Contract analysis

I. INTRODUCTION AND QUALIFICATIONS A. Witness Identification

1. Q. Please state your full name, title, and business address. A. My full name is Raymond K. Mosley. I serve as the Director of Capital Programs for the Metropolitan Transit Development Corporation, which I will refer to throughout this testimony as "MTDC" or "the Corporation." My business address is 200 West Adams Street, Suite 2400, Chicago, Illinois 60606. In my capacity as Director of Capital Programs, I report

2. Q. On whose behalf are you submitting this pre-filed direct testimony? A. I am submitting this pre-filed direct testimony on behalf of Petitioner Metropolitan Transit Development Corporation in Illinois Commerce Commission Docket No. 23-0214. B. Professional Background and Qualifications

3. Q. Please describe your educational background and professional qualifications. A. I hold a Bachelor of Science degree in Civil Engineering from the University of Illinois at Urbana-Champaign, conferred in 1998, and a Master of Science degree in Transportation Planning and Engineering from Northwestern University, conferred in 2001. I am a licensed Professional Engineer in the State of Illinois (License No. 062-04

4. Q. Please describe your professional experience. A. I have more than twenty-four years of experience in transit capital project management, infrastructure planning, and fleet acquisition programs. Prior to joining MTDC, I held progressively responsible positions at Ashgrove Partners LLC, where I served for seven years as a project engineer and then senior project manager overseeing transit infrastructure design an

5. Q. What are your primary responsibilities as Director of Capital Programs? A. As Director of Capital Programs, I oversee the planning, design, procurement, and delivery of all major capital projects undertaken by MTDC. This encompasses fleet acquisitions, facility construction and renovation, infrastructure modernization, and technology system deployments. I manage a staff of twenty-eight professionals, including

6. Q. Have you previously submitted testimony before the Illinois Commerce Commission or other regulatory bodies? A. I have not previously submitted testimony before the Illinois Commerce Commission. However, I have provided sworn testimony in connection with FTA Full Funding Grant Agreement proceedings, and I have testified before committees of the Illinois General Assembly on matters related to transit capital fund

7. Q. What is the purpose of your pre-filed direct testimony in this proceeding? A. The purpose of my testimony is to support the Verified Petition filed by MTDC in ICC Docket No. 23-0214 on March 1, 2023. Specifically, my testimony is intended to accomplish the following: (a) To describe MTDC's Phase 1 Bus Fleet Electrification Plan, including the procurement of 225 battery-electric buses and the installation of dep

8. Q. Please summarize your principal conclusions. A. Based on my review of the engineering studies, financial analyses, and operational planning conducted in connection with the Phase 1 electrification project, and drawing upon my professional experience in transit capital program management, I have reached the following conclusions: First, the Phase 1 Bus Fleet Electrification Plan is technically feasible, financia

II. OVERVIEW OF MTDC AND ITS TRANSIT OPERATIONS A. MTDC Organization and Statutory Authority

9. Q. Please describe the Metropolitan Transit Development Corporation and its statutory authority. A. The Metropolitan Transit Development Corporation is an Illinois municipal corporation and public transit authority created pursuant to the Metropolitan Transit Development Act, 70 ILCS 3615. MTDC was established by the Illinois General Assembly to plan, construct, operate, and maintain public transit services within

10. Q. Please describe MTDC's current transit fleet and operations. A. MTDC currently operates an active bus fleet of 1,840 revenue vehicles. The existing fleet is composed of a mix of conventional diesel-powered transit buses and compressed natural gas ("CNG") transit buses. In addition to its bus operations, MTDC operates 312 heavy-rail transit cars on four rapid transit lines serving the greater Chicago metropolit

11. Q. Please describe MTDC's existing bus depot infrastructure. A. MTDC maintains and operates a network of bus garages throughout its service area. These facilities serve as the primary locations for bus storage, fueling, maintenance, cleaning, and dispatch operations. Each garage is equipped with fueling infrastructure appropriate to its fleet composition — diesel fueling stations at some locations and CNG compres

12. Q. Please describe MTDC's 2021 Strategic Sustainability Plan. A. In June 2021, the MTDC Board of Directors adopted the 2021 Strategic Sustainability Plan (the "Sustainability Plan"), which establishes the Corporation's long-term vision and actionable roadmap for transitioning to a more environmentally sustainable transit operation. The Sustainability Plan was developed over a period of approximately eighteen mont

13. Q. How is the Sustainability Plan organized? A. The Sustainability Plan organizes the fleet electrification effort into multiple phases, each building upon the preceding phase to expand battery-electric bus deployment incrementally across the service area. Phase 1, which is the subject of this proceeding, encompasses the initial deployment of 225 battery-electric buses and the associated depot charging infrastruc

III. FTA GRANT AWARD AND PROJECT FUNDING A. Federal Transit Administration Low- and No-Emission Vehicle Program

14. Q. Please describe the federal funding that MTDC has secured for the Phase 1 electrification project. A. MTDC has been awarded a competitive grant under the Federal Transit Administration's Low- and No-Emission Vehicle Program, which is authorized under 49 U.S.C. § 5339(c). This program provides federal funding to transit agencies for the purchase or lease of zero-emission and low-emission transit buses and the a

15. Q. What is the total value of the FTA grant, and how is the project funding structured? A. The FTA grant award provides $78,500,000 in federal funding. Under the terms of the Low- and No-Emission Vehicle Program, the federal share may cover up to 80% of total eligible project costs. Accordingly, the total eligible project cost for Phase 1, as approved by the FTA, is $98,125,000, calculated as follows: Federal sha

16. Q. How will MTDC fund its $19,625,000 local match? A. MTDC will fund the $19,625,000 local match obligation from a combination of the Corporation's capital reserves and existing bonding capacity. MTDC's financial capacity to provide the required local match has been confirmed through review of the Corporation's audited financial statements for Fiscal Year 2022, which were prepared by Fielding & Calloway CPAs, LLC

17. Q. How are the total project costs allocated among the major project elements? A. The $98,125,000 total eligible project cost is allocated among the major project elements as follows: The bus procurement budget of $71,800,000 covers the purchase of 225 battery-electric transit buses at an average cost of approximately $319,111 per unit. This per-unit cost is consistent with current market pricing for transit-clas

18. Q. Are the distribution system upgrade costs included in the project budget? A. No. The distribution system upgrade costs of $12,300,000, which relate to improvements on the Prairie Shore Electric Company distribution system necessary to serve the new 45 MW load, are separate from and in addition to the $98,125,000 total eligible project cost. The distribution system upgrade costs are the subject of the proposed

IV. PHASE 1 ELECTRIFICATION PLAN — BUS FLEET A. Scope of Phase 1

19. Q. Please describe the scope of the Phase 1 electrification project with respect to the bus fleet. A. Phase 1 encompasses the procurement and deployment of 225 battery-electric transit buses across MTDC's service area. These 225 buses represent approximately 12.2% of MTDC's total active bus fleet of 1,840 vehicles. Phase 1 is designed to be the foundational step toward achieving the 2021 Strategic Sustainability

20. Q. What are the anticipated specifications for the battery-electric buses? A. MTDC intends to procure a mix of standard 40-foot and 60-foot articulated battery-electric transit buses. The specific proportions of each bus type will be determined through the competitive procurement process; however, for planning purposes, MTDC has based its load projections and infrastructure design on a fleet composition of approx

21. Q. How will the 225 battery-electric buses be deployed across the three depot locations? A. The 225 battery-electric buses will be allocated among the three depot locations based on route demand, operational efficiency, and the electrical service capacity available at each depot. The planned deployment is as follows: The number of charger stalls at each location slightly exceeds the number of buses allocated to t

22. Q. What is the anticipated delivery schedule for the buses? A. Bus deliveries will be phased in alignment with the completion of depot charging infrastructure at each garage location. MTDC anticipates that bus deliveries will commence in the fourth quarter of 2024, with the first buses being assigned to the North Garage, which is expected to be the first depot to achieve charging infrastructure readiness. Deliver

V. DEPOT CHARGING INFRASTRUCTURE — TECHNICAL SPECIFICATIONS A. Overview of Charging Infrastructure Design

23. Q. Please provide an overview of the charging infrastructure planned for the three depot locations. A. MTDC has selected three existing bus garage facilities for the installation of Phase 1 depot charging infrastructure: the North Garage at 4501 West Lawrence Avenue, Chicago; the West Garage at 1200 South Cicero Avenue, Chicago; and the South Garage at 7800 South Vincennes Avenue, Chicago. These three garages wer

24. Q. Please describe the proposed charging infrastructure at the North Garage. A. The North Garage is MTDC's largest bus garage and is located on an approximately 14.2-acre site on the northwest side of Chicago. The facility currently houses diesel-fueled buses and includes indoor bus storage bays, maintenance shops, a fueling station, and an employee parking lot. The site has sufficient available space on its east

25. Q. Please describe the proposed charging infrastructure at the West Garage. A. The West Garage is located on an approximately 10.8-acre site on the west side of Chicago. The facility currently serves as a maintenance and dispatch center for CNG-fueled buses and includes indoor storage bays, CNG compression and dispensing equipment, a maintenance facility, and administrative offices. An undeveloped area on the sou

26. Q. Please describe the proposed charging infrastructure at the South Garage. A. The South Garage is located on an approximately 8.4-acre site on the south side of Chicago in the Greater Chatham neighborhood. This facility currently serves as a diesel bus maintenance and dispatch center. The site includes indoor bus parking, a maintenance shop, and a diesel fueling island. An area along the western property bounda

27. Q. What is the total combined new electrical load for the three depot locations? A. The total combined new electrical load across the three depot locations is 45 MW, calculated as follows: This 45 MW figure represents the aggregate new electrical service capacity requested at the three depot locations and forms the basis for MTDC's interconnection request to Prairie Shore Electric Company.

28. Q. Will the actual peak demand at these depots reach the full 45 MW simultaneously? A. No. While the combined nameplate service capacity requested is 45 MW, the actual coincident peak demand across the three depots is expected to be materially lower due to several factors. First, as I described above, the intelligent CMS at each depot will stagger charger activations to limit coincident demand to well below the a

VI. GRID INTERCONNECTION — ENGINEERING BASIS A. Creston Engineering Group Interconnection Study

29. Q. Please describe the interconnection study conducted by Creston Engineering Group. A. MTDC retained Creston Engineering Group, Inc. to conduct a comprehensive interconnection study for all three depot locations. The study, which was completed in November 2022, assessed the capacity of the existing Prairie Shore Electric Company distribution system to accommodate 45 MW of new load at the three proposed service p

30. Q. What were the principal findings of the interconnection study? A. The interconnection study concluded that Prairie Shore's existing distribution system, in its current configuration, does not have sufficient capacity to serve 45 MW of new load at the three proposed depot locations without upgrades. However, the study identified a set of targeted distribution system upgrades that, once completed, will enable re

31. Q. What distribution system upgrades are required, and what are the estimated costs? A. The total estimated cost of the required distribution system upgrades, as determined by the Creston interconnection study, is $12,300,000. This cost encompasses all upgrades on Prairie Shore's side of the service point at each of the three depot locations. The general allocation of upgrade costs among the three depot locations

32. Q. Please describe the proposed Infrastructure Cost-Sharing Agreement between MTDC and Prairie Shore. A. MTDC and Prairie Shore Electric Company have negotiated a draft Infrastructure Cost-Sharing Agreement (the "Cost-Sharing Agreement") to allocate the $12,300,000 in distribution system upgrade costs between the two parties. Under the proposed agreement, the costs are allocated as follows: • MTDC share: 60% = $7

33. Q. What is the rationale for the 60/40 cost-sharing split? A. The 60/40 allocation reflects the proportionate benefit that each party will receive from the distribution system upgrades. MTDC, as the new load customer requesting interconnection of a very large new load, is the primary driver of the need for the upgrades and will be the primary beneficiary of the new service capacity. Accordingly, MTDC's share is s

34. Q. Are there conditions precedent in the Cost-Sharing Agreement? A. Yes. The Cost-Sharing Agreement includes several conditions precedent to the obligations of both parties, including: (i) approval by the Illinois Commerce Commission of the Verified Petition and the Cost-Sharing Agreement in this Docket No. 23-0214; (ii) continued availability of FTA Grant Award Number IL-2023-0067-00 and MTDC's continued eligibi

35. Q. Will the proposed interconnection adversely affect distribution system reliability for existing Prairie Shore customers? A. No. The interconnection design, as detailed in Creston's study, ensures that the addition of 45 MW of new load will not degrade service quality or reliability for any existing Prairie Shore customers. The distribution system upgrades are designed to provide adequate capacity margins above

VII. ENERGY CONSUMPTION AND COST PROJECTIONS A. Estimated Annual Energy Consumption

36. Q. What is the estimated annual energy consumption for the 225 battery-electric buses? A. Based on a detailed analysis performed jointly by Creston Engineering Group and Dralvecen Reade & Co., MTDC's financial advisor, the estimated annual energy consumption for the fleet of 225 battery-electric buses is 39,420 megawatt-hours per year (39,420,000 kilowatt-hours per year). Dralvecen Reade & Co. is a financial advi

37. Q. Please describe the methodology used to derive the 39,420 MWh per year estimate. A. The annual energy consumption estimate was developed using a bottom-up methodology based on the following key inputs and assumptions: • Average daily mileage per bus: MTDC's operational data indicates that buses in revenue service on the routes assigned to the three Phase 1 garages average approximately 135 miles per day for 40

38. Q. Please describe the proposed rate schedule under which MTDC will purchase electricity for its depot charging operations. A. MTDC and Prairie Shore Electric Company have negotiated the terms of a proposed new time-of-use rate schedule designated as Schedule EV-T (Electric Vehicle — Transit). Schedule EV-T is specifically designed for large-volume transit fleet charging applications and requires approval by the

39. Q. Is the proposed EV-T rate reasonable and competitive? A. Yes. The proposed blended rate of $0.062 per kWh reflects the unique characteristics of the transit depot charging load — namely, its high volume, high load factor, off-peak concentration, and predictability. These characteristics make transit depot charging a highly desirable load from the utility's perspective, as it contributes to improved system util

40. Q. What is the estimated annual energy cost under the proposed Schedule EV-T? A. Based on the estimated annual consumption of 39,420,000 kWh and the proposed blended rate of $0.062 per kWh, MTDC's estimated annual energy cost for depot charging operations under Schedule EV-T is: 39,420,000 kWh × $0.062/kWh = $2,444,040 per year

41. Q. How does this cost compare to MTDC's current fuel costs for the buses that will be replaced? A. The 225 diesel and CNG buses that will be replaced by battery-electric buses currently consume an aggregate of approximately 2.7 million gallons of diesel fuel equivalent per year, at a current average cost of approximately $3.85 per gallon, resulting in annual fuel costs of approximately $10,395,000 for these 225 b

42. Q. Does the proposed EV-T rate result in any cost-shifting to other Prairie Shore ratepayers? A. No. Dralvecen Reade's rate-impact analysis, which is attached to this testimony as Exhibit RKM-2, confirms that the proposed Schedule EV-T rate is set at a level that fully covers Prairie Shore's marginal cost of serving the new transit charging load, including energy supply costs, distribution costs, and a reasonable

VIII. PUBLIC INTEREST AND ENVIRONMENTAL BENEFITS A. Environmental Benefits

43. Q. What are the anticipated environmental benefits of the Phase 1 electrification project? A. The displacement of 225 diesel and CNG buses with battery-electric buses will yield significant environmental benefits for the communities served by MTDC. Based on Creston's emissions analysis, the Phase 1 project is expected to achieve the following reductions in direct tailpipe emissions on an annual basis: • Carbon di

44. Q. How does the project benefit environmental justice communities? A. Several of the bus routes served by the Phase 1 garages operate through neighborhoods that have been identified as environmental justice communities under Illinois EPA criteria, including communities on the south side and west side of Chicago. The South Garage in particular is situated in the Greater Chatham neighborhood, a predominantly Black

45. Q. What are the economic benefits of the Phase 1 project? A. The Phase 1 project will deploy $98,125,000 in capital investment in the northeastern Illinois region, of which $78,500,000 represents federal funds that would not otherwise flow into the regional economy absent this project. The procurement of 225 battery-electric buses and the construction of depot charging infrastructure will generate significant dir

46. Q. How does the Phase 1 project align with MTDC's statutory mandate? A. MTDC's enabling statute, the Metropolitan Transit Development Act (70 ILCS 3615), charges the Corporation with the responsibility of providing efficient, reliable, and sustainable public transit service to the residents of its six-county service area. The Phase 1 Bus Fleet Electrification Plan directly advances each of these statutory objecti

47. Q. Has the Phase 1 project received support from stakeholders or advocacy organizations? A. Yes. The Clean Air Transit Alliance ("CATA"), a 501(c)(3) nonprofit advocacy organization dedicated to promoting clean and equitable public transportation, has intervened in this proceeding in support of MTDC's Verified Petition. CATA's Executive Director is Nathan B. Hartwell. CATA's intervention petition, filed in this d

IX. CONSULTANTS AND SUPPORTING ANALYSES

48. Q. Please identify the consultants and experts whose work supports your testimony and the Verified Petition. A. MTDC has retained three firms whose work product is referenced in my testimony and submitted as exhibits to the Verified Petition. I will briefly identify each firm and the nature of its engagement. A. Creston Engineering Group, Inc. Creston Engineering Group, Inc. has served as MTDC's engineering consu

49. Q. What relief is MTDC requesting from the Commission in this proceeding? A. Based on the engineering analyses, financial studies, and operational planning described in my testimony, MTDC respectfully requests that the Illinois Commerce Commission grant the following relief: (a) Approval for MTDC to interconnect new high-capacity depot charging infrastructure at three locations — the North Garage at 4501 West Law