Contract analysis

I. INTRODUCTION AND SUMMARY OF RELIEF REQUESTED Metropolitan Transit Development Corporation ("MTDC" or "Petitioner"), an Illinois municipal corporation and public transit authority organized and existing under the Metropolitan Transit Development Act, 70 ILCS 3615/1 et seq., by and through its undersigned counsel, Calderwood & Harkness LLP, respectfully petitions the Illinois Commerce Commission ("Commission" or "IC

1. Approving the interconnection of new high-capacity depot charging infrastructure with a combined electrical load of approximately forty-five megawatts ("MW") to the distribution system of Prairie Shore Electric Company ("Prairie Shore") at three MTDC bus depot locations situated within the City of Chicago, Illinois, and its immediate environs, as more fully described herein;

2. Approving a proposed Infrastructure Cost-Sharing Agreement between MTDC and Prairie Shore governing the allocation of an estimated Twelve Million Three Hundred Thousand Dollars ($12,300,000) in distribution-system upgrade costs necessary to accommodate the proposed interconnection at said depot locations;

3. Approving Prairie Shore's filing of a new tariff rate schedule, designated Schedule EV-T (Electric Vehicle — Transit), establishing a time-of-use rate structure for electric service to MTDC's depot charging facilities at a proposed blended rate of Six and Two-Tenths Cents ($0.062) per kilowatt-hour ("kWh"); and

4. Granting such other and further relief as the Commission deems just and appropriate in the circumstances. This Verified Petition arises from Phase 1 of MTDC's comprehensive fleet electrification program, which involves the procurement of two hundred twenty-five (225) battery-electric transit buses and the installation of depot charging infrastructure at three existing MTDC bus garages. The total project cost for P

II. PARTIES AND INTERESTED PERSONS A. Petitioner — Metropolitan Transit Development Corporation The Petitioner in this proceeding is Metropolitan Transit Development Corporation, an Illinois municipal corporation and public transit authority created pursuant to the Metropolitan Transit Development Act, 70 ILCS 3615/1 et seq. MTDC's principal offices are located at 200 West Adams Street, Suite 2400, Chicago, Illinois

III. JURISDICTION AND AUTHORITY The Commission has jurisdiction over this Verified Petition and the subject matter herein pursuant to the Illinois Public Utilities Act ("PUA"), 220 ILCS 5/1-101 et seq. The Commission's jurisdiction and authority to consider and act upon the relief requested in this Petition is established by multiple provisions of the PUA, as set forth below. Jurisdiction Over Interconnection. Pursua

IV. BACKGROUND AND PROJECT DESCRIPTION A. MTDC's Strategic Sustainability Plan In September 2021, the Board of Directors of MTDC formally adopted a Strategic Sustainability Plan (the "Sustainability Plan") setting forth MTDC's commitment to fleet modernization, environmental stewardship, and operational resilience. The Sustainability Plan establishes a comprehensive roadmap for the transition of MTDC's 1,840-bus flee

1. North Garage — 4501 West Lawrence Avenue, Chicago, Illinois 60630 The North Garage is MTDC's largest bus depot, located in the Albany Park neighborhood on the northwest side of Chicago. The facility currently houses and dispatches approximately 480 buses serving routes on the north and northwest sides of the metropolitan area. Under Phase 1, the North Garage will receive depot charging infrastructure designed to s

2. West Garage — 1200 South Cicero Avenue, Chicago, Illinois 60804 The West Garage is located in the Cicero area on the west side of the metropolitan region. The facility currently houses and dispatches approximately 420 buses serving routes on the west and southwest sides of the metropolitan area. Under Phase 1, the West Garage will receive depot charging infrastructure designed to support approximately 75 battery-e

3. South Garage — 7800 South Vincennes Avenue, Chicago, Illinois 60620 The South Garage is located in the Chatham neighborhood on the south side of Chicago. The facility currently houses and dispatches approximately 310 buses serving routes on the south side and portions of the south suburbs. Under Phase 1, the South Garage will receive depot charging infrastructure designed to support approximately 60 battery-electr

V. ENGINEERING AND INTERCONNECTION ANALYSIS A. Creston Engineering Group Interconnection Study MTDC retained the services of Creston Engineering Group, Inc. ("Creston"), an engineering consulting firm specializing in electric utility infrastructure, grid interconnection, and electric vehicle charging systems, to conduct comprehensive grid-interconnection studies and to design the depot charging infrastructure for Pha

1. North Garage — 4501 West Lawrence Avenue, Chicago, Illinois 60630 (18 MW New Load) The North Garage is currently served by a single Prairie Shore distribution feeder originating from the Montrose Substation, which is a 138 kV/12.47 kV facility located approximately 1.8 miles from the depot. To accommodate the proposed 18 MW of new charging load, the following distribution-system upgrades are required: • Installati

2. West Garage — 1200 South Cicero Avenue, Chicago, Illinois 60804 (15 MW New Load) The West Garage is currently served by a Prairie Shore distribution feeder originating from the Cicero Avenue Substation, a 69 kV/12.47 kV facility located approximately 0.9 miles from the depot. To accommodate the proposed 15 MW of new charging load, the following distribution-system upgrades are required: • Upgrade of the existing C

3. South Garage — 7800 South Vincennes Avenue, Chicago, Illinois 60620 (12 MW New Load) The South Garage is currently served by a Prairie Shore distribution feeder originating from the Vincennes Substation, a 69 kV/12.47 kV facility located approximately 1.2 miles from the depot. To accommodate the proposed 12 MW of new charging load, the following distribution-system upgrades are required: • Installation of a second

VI. PROPOSED INFRASTRUCTURE COST-SHARING AGREEMENT MTDC and Prairie Shore have engaged in extensive negotiations over a period of approximately four months, from October 2022 through January 2023, and have reached agreement in principle on the terms of a proposed Infrastructure Cost-Sharing Agreement (the "Cost-Sharing Agreement") to govern the allocation of the $12,300,000 in distribution-system upgrade costs identi

VII. PROPOSED SCHEDULE EV-T — POWER-PURCHASE RATE ARRANGEMENT A. Need for a New Tariff Rate Schedule Prairie Shore does not currently offer a tariff rate schedule designed for high-capacity transit electrification loads of the type and magnitude proposed by MTDC. Prairie Shore's existing commercial and industrial rate schedules, including its General Service — Large Load (Schedule GL) and its High-Voltage Service (Sc

VIII. FINANCIAL CAPACITY AND GRANT COMPLIANCE A. MTDC's Financial Capacity MTDC possesses the financial capacity to fund its obligations under the Phase 1 electrification project, including both its $19,625,000 local match for the FTA Grant and its $7,380,000 share of the distribution-system upgrade costs under the proposed Cost-Sharing Agreement, for a combined MTDC financial commitment of $27,005,000. MTDC's Fiscal

IX. ENVIRONMENTAL AND PUBLIC INTEREST BENEFITS The Phase 1 electrification project will generate significant environmental and public interest benefits for the communities served by MTDC across its six-county service area in northeastern Illinois. Reduction in Criteria Pollutant and Greenhouse Gas Emissions. The replacement of 225 diesel and CNG buses with battery-electric vehicles will eliminate tailpipe emissions o

X. PROPOSED PROCEDURAL SCHEDULE MTDC respectfully proposes the following procedural schedule for the Commission's consideration of this Verified Petition, subject to modification by the assigned Administrative Law Judge ("ALJ") and the Commission: MTDC notes that Prairie Shore Electric Company is anticipated to file a Petition to Intervene in this proceeding, as discussed in Section II.B above. MTDC does not object t