Missing IMEA Public Power Data Prevents Full Local Oversight in Naperville
*** NOTE: DRAFT IN PROGRESS ***
The Illinois Municipal Electric Agency (IMEA) is a unit of local government in Illinois. It is a Joint Municipal Electric Power Agency that is funded by the public ratepayer dollars of the IMEA Members. And Naperville is the largest Member, providing roughly 35% of the total sales revenue from all the IMEA Members.
When a public agency makes statements about costs, savings, fair billing, or market competitiveness, those claims must be backed by verifiable evidence. And when the underlying data is withheld, aggregated, or kept behind non-disclosure agreements, those types of statements are unfalsifiable claims.
What is an “Unfalsifiable Claim”?
In both science and public accounting, a claim is falsifiable if an independent third party can examine the evidence, run the numbers, and verify whether it is true or false.
An unfalsifiable claim is structured so that no outside expert, civic researcher, citizen, or ratepayer can test its accuracy.
Unfalsifiable claims by IMEA build a wall between the agency and the public’s right to examine and understand how public dollars are being spent. And this wall serves as a shield from public accountability and the local control by effectively replacing “trust and verify” with “trust us“.
4 Ways Structural Opacity Shields Public Power from Accountability
1. The Closed-Door Barrier: No Online Video Recordings
The Question:
If our local Naperville Park District, School Boards, and City Council record and stream their public meetings, why doesn’t our multi-million-dollar public power agency?
The Problem:
While IMEA is a unit of local government subject to Illinois Open Meetings Act principles, IMEA board and committee meetings take place during hours when many cannot attend in-person or watch the meetings via webinar. And IMEA does not provide recordings of these IMEA webinar meetings for public review.
Why It Matters:
Summarized written minutes capture decisions, but they erase the debate, questions, and context. Demanding that citizens attend meetings that are convenient to IMEA staff and board members creates an artificial barrier. It asserts that governance is “open and transparent” while making public observation and oversight practically impossible for many.
Further Details:
[refer to webpage documenting IMEA response on recordings]
2. Half of the IMEA Bill Represents Coal-Fired Ownership and Associated Liabilities
The Question:
When nearly half of the IMEA bill is related to IMEA’s ownership shares of two coal-fired generating plants, why are the ownership and operational details treated like trade secrets?
The Problem:
Ownership contracts and agreements associated with the Prairie State Energy Campus (PSEC) and Trimble County coal plants apparently enforce confidentiality agreements that shield granular planning, operational and financial data from public review. But it is our ratepayer dollars that pay the financials support for IMEA which is the legal entity by which the Members “jointly plan, finance, own and operate, facilities for the generation and transmission of electrical power and energy.”
The $xxx Million Reality:
From our Naperville monthly bills from IMEA over the 12 months of the IMEA Fiscal Year 2026 (FY2026) that ended on April 30, 2026, we find $164.2 million in IMEA costs that are related to the IMEA ownership shares of the Prairie State and Trimble County. That $164.2 million represents roughly half (47.68%) of the $344.4 million total that IMEA billed to the Members in FY2026. $56.0 million for Prairie State operating expenses, $29.9 million for Trimble County operating expenses, xx million for the coal plants reitrement fund, 78.3 million for debt service, and xx for Prairie State and Trimble County capital expenses .
These represent continuing expenses and liabilities which must be paid by the ratepayers until such time as this existing debt is retired and the plants are closed down.
Why It Matters:
IMEA routinely asserts that its ownership shares in these coal-fired generation assets remains economically advantageous. However, because operational details, forecasts, capital expenditures, and risk assessments are shielded behind non-disclosure, the public is barred from evaluating the true costs and risks.
Claims that do not provide those ownership sourced details cannot be falsified. Claims of economic benefit remain a closed loop that cannot be verified by the ratepayers who are responsible for paying the costs of ownership and bearing the financial risks
Further Details:
3. The IMEA Socialized “Innovation Tax”
The Question:
Can a public power contract legally penalize a city for investing in modern, money-saving technology like battery storage?
The Problem:
IMEA’s socialized accounting treats distinct regional transmission grids (PJM vs. MISO) as identical, hiding significant zonal rate disparities behind high-level summaries. Should Naperville—representing 35% of agency revenue—attempt to deploy a 10 MW Battery Energy Storage System (BESS) to shave local coincident peaks and reduce system reliability (capacity) and transmission charges, the contract structure acts as an Innovation Tax where there appear to be two conflicting choices.
Forced Cost-Shifting (Choice A):
Under standard tariff formulas, a 10 MW peak reduction yields ~$2.1M in gross base savings for Naperville ($9.50/kW Power Supply + $8.03/kW Delivery). However, because 70.3% of IMEA’s demand pool is locked in rigid debt and coal operations ($65.5M), a peak drop does not lower the agency’s underlying costs. Instead, the pool math automatically inflates the Demand Cost Adjustment (DCA), shifting unrecovered legacy debt onto neighboring municipal members.
Board Neutralization (Choice B):
To prevent this political cost-shift, IMEA’s contract allows its Board under Schedule B to declare “special situations,” pass targeted “Rate Ordinances,” or apply 12-month rolling demand ratchets. The Board can legally adjust Naperville’s Billing Demand to add back the shaved 10 MW—effectively trapping Naperville in legacy debt commitments regardless of local efficiency investments.
Why It Matters:
Without open data, Naperville council members and ratepayers are kept in the dark about how socialized rate structures penalize local independence and innovation in order to shield centralized coal-related liabilities.
Without public disclosure of proposed options and “middle ground” solutions, the public remains in the dark on the costs, benefits, and risks that they will bear through their captive ratepayer dollars.
Further Details:
4. The “Fair Share” Question: Hidden Subsidies & Partial Disclosure
The Question:
Is Naperville quietly subsidizing other municipalities while carrying 35% of the agency’s financial burden? Or the reverse, is Naperville being subsidized?
The Problem:
While IMEA recently began sharing high-level monthly PJM settlement statements, critical details remain buried. Single line items blend four distinct members into a single PJM entity. And no detailed breakdowns are provided for MISO monthly settlements where twenty-eight members blend into a single MISO entity. Energy and capacity revenues for multiple generation assets — such as Prairie State and Trimble County — are also aggregated into single line items.
A majority of Members receive compensation from IMEA for dedicated Member generation resources which can also function as emergency generation resources for those Members in the event of the loss of connection to the high voltage network of the grid operators.
Why It Matters:
IMEA asserts that Member generation payouts and socialized cost allocations are fair, and they are reviewed and approved by the IMEA board. However, without independent review, Naperville and other Members who do not own local generation may be effectively subsidizing emergency backup generators owned by other Members. Furthermore, because PJM and MISO revenues and expenses are lumped into aggregated net summaries, ratepayers cannot verify that the peak contributions of Naperville and Members match their financial cost allocations.
Likewise, IMEA asserts economic operation of Prairie State and Trimble County for which there has been no apparent independent review.
Further Details:
Moving from “Trust Us” to “Trust And Verify”
Reclaiming true public power requires replacing trust and blind faith with evidence-based governance that fulfills the spirit and intent of the words “open and transparent”. We advocate for IMEA to:
- Record and Publish Governance Meetings: Archive the webinar recordings of all board and committee meetings online for full public access.
- Open the Books on Ownership Liabilities: Reform the confidentiality agreements of ownership interests to ensure multi-decade public power commitments, planning, and operational data are subject to open records standards.
- Reconcile Rate Statements: Provide clear, published line-item mapping between the socialized costs of the monthly municipal billings and the audited financial statements. This includes the annual budgets.
- Publish Un-netted Power and Transmission Expenses Data: Continue the progress of publishing PJM statements, by publishing MISO statements, point-to-point transmission expenses, and other significant categories of expenses where net accounting interferes with transparency.
- Develop a Socialized Costs Methodology for Modern Grid Resources — Where the Process Ensures Public Participation: Carve out room for new local resources —such as Battery Energy Storage Systems (BESS)— to operate alongside IMEA’s legacy resources. The process must be open, transparent, and include the needs and priorities of the ratepayers who pay the bills.