
Second, as you think about where other volatility lies and interest rate exposure, we really mitigated that risk by having completed our sole corporate financing in the first quarter. So locking that in. And you can see that in the sensitivities in our exact. We have no exposure really on that. And then as you talked about, right, we do have leverage across the business. It would be more focused on areas that hit the bottom line, but then remember at the corporate entity, dollar-saved filter down to all the areas as well. And so it'ill be a combination across the platform.
In addition to that, as I mentioned, we do see some favorable depreciation at PECO relative to expectations.
And then finally, we had if you think about the $0.05 in totality, we had $0.01 of the favorability from the carbon mitigation credit deposit rate on that reg asset on a full year basis, that's probably going to be about $0.03. So when you put all that together, clear line of sights offsetting the $0.05 and feeling good about the rest of the year and delivering in the range at midpoint or better.

Paul Andrew Zimbardo

Okay. Excellent. And then changing topics. I saw (technical difficulty) the same opportunity. Could you quantify how much that could be and just confirming if there's any offset to rate base, those kind of items are factored into the plan?

Calvin G. Butler

Shar, you cut out midway through your question. Would you mind repeating that, please? I mean, Paul.

Paul Andrew Zimbardo

Sure. I was asking about the IIJA, the Infrastructure and Jobs Act just I saw that headline during the quarter. If you could quantify what the opportunity could be for Exelon. And just if there are any offsets to rate base from kind of federal financing if that's incorporated in the plan today?

Jeanne M. Jones

Yes.

Calvin G. Butler

I'll let Jeanne take that, and then we'll go from there, please.

Jeanne M. Jones

Yes. Thanks, Calvin. So the $700 million is what we've applied for. So it's a really competitive process. So it's hard to estimate what portion of that we'll get. But what I can tell you is we haven't factored it in. So it's the -- we're not expecting any meaningful impact to rate base to finance the needs, we're reaffirming everything. And then we'll continue to update that -- update you on that as that progresses.

Calvin G. Butler

And I would just add, Paul, understanding as we said before the IIJA and the IRA create tremendous opportunity for us as Exelon utilities, specifically to partner with our jurisdictions and drive this energy transition faster. And it also goes to the affordability factor of what we do and how we do within our jurisdictions. So we're working it hard, and we're partnering and looking for all the opportunities to really increase in our investments, but more importantly, partner with our communities in this endeavor.

Operator

Our next question comes from the line of Steve Fleishman from Wolfe.

Steven Isaac Fleishman

Calvin. So just on the Illinois, I guess, we're going to get the recommendation soon on the multiyear, the new framework. So obviously, things like capital structure and ROEs and I assume rate base are the key variables. Are there any other -- and then, I guess, maybe incentives. Are those kind of the key issues to monitor in the recommendations or any other things that we should be watching for?

Calvin G. Butler

Yes. Thank you. I'll let Gil take that in because he's been intimately involved in the process. Gil?

Gil C. Quiniones

I think you pretty much captured those are the items that we anticipate parties are going to be interested in.

Steven Isaac Fleishman

Okay. And then I do -- I think there was a minimum capital structure allowed under the bill. Is that still kind of through the 50%?

Gil C. Quiniones

Yes, I'd say harbor at 50%.

Steven Isaac Fleishman

Okay. And the -- I guess my other question, the carrying charge or recovery on the CMC deferral. This is just CMC costs that you're not yet recovering in rates that you're earning a carrying charge on?

Jeanne M. Jones

That's right. Yes. It's -- it earns a customer deposit rate, which was 0 in '22 and then was reset at the 5% at the end of last year, early part of this year. And so outside relative to expectations for this year. But that reg asset is expected to be collected and wind down by May of '24. So it's not a future years earnings, but it is helpful this year.

Steven Isaac Fleishman

Okay. And then finally, on the IRS implementation of IRA and the minimum tax. Is there any -- has there been any developments or sense of outcome there, I guess, on the, I guess, particularly the repair tax issue or just kind of sitting and waiting?

Jeanne M. Jones

Yes, same status. So still, about $200 million per year. We -- that's all reflected in our guidance and our first -- from an earnings and a credit metric forecast and we give you kind of the sensitivity of where we'll be, if it isn't alleviated and where it will be, if it is. Still, optimistic we get regulations by the end of the year and still ongoing discussions with us, EEI, the industry and treasury on the repair deduction and in general, how the corporate alternative minimum impact energy providers like Exelon. And some further dialogue recently, I would say about why the utility industry is different given the capital-intensive nature of our business. And so just ongoing dialects, but no new changes to the assumptions or estimates.

Operator

Our next question comes from the line of David Arcaro from Morgan Stanley.

David Keith Arcaro

There's a new Chair in Illinois. I was just wondering if you have had any initial dialogue or perspectives that you might offer on how it might be to work together with the ICC going forward, especially given that it's such a busy regulatory year.

Calvin G. Butler

Yes. David, thank you for the question. I think as I said in my opening comments, the transition of leadership and commissioners is part of the process. And so we are really engaging with all stakeholders in a very collaborative process as we move forward.
But directly to your question, the Governor Pritzker did accept the resignation of Chair Zalewski and has nominated the incoming for Doug Scott, who, as you know, used to be the former Chair of the commission and was very instrumental in the tracking and creating of the Climate Equitable and Jobs Act. And there has been communication, but the communications have been around moving the state's goals forward. And we have heard nothing to date that is taking that are derailing those efforts. And as Gil alluded to earlier in Jeanne, we're still expecting a final order on ComEd for your multiyear plan by December 20. So also along with the new Chair, they're getting a couple of new commissioners. And again, that process continues to move forward.

David Keith Arcaro

Okay. Great. And I was also wondering, with the ComEd and BGE reconciliations. I was -- I just wanted to check. Do those -- do there tend to be big swing factors in those regulatory processes? Or are they pretty standardized just in terms of what costs fit in? And are they smooth recovery processes typically?

Jeanne M. Jones

Yes. So on the -- on ComEd, the reconciliation they filed is for the 2022 -- -- under the 2022 formula rate. So this is a reconciliation that has been going on for 10 years. So I think that, that one is a little bit more straightforward. And as I mentioned in my prepared remarks, part of that is just the cash collection of the true-up on the treasury rate. Under the formula rate, you set the rate based on prior year treasuries and then you can recognize it in earnings, but then you true it up in rates later. So that one's pretty standard in the sense that it's been going on and it's sort of clear.
The BGE one, though, is the first reconciliation and a multiyear plan in Maryland. And so this will be the first time we're going through it. But there's a framework there to work through. And so that's -- but that order will come in December of this year as well. And I think it's important for this year, but I think it's really important in terms of kind of what you mentioned, right, setting the precedent going forward so that we know what is recoverable, what's not. And you get into a place where you can say, okay, if there's a variance here, I can put up a receivable or reg asset or conversely, if we do well, we put up a liability and we'll get that back to customers. So I think going through that will be helpful as it has been, we've seen in ComEd, once you get through it the first time, it's very helpful going forward.

Operator

Our next question will be the last one coming from the line of Jeremy Tonet from JPMorgan Securities LLC.

Jeremy Bryan Tonet

Just wanted to dial into Maryland, a little bit more if we could. We've seen changes in the commission and there are these kind of policy goals out there. Just wondering how you see that effect in BGE, both the electric and gas side? Or is that kind of offsetting over time? Or just wondering, updated thoughts about the future of gas there and how that impacts Exelon?

Calvin G. Butler

Yes. So great question. And with me in the room, I have Carim Khouzami, who's the CEO of BGE. But let me take the initial piece, and then I'll turn it over to Carim to see if he has any additional information.
So just like Illinois, Jeremy, we're having a transition of a Chair of our commission as well as a couple of Governor Moore appointees. Governor Moore has taken a very aggressive position to continue to push decarbonization and transportation electrification throughout the state of Maryland, really rivaling it with California and Illinois in the like of moving forward.
Having said that, there is an alignment with the jurisdictional goals of what BGE is doing as well as Pepco Maryl. The gas portfolio within our business is, we believe, is critical to the long-term decarbonization of the industry as we are going through the process of replacing the gas infrastructure within Maryland, we continue to reduce greenhouse gas emissions in that effort and we've attacked it as a portfolio approach because reliability of the system and affordability for our customers is critical in our endeavors. So we have communicated that with the state. BGE has been very involved in those conversations, and I'll let Carim just take us a step further.

Carim V. Khouzami

Thank you, Calvin, I think you hit all good points. One of the key points to highlight is in last year's legislative session in the Climate Solution Now Act, which set forth state goals for us to achieve as is economy-wide laid out a number of working groups where they would determine what is the right path for Maryland going forward. BGE and the other Maryland utilities are at the table with all the other interested parties, and we're working through those issues now, and that will be including at the end of this year with recommendations.
As Calvin mentioned, there are a number of ways to get to the state goals. We see the pathway that is the most affordable, reliable and resilient as being one that still includes gas as part of the infrastructure. And we're working with the groups to kind of talk through what is the right path forward for Maryland, and we do have confidence that gas will be part of the future.

Jeremy Bryan Tonet

Got it. That's very helpful there. And then just pivoting to results and just a smaller question overall, but I was hoping you could illuminate a little bit of color on the GAAP to non-GAAP reconciliations there as far as the change in environmental liabilities and the change in FERC liability. Just a little bit more color on what those items were.

Calvin G. Butler

Sure.

Jeanne M. Jones

Yes, sure. So on the environmental liabilities, that's the PHI is the legacy issue where we continue to update estimates for remediation of that. So we just slightly increased the reserve there. On the ComEd item, ComEd and on the FERC had an audit began in '21. We got draft findings earlier this year. And just based on ongoing discussions, we booked about $15 million of a probable loss. So that's ongoing. But that's kind of the nature of the 2 and they're infrequent unusual, as we carve them out from an operating perspective.

Calvin G. Butler

I think that was the last question?

Operator

Yes, that was the last question and at this time, I would like to turn the conference back over to Calvin Butler for closing remarks.

Calvin G. Butler

Thank you, Gigi. And I just want to take a moment to say thank you for joining us today. I appreciate your engagement and all your questions. And with that, it concludes the call. Have a great day.

Operator

Thanks to all our participants for joining us today. This concludes our presentation. You may now disconnect. Have a good day.