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CORRESP
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CORRESP

 August 28, 2015

 VIA
EDGAR SUBMISSION AND COURIER

 Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549-3561

Attention: William H. Thompson

Re:
Exelon Corporation

 Form 10-K for the Fiscal Year Ended December 31, 2014

 Filed February 13, 2015

Form 10-Q for the Quarterly Period Ended June 30, 2015

Filed July 29, 2015

File No. 1-16169

 Ladies and
Gentlemen:

 We are writing in response to the comments contained in the Staff’s letter dated August 14, 2015 (the “Comment Letter”)
with respect to Exelon Corporation’s (“Exelon”) Form 10-K for Fiscal Year Ended December 31, 2014, as filed with the Commission on February 13, 2015 (“2014 Form 10-K”) and Form 10-Q for Quarterly Period Ended
June 30, 2015, as filed with the Commission on July 29, 2015.

 For the convenience of the Staff’s review, we have set forth the comments
contained in the Staff’s Comment Letter along with Exelon’s responses. The response to this letter is provided on a supplemental basis.

*     *     *     *

Form 10-K for the Fiscal Year Ended December 31, 2014

Item 8. Financial Statements and Supplementary Data

Combined Notes to Consolidated Financial Statements

Consolidated Statements of Operations and Comprehensive Income

1.
Please tell us what consideration each registrant gave to separately presenting revenues and related costs and expenses applicable to revenues from tangible goods, services and other revenues pursuant to Rule 5-03
(b)(1) and (b)(2) of Regulation S-X.

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 Response:

Exelon is a utility services holding company engaged through its principal subsidiaries in the energy generation and energy distribution businesses.

Rate-Regulated Utility Registrants

 Exelon’s
rate-regulated utility businesses include Commonwealth Edison Company (ComEd), PECO Energy Company (PECO), and Baltimore Gas and Electric Company (BGE) (collectively the rate-regulated utilities), each of which is a separate debt registrant. ComEd,
PECO and BGE are primarily engaged in the purchase and rate-regulated retail sale of electricity and the provision of electric transmission and distribution services. PECO and BGE are also engaged in the purchase and rate-regulated retail sale of
natural gas and the provision of natural gas distribution services. The rate-regulated utilities are public utilities under the applicable state public utility regulations and are subject to rate regulation by their respective state utility
commissions. Additionally, the rate-regulated utilities are public utilities under the Federal Power Act subject to regulation by the Federal Energy Regulatory Commission (FERC).

Rule 5-03(b)(1) requires a registrant to state separately (a) net sales of tangible products; (b) operating revenues of public utilities or others;
(c) income from rentals; (d) revenues from services; and (e) other revenues. Rule 5-03(b) also indicates that a public utility company using a uniform system of accounts or a form for annual report prescribed by federal or state
authorities, or a similar system or report, shall follow the general segregation of operating revenues and operating expenses reported under Rule 5-03(b)(2) prescribed by such system or report. As noted above, all three of Exelon’s
rate-regulated utilities are subject to FERC and state public utility commission regulation which requires them to maintain their books and records in accordance with FERC’s uniform system of accounts. The FERC uniform system of accounts
requires operating revenues for public electric and natural gas utilities to be recorded within the single utility account 400 - Operating Revenues. As a result, we have historically reported all revenue from utility operations within a single line
item on the face of the statement of operations and comprehensive income. Correspondingly, we have historically reported the expenses for the purchases of both electricity and natural gas for resale within a single line item within the operating
expenses section of the statement of operations and comprehensive income. We believe the presentation of the rate-regulated utilities’ operating revenues and expenses is consistent with the requirements in Rule 5-03(b)(1)(b) and Rule
5-03(b)(2)(b) for the operating revenues and expenses of public utilities.

 Upon receiving this Comment Letter, we performed benchmarking of other public
utilities with both rate-regulated electricity and natural gas operations. Pursuant to our review, to more closely align with our peers for comparability purposes, we will revise our presentation on the statements of operations and comprehensive
income for PECO and BGE to reflect separately (1) operating revenues from the rate-regulated sale of electricity and operating revenues from the rate-regulated sale of natural gas, and (2) purchased power expense and purchased fuel expense
within the operating expenses section of the statement of operations and comprehensive income. We will make this change for all periods presented beginning with the Form 10-K for the Fiscal Year Ending December 31, 2015 (“2015 Form
10-K”). We also note that separate disclosure of PECO and BGE’s revenues from the rate-regulated sales of electricity and of natural gas has historically been provided within Item 7. Management’s Discussion and Analysis of
Financial Condition and Results of Operations. ComEd’s operating revenues are derived only from the rate-regulated sale of electricity, and thus no similar change in presentation will be made.

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 Exelon Generation Registrant

Exelon Generation Company (Generation), a subsidiary of Exelon and a debt registrant, is primarily engaged in the physical delivery and marketing of electric
generation capacity and natural gas, the provision of renewable and other energy-related products and services, and natural gas and oil exploration and production activities. For the year ended December 31, 2014, Generation’s operating
revenues of $17.4 billion consisted of electricity sales of approximately $14.2 billion, natural gas sales of approximately $3.0 billion, and other revenues of approximately $0.1 billion. Other revenues at Generation are derived primarily from oil
and natural gas exploration and production activities, sales of home products and services, and sales of distributed generation and energy efficiency services. As noted in Item 1. General Business of the 2014 Form 10-K, Generation is a public
utility under the Federal Power Act subject to regulation by the FERC. However, unlike ComEd, PECO and BGE, the prices that Generation charges its customers are not rates established by state public utility commissions or FERC. Generation prices its
sales of electricity and natural gas for re-sale at market-based rates. Furthermore, Generation is not required to use a uniform system of accounts or a form for annual report prescribed by federal or state authorities segregating and reporting
operating revenues and operating expenses by such system or report. Accordingly, Generation believes its historical practice of presenting its operating revenues from the sale of electricity and natural gas as a single line on the face of its
statement of operations and comprehensive income is appropriate under Rule 5-03(b)(1)(b) as operating revenues of public utilities. Additionally, Rule 5-03 permits the aggregation of revenue classes if each class is not more than 10% of consolidated
revenues. As such, Generation has also combined all other revenue classes into this single line item on the face of its statement of operations and comprehensive income.

Exelon Corporation Registrant

 As noted, each of
Exelon’s principal subsidiaries (ComEd, PECO, BGE and Generation) is a public utility. Exelon’s presentation of operating revenues in a single line item on the face of its consolidated statement of operations and comprehensive income
accordingly is consistent with the guidance in Rule 5-03(b)(1)(b). At the same time, through our benchmarking, we noted that many, but not all, public companies similar to Exelon with both rate-regulated public utility revenues and non-rate
regulated competitive public utility revenues present rate-regulated and non-rate regulated revenues separately on the face of their statements of operations and comprehensive income. Upon further reflection, we believe the separate presentation of
rate-regulated public utility revenues and non-rate regulated competitive public utility revenues provides more transparency to financial statement users. As a result, beginning with the 2015 Form 10-K, we will separately present total operating
revenues from rate-regulated utilities and total operating revenues from competitive businesses on the face of Exelon’s consolidated statement of operations and comprehensive income for all periods presented. Similarly, Exelon will separately
present rate-regulated purchased power and fuel expense and non-rate regulated purchased power and fuel expense. Exelon will not separately present on a consolidated basis the revenues or expenses associated with PECO’s and BGE’s sales of
electricity and natural gas in accordance with Rule 5-03(b) as total consolidated sales of rate-regulated natural gas are less than 10% of Exelon’s consolidated revenues.

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 16. Retirement Benefits (Exelon, Generation, ComEd, PECO and BGE), page 386

2.
Please tell us whether the defined benefit plans and other postretirement plans are multiemployer plans as defined in ASC 715-80-20 or multiple-employer plans as defined in ASC 715-30-20, and describe the
characteristics of the plans that support your determination.

 Response:

Exelon sponsors single-employer pension and other postretirement benefit plans for its employees, including employees of its subsidiaries.

Exelon’s subsidiaries account for their participation in Exelon’s single-employer pension and other postretirement benefit plans as participation in
multiemployer plans for purposes of their stand-alone financial statements (as disclosed on p. 395 of the 2014 Form 10-K). ASC 715-30-55-64 discusses parent-subsidiary arrangements and states that the subsidiaries should report their participation
in the parent’s overall single-employer pension plan as a participation in a multiemployer pension plan. As described in ASC 715-80-20, a multiemployer plan is “a pension or postretirement benefit plan to which two or more unrelated
employers contribute, usually pursuant to one or more collective-bargaining agreements. A characteristic of multiemployer plans is that assets contributed by one participating employer may be used to provide benefits to employees of other
participating employers since assets contributed by an employer are not segregated in a separate account or restricted to provide benefits only to employees of that employer”. Exelon has a Master Trust with various sub-trusts supporting its
pension and other postretirement benefit plans. The assets in the Master Trust and related sub-trusts are not legally segregated by subsidiary and can be used to provide benefits to eligible employees of any subsidiary participating in the plans.
This structure supports Exelon’s use of multiemployer accounting at the subsidiary financial statement level.

 The availability of assets to
participants of any subsidiary differentiates multiemployer plans from multiple-employer plans. As defined in ASC 715-30-20, a multiple-employer plan is “a pension plan or other postretirement benefit plan maintained by more than one employer
but not treated as a multiemployer plan. Multiple-employer plans are generally not collectively bargained and are intended to allow participating employers, commonly in the same industry, to pool their plan assets for investment purposes and to
reduce the cost of plan administration. A multiple-employer plan maintains separate accounts for each employer so that contributions provide benefits only for employees of the contributing employer. Multiple-employer plans may have features that
allow participating employers to have different benefit formulas, with the employer’s contributions to the plan based on the benefit formula selected by the employer.” In addition to not segregating assets, Exelon also does not allow the
participating subsidiaries to establish different benefit formulas. Exelon, as plan sponsor, determines the benefits available to employee plan participants across all of its subsidiaries. Therefore, it would not be appropriate for Exelon’s
subsidiaries to account for their participation in Exelon’s single-employer plans as multiple-employer plans for purposes of their stand-alone financial reporting.

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 24. Segment Information (Exelon, Generation, ComEd, PECO and BGE), page 451

3.
We note that the regulated utilities generate revenues from the sale of electricity, distribution of gas and electricity, transmission of electricity and riders to recover costs incurred for regulatory programs and
uncollectible accounts, among other sources. We also note that Generation generates revenues from gas and oil exploration and production activities, retail and wholesale electricity and gas sales, distributed generation, heating, cooling and
cogeneration facilities, home improvements, sales of appliances and servicing of heating, air conditioning, plumbing, electrical and indoor quality systems. Please provide us with a summary of revenues from external customers for each product and
service for each registrant. In addition, please tell us why you did not provide the disclosures in ASC 280-10-50-40.

 Response:

 ASC 280-10-50-40 requires entity-wide disclosures related to products and services. The entity-wide disclosures pertain to those entities whose
reportable segments are not based on products and services or geographic areas, and to reporting entities whose segment revenues are derived from a broad range of different products and services.

Rate-Regulated Utility Registrants

 Consistent with the
enhancements to the presentation of revenues on the face of the statements of operations as explained in the response to comment 1 above, PECO and BGE will revise their presentations within the Segment Information footnote to reflect separately
operating revenues from the rate-regulated sale of electricity and operating revenues from the rate-regulated sale of natural gas for all periods presented beginning with the 2015 Form 10-K. Reference is made to the first table below for the 2014
operating revenue amounts for sales of rate-regulated natural gas and sales of rate-regulated electricity for each of the utility registrants.

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 Exelon Generation Registrant

We consider Generation’s sale of competitive electricity and sale of competitive natural gas products and services as similar in nature, and thus believe
grouping them into a single line item under operating revenues within our Segment Information footnote is consistent with the guidance in ASC 280-10-50-40. The second table below sets forth the products and services comprising Generation’s 2014
operating revenues. As shown, operating revenues for the dissimilar products or services within Generation, such as oil and gas exploration and production activities, home products and services, distributed generation and energy efficiency, and
proprietary trading activities, individually represent less than 1% of Generation’s total operating revenues, and thus such amounts have not been separately reported within the Segment Information footnote.

While we believe our historical disclosure of operating revenues for Generation under ASC 280-10-50-40 has been appropriate as described above, we do
acknowledge that in 2014 operating revenues for natural gas sales of $2.957 billion represented 17% of Generation’s $17.393 billion total operating revenues. In 2013, natural gas sales operating revenues were $1.9 billion, or 12% of the total
$15.6 billion. The absolute and proportional growth in the natural gas sales operating revenues is