Clean Energy Alliance of Naperville

Clean Energy Transition Off Coal-Fired Electricity

Myth of IMEA Transparency in Many Key Areas

IMEA maintains that it is open and transparent. However, from our citizen perspective, we see a lack of transparency in many key areas. The notion that IMEA is transparent in these key areas is a myth. In reality, transparency in these key areas simply does not exist.

On February 3, 2026, during the Naperville City Council meeting, we presented public comments centered on the issue of “trust.” Although we did not explicitly mention the phrase “lack of transparency,” our remarks provided examples that are inherently tied to this theme.

Lack of transparency is a major barrier to our citizen understanding of IMEA’s uses of our citizen ratepayer dollars. And lack of transparency runs contract to the purported “public power” benefits of transparency, accountability, and local control.

The main objective of this webpage is to offer additional background and context for the public comments made at the City Council meeting. Due to the three-minute time limit, it was not possible to provide a comprehensive explanation at that time. Here, we intend to elaborate further on those points to provide the more complete story.

We use the following sections to provide further description, while following the same chronological order as presented in the public comments. The purpose of the chronological order was to illustrate the continued, long running pattern.

You watch and listen to the public comments by viewing the City of Naperville’s YouTube channel recording. Here’s a timestamped link that takes you directly to start of our comments:
https://www.youtube.com/watch?v=z0_D4zHZU34&t=4745s

Lack of Transparency on IMEA Early Contract Renewal Efforts

The Public Comments:

“At a summer 2019 IMEA board meeting, I heard leadership say that contract extensions might soon be necessary.

In November 2019, NEST and I shared concerns about early renewal here at City Council.

IMEA’s November 2019 “closed” planning meeting minutes still remain sealed from the public today—more than five years later—by repeated board vote.”

Further Background and Explanation:

We first heard mention of early contract renewal discussions during the Aug 29, 2019 IMEA board meeting. And the IMEA board meeting minutes for June 20, 2019, approved at that August meeting, also documented that: “Staff is developing a Fall 2019 IMEA Board Strategic Review session to discuss State and Federal legislative issues, the status of the energy and capacity markets and the logistics of the renewal of long-term sales contracts for IMEA members which will be held in closed session.”

IMEA designed and developed the new contract proposal without input from the public and our elected city council members, until the proposed new contract was first presented in draft form at the Dec 7, 2023 IMEA board meeting.

YouTube clips of the Nov 2019 public comments on early contract renewal and the City of Naperville response are available here:
Nov 19, 2019 IMEA Contract Extension Part 1: Public Comments at Naperville City Council
https://youtu.be/nrJmdPBGQR0
Nov 19, 2019 IMEA Contract Extension Part 2: Response by Naperville to Public Comments
https://youtu.be/HaYktgi0JIk

During those years, we also documented what we were learning about new contract developments in our webpage and associated whitepaper:
Early Contract Renewal
https://cleanenergynaperville.org/did-you-know/early-contract-renewal/
“Why we believe early contract renewal/extension efforts are underway in IMEA” [whitepaper] https://drive.google.com/file/d/1cA0fseg23Kj92lvFPZGKTppxvMxWdino/view

Lack of Transparency on Carbon Capture Pilot Project Costs

The Public Comments:

“In January 2022, City Council learned from us that the carbon capture pilot project wasn’t totally “free” to Members, which was the impression from lack of information from IMEA.”

Further Background and Explanation:

We first learned through a newspaper article that the federal grant for the Prairie State carbon capture project paid 80% of the project costs. The remaining 20% cost share was covered by Prairie State owners including IMEA. IMEA’s costs are covered in the monthly bills paid by the Member ratepayers, including Naperville.

The carbon capture project closeout meeting report documented the 20% cost share total as $3,454,337 (as of Apr 1, 2022). IMEA’s responsibility would have been approximately $520,000 as a 15.17% owner of Prairie State, and Naperville ratepayers would have paid roughly 1/3 or nearly $175,000.

Here is a link to the June 14, 2022 project closeout report:
Full-Scale FEED Study For a 816 MWe Capture Plant at the
Prairie State Generating Company Using Mitsubishi Heavy
Industries of America Technology
https://drive.google.com/file/d/1kQiNJBpT_767xq5tMk5jReMWcwSwJQEU/view

Lack of Transparency in the Development of the IMEA Sustainability Plan

The Public Comments:

“In December 2023, City Council listened to our concerns about IMEA’s “Sustainability Plan,” which was developed without public input.”

Further Background and Explanation:

During the Aug 24, 2023 IMEA board meeting, we learned that an IMEA working group was holding meetings to develop the IMEA Sustainability Plan. These meetings were not available to the public.

IMEA designed and developed the IMEA Sustainability Plan without input from the public and our elected city council members, until the sustainability plan was first presented in draft form at the Oct 26, 2023 IMEA board meeting.

YouTube clips of the Dec 2023 public comments on the IMEA Sustainability Plan and the Naperville city council discussion are available here:
Dec 5, 2023 Naperville IMEA Sustainability Plan Public Comments
https://youtu.be/Uuqjj7FdLtY
Dec 5, 2023 Naperville IMEA Sustainability Plan Discussion by City Council
https://youtu.be/XmO4w1_P3nk

Lack of Transparency on IMEA Transmission Ownership Projects

The Public Comments:

“This past December, I shared that IMEA refused to provide proformas for transmission ownership projects—withholding data from the public on costs, benefits, risks, and assumptions.”

Further Background and Explanation:

At the Dec 12, 2024 IMEA board meeting, the IMEA President and CEO stated that IMEA would provide proforma estimates before asking the board to approve the LaSalle-Peru/Lima transmission ownership project. But IMEA did not publicly provide the proformas, and the project was approved by the board at the Oct 23, 2025 board meeting. IMEA again did not publicly provide proforma estimates for the further transmission ownership projects that were approved by the board at the Dec 4, 2025 board meeting.

IMEA Members’ ratepayers will bear the costs and benefits of these transmission ownership projects. For IMEA to demonstrate transparency and accountability, IMEA should be showing “the math” behind its decisions, including risks and assumptions.

IMEA denied our written request for the proforma estimates for that LaSalle-Peru/Lima transmission ownership project, citing the pre-decisional materials exception in Section 7(f) of the Freedom of Information Act.

Here is a link to a copy of the email thread with the request for “copies of proforma estimates, spreadsheets, analyses, etc. that provide the projections for the revenues/expenses of the LaSalle-Peru/Lima transmission ownership project” and IMEA’s reply citing exception 7(f):
https://drive.google.com/file/d/1SbqOYukLK3_Y1V_zNPAbnwF4gr9UywD1/view

YouTube clips of Dec 2025 public comments on the IMEA transmission ownership projects and the Naperville city council discussion are available here:
Dec 2, 2025 Naperville IMEA Transmission Ownership Project Public Comments
https://youtu.be/Z_Q1rvhadAA
Dec 2, 2025 Naperville IMEA Transmission Ownership Project Discussion by City Council
https://youtu.be/07twf5Gj-9M

Lack of Transparency of IMEA Board Meetings

The Public Comments:

“IMEA doesn’t provide board meeting recordings. When requesting a webinar clip of the Resource Planning presentation, IMEA’s formal response was: “The record you requested does not exist.””

Further Background and Explanation:

(1) While many units of government, such as Naperville and other IMEA Members, provide public recordings of their government meetings, unit of government IMEA does not provide board meeting recordings. During the Covid pandemic, IMEA held board meetings via webinar and has continued to offer webinars as an option for the public to attend the live meeting. If you unable to attend the meeting, the meeting minutes which are approved and posted after the next meeting are the primary source of information provided by IMEA. We also request the meeting slides which we post in our IMEA Meeting Records directory.

The IMEA General Counsel stated the following in an email reply on Dec 19, 2024:
“IMEA does not have cameras in the Boardroom to film the Board proceedings, and the IMEA Board has never authorized video recording of their meetings. ….. The Minutes are the official public record of the meeting.”


(2) We believe that the IMEA President and CEO’s “Resource Planning” presentation at the Oct 24, 2024 board meeting is an important one for the public to hear, and we requested a copy of that presentation when we had seen the webinar notification that the meeting was being recorded. We first asked verbally. And when here was no response, we followed up with an email request.

The IMEA General Counsel response in that same Dec 9, 2024 email reply stated the following:
“I can see from your follow up e-mails that you believe there should be a Teams video recording of the live webinar of the slides presented and the voting activity from the meeting. There is not. The live webinar that we have been providing for each Board meeting since the COVID Declaration ended is an accommodation to the public and to Board members who cannot travel for a given Board meeting. Those webinars were never intended to be video recorded. It is my understanding that we have provided you with the slides presented at the October Board meeting. In addition, the Minutes of the October Board meeting have been approved and are posted on the IMEA website. The Minutes are the official public record of the meeting. The information you provide below about Teams is interesting, but IMEA did not and cannot access the video clip you seek on Teams. We tried. The record you requested does not exist.”

Here is a link to copy of the email thread with IMEA requesting the “Resource Planning” presentation recording and receiving IMEA’s reply:
https://drive.google.com/file/d/1L5nHOhSE2a4tHMglHDtxLVWBx2u8FoDx/view

Lack of Transparency Due to Net Expenses Accounting

The Public Comments:

“Did you know we can’t see the market sale revenues, since they are buried in “net expense” accounting? While legal and audited, this also blocks public understanding.”

Further Background and Explanation:

Net expenses accounting does not allow us to see and understand the performance of IMEA resources which are sold into the PJM and MISO energy and capacity markets. The monthly IMEA financial statements show us what we pay for those resources, but we cannot see what we get in return for the dollars we spend for each of those resources.  We only see the net results for PJM and MISO which represent net market purchases minus net market sales. And IMEA does not provide us with supplemental reporting of the sales dollars and units of energy and capacity for those resources, including the ownership resources of Prairie State and Trimble County.

Sharing copy/pastes from Gemini Pro AI to provide further explanations on IMEA’s use of “net expenses”:

GASB vs. FERC Accounting Standards

As a governmental body, IMEA must follow the Governmental Accounting Standards Board (GASB) principles rather than the Federal Energy Regulatory Commission (FERC) Uniform System of Accounts used by private utilities.

  • Netting vs. Gross Reporting: While private utilities often report all sales as revenue (gross), GASB allows for “netting” in specific circumstances—particularly when an entity acts as an agent for its members or when transactions are considered “exchange-like” offsets to a primary cost.
  • The “Agent” Logic: IMEA acts as the Load Serving Entity (LSE) agent for its 32 members. In accounting terms, if IMEA is viewed as a pass-through entity that manages a “pool” of power, the energy it sells back into the market (PJM/MISO) is often treated as a reduction of the cost of the power it bought for its members, rather than a separate business line of selling power for profit.
Market Settlements as “Cost Offsets”

In the RTO (Regional Transmission Organization) markets like PJM and MISO, the billing process is inherently built on netting.

  • Settlement Statements: PJM and MISO issue settlement statements that show a “Net Billing” amount. If IMEA buys 100 MWh for its members but its owned generation (like the Prairie State coal plant) produces 120 MWh, the market clears the difference.
  • Negative Expense: Reporting this as a “Purchased Power” expense with a negative value is a way to reflect the net cost of serving the load. Legally, many joint action agencies argue that because their mission is strictly to supply members at cost, any market sales are not “revenue” in the traditional sense, but a recovery of costs already incurred to maintain those power resources.
Transparency and Governance Challenges

This “net” reporting method can indeed make it difficult for the public and even elected officials to see the full scale of operations.

  • Impact on Oversight: When revenues are buried as expense credits, the “top line” of the financial statement looks smaller than the actual volume of business being conducted.
  • Member Representation: Since city councils and IMEA board members are reviewing “net” numbers, they may not see the volatility of the wholesale sales that are offsetting the costs.

Gemini Pro AI thread (prompt and response)
https://gemini.google.com/share/a78a71d328fd

An example of IMEA net expenses can be found in our webpage:
How the IMEA Business Model Works
https://cleanenergynaperville.org/did-you-know/imea-business-model/

Lack of Transparency on the Prairie State Energy Campus (PSEC)

The Public Comments:

“And back again to 2007, months after we signed our contract, IMEA signed the Prairie State owners’ agreement with a confidentiality section which is used to withhold planning and financial reports from the public who pay the bills.”

Further Background and Explanation:

IMEA Members’ ratepayers bear the costs and benefits of PSEC, as with the transmission ownership projects described earlier. Ratepayers are also responsible for the risks of ownership of this mine and coal-fired power plant too.

We first documented the Prairie State Energy Campus (PSEC) confidentiality agreement in our detailed Lack of Transparency whitepaper. From our citizen perspective, we believe we should be able to see the same ownership information and reports, as if we Naperville directly owned PSEC. But we cannot, because of the confidentiality agreement.

The lack of ownership information and ownership reports includes, but is not limited to:
– Plans, budgets, projections, and assumptions
– Financial reports and analyses
– Operational reports and analyses

Here is a copy/paste of the confidentiality agreement in the PSEC Participation Agreement signed by IMEA and the other owners:

“Section 18.4 Confidentiality. Except as may be permitted by the Management Committee, no Participant shall disclose or otherwise make available to any other Person (other than such Participant’s Affiliates, employees, officers, directors, legal advisors, financial and technical advisors and accountants, and prospective or active Participant Lenders, provided each such Person agrees to· maintain the confidentiality of such information) any information of a technical, commercial or business nature regarding the Project or this Agreement (“Confidential Information”) without the prior written consent of the other Participants, except to the extent that disclosure of such Confidential Information is required by court order, a Governmental Authority or Applicable Law or the rules of any recognized national stock exchange. …..”

PSEC Participation Agreement by and among the nine “Participants”
https://drive.google.com/file/d/1YhTvbvvaa_F1AYi-uWrbMQDKdk0w1uX7/view

Here is our Lack of Transparency webpage and detailed whitepaper:
Lack of Transparency by Naperville and IMEA
https://cleanenergynaperville.org/did-you-know/lack-of-transparency/
Lack of Transparency pdf
https://drive.google.com/file/d/1yULabh38ZR-tHEN6nvenCo4JNBh4VdJ_/view

Conclusion

The Public Comments:

“This lack of transparency interferes with our citizen ability to understand and trust what IMEA, as a unit of local government, is doing with our dollars.”

“It sure looks to me like IMEA has forgotten about the public in “public power”, and that principle of “trust but verify”.

“It’s now 2026. We see widespread community concerns, and misinformation too. We’re paying quite a price—both tangible and intangible—for IMEA’s Way of supplying power.”

Further Background and Explanation:

IMEA is both a unit of local government and an active member of the American Public Power Association. Public transparency in how IMEA utilizes our citizen ratepayer dollars should be one of its top priorities. The lack of transparency in many key areas runs contrary to the purported “public power” benefits of transparency, accountability, and local control.

American Public Power Association’s “Public Power for Your Community”
https://www.publicpower.org/system/files/documents/municipalization-public_power_for_your_community.pdf