STATE OF ILLINOIS ILLINOIS COMMERCE COMMISSION
Docket No. 23-0214
In the Matter of the Petition of Metropolitan Transit Development Corporation for Approval of Electrification Infrastructure and Interconnection
PRE-FILED DIRECT TESTIMONY OF RAYMOND K. MOSLEY On Behalf of Petitioner Metropolitan Transit Development Corporation
Filed: March 1, 2023
Prepared by:
Calderwood & Harkness LLP 70 West Madison Street, Suite 5000 Chicago, Illinois 60602 Telephone: (312) 555-7800 Facsimile: (312) 555-7801
Patricia Dunmore, Responsible Partner David Stanton, Lead Associate Attorneys for Petitioner Metropolitan Transit Development Corporation
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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 directly to Harold J. Greenway, the Executive Director of MTDC.
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. 062-048723). I have also completed the National Transit Institute's Advanced Capital Program Management certificate program and hold a Project Management Professional (PMP) certification from the Project Management Institute.
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 and construction projects across the Midwest and Great Lakes regions. In that capacity, I managed capital projects with aggregate budgets exceeding $200 million, including bus rapid transit corridor development, rail station modernization, and maintenance facility construction.
I joined MTDC in 2008 as a Senior Capital Projects Manager. In that role, I was responsible for managing individual capital procurements and infrastructure improvement projects, including the renovation of MTDC's Central Maintenance Facility and the procurement of 340 compressed natural gas buses between 2010 and 2014. I was promoted to Deputy Director of Capital Programs in 2015 and to my current position as Director of Capital Programs in 2018.
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 project managers, engineers, procurement specialists, and contract administrators. My annual capital program budget authority currently exceeds $250 million.
I am responsible for ensuring that all capital projects are delivered on schedule, within budget, and in compliance with applicable federal, state, and local requirements. I have extensive experience with Federal Transit Administration ("FTA") grant administration, including compliance with FTA capital program requirements under 49 U.S.C. Chapter 53, Buy America provisions, National Environmental Policy Act ("NEPA") reviews, and FTA's project management and oversight framework. I routinely interface with the FTA Region V office, the Illinois Department of Transportation, and the Illinois Commerce Commission on matters related to transit capital investments.
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 funding and infrastructure modernization. I have also submitted written statements to the Regional Transportation Authority's capital program review process on multiple occasions.
C. Purpose of Testimony
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 depot charging infrastructure at three MTDC bus garages;
(b) To explain the technical basis for MTDC's interconnection request to Prairie Shore Electric Company's distribution system for approximately 45 megawatts ("MW") of new electrical load across three depot locations;
(c) To present the engineering and financial analyses that support the project, including the interconnection study prepared by Creston Engineering Group, Inc. and the rate-impact analysis prepared by Dralvecen Reade & Co.;
(d) To describe the proposed Infrastructure Cost-Sharing Agreement between MTDC and Prairie Shore Electric Company for the allocation of distribution system upgrade costs; and
(e) To demonstrate that the proposed interconnection and power-purchase arrangement under the proposed Schedule EV-T tariff are in the public interest and should be approved by the Commission.
D. Summary of Conclusions
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, financially sound, and consistent with MTDC's statutory mandate under the Metropolitan Transit Development Act and with MTDC's 2021 Strategic Sustainability Plan.
Second, the proposed 45 MW of new electrical load across three depot locations — North Garage (18 MW), West Garage (15 MW), and South Garage (12 MW) — is necessary and appropriate to support the planned fleet of 225 battery-electric buses. The load requirements are based on conservative engineering analyses that account for peak charging demand, seasonal variation, and operational contingencies.
Third, the proposed Infrastructure Cost-Sharing Agreement between MTDC and Prairie Shore Electric Company, which allocates $12,300,000 in distribution system upgrade costs on a 60/40 basis (MTDC 60% / Prairie Shore 40%), is reasonable and beneficial to both MTDC and Prairie Shore ratepayers. The cost-sharing structure reflects the proportionate benefits each party will receive from the infrastructure improvements.
Fourth, the proposed Schedule EV-T rate of $0.062 per kilowatt-hour is competitive, cost-effective for MTDC, and structured so as not to result in cost-shifting to other Prairie Shore ratepayers.
Fifth, Commission approval of the Verified Petition will enable MTDC to deploy $78,500,000 in federal grant funding from the FTA Low- and No-Emission Vehicle Program for the benefit of the northeastern Illinois region, while advancing the state's clean energy and environmental justice objectives.
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 a six-county service area in northeastern Illinois, encompassing Cook, DuPage, Kane, Lake, McHenry, and Will Counties. The Corporation's service area includes the City of Chicago and approximately 280 suburban municipalities, serving a combined population of approximately 8.6 million residents.
MTDC is governed by a Board of Directors consisting of fifteen members appointed by the Governor of Illinois with the advice and consent of the Illinois Senate. The current Chair of the Board of Directors is Alderman Vivian Ochoa-Brennan. Day-to-day operations of the Corporation are managed by its executive leadership team, which includes Harold J. Greenway, Executive Director; Sandra R. Pellegrino, Chief Financial Officer; and Constance M. Adler, General Counsel. Under its enabling statute, MTDC is authorized to acquire, construct, and maintain transit facilities and equipment; to enter into contracts for the procurement of goods and services; and to apply for and receive federal, state, and local grants in support of its transit mission.
B. Current Fleet and Operations
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 metropolitan area.
For Fiscal Year 2023, MTDC's total annual operating budget is approximately $1,420,000,000 (approximately $1.42 billion), which covers all bus and rail operations, maintenance, administration, and capital-related expenditures funded through operating revenues. MTDC's bus service operates on more than 175 fixed routes across the six-county service area, providing approximately 290 million unlinked passenger trips per year on its bus system alone.
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 compression and dispensing facilities at others. The three garages that are the subject of this proceeding — the North Garage, the West Garage, and the South Garage — were selected for Phase 1 electrification based on a comprehensive assessment of site suitability, route compatibility, and electrical infrastructure availability that I will describe in greater detail later in this testimony.
C. 2021 Strategic Sustainability Plan
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 months with input from MTDC staff, the Board of Directors, municipal stakeholders, community organizations, environmental advocacy groups, and members of the riding public.
The core commitment of the Sustainability Plan is the conversion of 40% of MTDC's bus fleet to battery-electric propulsion by the year 2030. Based on MTDC's current active fleet of 1,840 buses, this target translates to the electrification of approximately 736 buses over the period from 2023 to 2030.
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 infrastructure at three garage locations. Subsequent phases, which are not before the Commission in this docket, will extend electrification to additional garages and routes as battery technology continues to advance and as additional funding becomes available.
The Sustainability Plan also establishes environmental performance targets, including quantified reductions in greenhouse gas emissions, criteria air pollutant emissions (particularly nitrogen oxides and fine particulate matter), and noise pollution levels. The Plan places particular emphasis on delivering environmental benefits to environmental justice communities — neighborhoods that bear disproportionate burdens of air pollution and that are frequently located near bus depots and along heavily-trafficked bus corridors. The Plan is consistent with and supports the state policy objectives embodied in the Illinois Climate and Equitable Jobs Act (Public Act 102-0662) and with federal sustainability mandates applicable to transit agencies receiving FTA funding.
Relevant excerpts of the 2021 Strategic Sustainability Plan are attached to this testimony as Exhibit RKM-5.
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 acquisition, construction, and leasing of supporting facilities, including charging infrastructure.
MTDC submitted its application for Low- and No-Emission Vehicle Program funding in the spring of 2022. After a rigorous competitive review process, the FTA issued a Notice of Award to MTDC on January 9, 2023, under FTA Grant Award Number IL-2023-0067-00. The grant was awarded by the FTA Region V office, which is led by Regional Administrator Karen L. Osterman. The Notice of Award confirms that MTDC's Phase 1 Bus Fleet Electrification Plan meets all programmatic eligibility requirements and that the proposed project scope, budget, and schedule are approved for federal funding.
B. Grant Amount and Project Cost Structure
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 share (80%): $78,500,000 MTDC local match (20%): $19,625,000 Total eligible project cost: $98,125,000
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. The engagement partner for MTDC's audit is Douglas H. Fielding, CPA, and the firm is located at 155 North Wacker Drive, Suite 1800, Chicago, Illinois 60606. The audited financial statements demonstrate that MTDC maintains adequate capital reserves and debt capacity to support the local match without impairing the Corporation's ongoing operations or financial stability.
The audited financial statements are attached to this testimony as Exhibit RKM-7.
C. Project Budget Allocation
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-class battery-electric buses and includes the cost of on-board battery systems, electric drive systems, and ancillary equipment.
The depot charging infrastructure budget of $26,325,000 covers all charging equipment, electrical distribution systems, civil site work, and installation at the three garage locations. This budget encompasses the procurement and installation of high-power DC fast chargers, electrical panels, switchgear, step-down transformers, conduit and cable runs, concrete pads and foundations, and intelligent charging management systems at each depot.
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 Infrastructure Cost-Sharing Agreement between MTDC and Prairie Shore, which I will discuss in detail in Section VI of this testimony. Under the proposed cost-sharing arrangement, MTDC will contribute $7,380,000 (60%) toward these upgrade costs from its capital reserves, and Prairie Shore will fund the remaining $4,920,000 (40%) through its capital budget, subject to appropriate regulatory recovery.
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 Plan's target of electrifying 40% of the fleet, or approximately 736 buses, by 2030.
The 225-bus deployment was selected as the appropriate scope for Phase 1 based on several factors, including the availability of FTA grant funding, the capacity of the three selected depot locations to accommodate charging infrastructure, the suitability of existing bus routes for battery-electric operation, and the desire to establish a sufficiently large initial fleet to generate meaningful operational data and experience that will inform subsequent phases of the electrification program.
B. Battery-Electric Bus Specifications
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 approximately 165 standard 40-foot buses and 60 articulated 60-foot buses.
The anticipated performance specifications for the battery-electric buses include the following:
• Battery capacity: Minimum of 440 kilowatt-hours ("kWh") usable capacity for 40-foot buses; minimum of 660 kWh usable capacity for 60-foot articulated buses.
• Nominal range: Minimum of 200 miles per charge for 40-foot buses; minimum of 150 miles per charge for 60-foot buses, under standard revenue service operating conditions including heating, ventilation, and air conditioning ("HVAC") loads.
• Charging compatibility: All buses must be compatible with depot-based overnight DC fast charging at power levels up to 150 kilowatts ("kW") per bus, as well as SAE J3068/CCS Type 1 charging standards.
• Expected useful life: Minimum of 12 years or 500,000 miles, consistent with FTA minimum useful life requirements for transit buses.
• Maintenance advantages: Battery-electric buses are anticipated to deliver maintenance cost savings of approximately 25–30% compared to comparable diesel buses, based on the elimination of internal combustion engine, transmission, and exhaust aftertreatment maintenance requirements.
All buses will be procured in compliance with FTA Buy America requirements under 49 U.S.C. § 5323(j) and applicable federal accessibility standards under the Americans with Disabilities Act.
C. Deployment Plan
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 that location. This is necessary to ensure operational flexibility, accommodate maintenance bay charging, and provide redundancy in the event of charger outages or scheduling conflicts. The additional stalls also account for the fact that some buses may require extended charge times under extreme weather conditions or after high-mileage service days.
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. Deliveries to the West Garage and South Garage will follow in the first and second quarters of 2025, respectively. The full complement of 225 buses is expected to be delivered and in revenue service by the end of the third quarter of 2025, subject to manufacturer delivery schedules and infrastructure completion timelines.
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 were identified through a comprehensive site assessment that evaluated physical site constraints, available land area for electrical equipment, proximity to suitable electrical distribution infrastructure, and operational route compatibility.
The engineering design for the charging infrastructure at all three depot locations has been prepared by Creston Engineering Group, Inc. ("Creston"), which MTDC retained as its engineering consultant for this project. Creston is a nationally recognized engineering firm specializing in transit electrification, electrical infrastructure design, and utility interconnection. Creston's headquarters are located at 8700 Bryn Mawr Avenue, Suite 600, Rosemont, Illinois 60018. The lead engineer and project director for MTDC's engagement is Martin J. Sadowski, P.E., who has more than twenty years of experience in heavy commercial and transit electrification projects.
The charging infrastructure at each depot location will include high-power DC fast chargers rated at 150 kW per dispenser, electrical distribution panels, medium-voltage switchgear, step-down transformers (from distribution voltage to service voltage), underground and overhead cable runs, concrete equipment pads, and an intelligent charging management system ("CMS") that enables automated load scheduling, demand limiting, and integration with the utility's demand response programs. Detailed site plans and charging infrastructure layouts for all three garages are attached to this testimony as Exhibit RKM-6.
B. North Garage — 4501 West Lawrence Avenue, Chicago, IL 60630
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 eastern perimeter to accommodate the new electrical service equipment, including pad-mounted transformers, switchgear enclosures, and charger cabinets, without displacing any existing operational functions.
The proposed new electrical service capacity at the North Garage is 18 MW. The depot will be equipped with 95 DC fast charger stalls, each rated at 150 kW, to serve the 90 battery-electric buses assigned to this location. The connection to Prairie Shore Electric Company's distribution system at this location will be via a new dedicated 12.47 kV feeder originating from Prairie Shore's Lawrence Avenue Substation, located approximately 0.7 miles east of the garage site. The interconnection will require Prairie Shore to install a new 20 MVA transformer bank at the Lawrence Avenue Substation and to construct the new feeder line to the North Garage property boundary, where MTDC-owned switchgear will accept the service.
The charging management strategy at the North Garage is designed to concentrate the primary charging load during nighttime off-peak hours, generally between 11:00 PM and 5:00 AM, when buses are parked in the depot between the end of evening service and the start of morning pull-out. The CMS will stagger charger activations across the 95 stalls to avoid simultaneous peak demand, maintaining actual coincident demand at or below approximately 14 MW even though the nameplate aggregate capacity of the chargers is 14.25 MW (95 × 150 kW). A secondary daytime charging window will be available for mid-day opportunity charging of buses that return to the depot during service hours, but daytime demand is projected to remain below 5 MW at this location.
C. West Garage — 1200 South Cicero Avenue, Chicago, IL 60804
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 southern portion of the site, currently used for overflow bus parking, has been identified as suitable for the installation of electrical service equipment and charger infrastructure.
The proposed new electrical service capacity at the West Garage is 15 MW. The depot will be equipped with 80 DC fast charger stalls, each rated at 150 kW, to serve the 75 battery-electric buses assigned to this location. The connection to Prairie Shore's distribution system at this location will be through a new 12.47 kV service tap from the existing Cicero-Cermak distribution feeder, which runs along South Cicero Avenue. Creston's interconnection study has determined that this feeder currently operates at approximately 62% of rated capacity, and the addition of 15 MW of new load will require Prairie Shore to upgrade the feeder conductor, install a new 18 MVA distribution transformer, and reconfigure protective relaying at the Cicero-Cermak switching station.
The charging management strategy at the West Garage is similar to that at the North Garage. Primary overnight charging will occur between 10:30 PM and 5:30 AM, with the CMS managing staggered charger activation to limit coincident demand to approximately 11.5 MW. Daytime mid-day charging capacity is projected to require no more than 4 MW at this location.
D. South Garage — 7800 South Vincennes Avenue, Chicago, IL 60620
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 boundary, currently occupied by a decommissioned bus wash facility and surface parking, has been identified for the installation of charging infrastructure and electrical service equipment.
The proposed new electrical service capacity at the South Garage is 12 MW. The depot will be equipped with 65 DC fast charger stalls, each rated at 150 kW, to serve the 60 battery-electric buses assigned to this location. The connection to Prairie Shore's distribution system will be through a new 12.47 kV service lateral from Prairie Shore's Vincennes-79th Street distribution feeder. Creston's analysis indicates that this feeder will require conductor upgrades and the installation of a new 15 MVA transformer to accommodate the additional load. Prairie Shore will also need to install new fuse-protected switches and recloser equipment to maintain coordination with existing protective devices on the feeder.
The South Garage is located in a community that has been designated as an environmental justice area under both Illinois Environmental Protection Agency criteria and federal Executive Order 12898. The electrification of buses operating from this garage will therefore deliver direct and disproportionate air quality benefits to the surrounding community by eliminating diesel exhaust emissions from 60 buses that are currently stored, idled, and dispatched from this location.
The charging management strategy at the South Garage mirrors the approach at the other two depots. Primary overnight charging will occur between 11:00 PM and 5:30 AM, with the CMS managing coincident demand to approximately 9 MW. Daytime charging demand is projected at no more than 3.5 MW.
E. Combined New Electrical Load
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 aggregate nameplate charger capacity. Second, the charging profiles at the three depots are not perfectly synchronized; differences in route schedules, pull-out times, and pull-in times among the three garages result in natural diversity in charging load timing. Third, not all charger stalls will be occupied simultaneously at all times, as some buses may be in revenue service, undergoing maintenance, or otherwise unavailable for charging.
Creston's load profile analysis estimates that the diversified coincident peak demand across all three depots will be approximately 34 MW, representing a diversified load factor of approximately 0.76. Moreover, the peak demand period is expected to fall during nighttime off-peak hours, generally between 12:00 AM and 4:00 AM, when overall system demand on Prairie Shore's network is at its lowest. This favorable load shape is a significant benefit to Prairie Shore and its ratepayers, as it utilizes otherwise underutilized system capacity during off-peak periods.
The MTDC charging management system will also incorporate demand response capabilities that will allow Prairie Shore, with appropriate advance notice, to curtail or shift charging loads during emergency grid conditions. This capability further enhances the value of the transit charging load from a grid management perspective.
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 points. Creston's study included a detailed analysis of the existing distribution feeders, substation capacity, transformer loading, voltage regulation, protective relaying coordination, and thermal capacity of conductors serving each of the three garage locations.
The interconnection study was performed in coordination with Prairie Shore Electric Company's engineering staff, who provided Creston with system data, load flow models, and access to distribution system records. Creston's lead engineer, Martin J. Sadowski, P.E., met with Prairie Shore's distribution planning engineers on multiple occasions during the study period to review system conditions, validate modeling assumptions, and discuss potential upgrade alternatives.
The Creston interconnection study report is attached to this testimony as Exhibit RKM-1.
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 reliable service to the new loads without adversely affecting service quality or reliability for any existing Prairie Shore customers. The study further determined that the required upgrades are technically straightforward and can be completed within a timeline consistent with MTDC's planned infrastructure construction schedule.
B. Distribution System Upgrade Requirements
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 is as follows:
The nature of the required upgrades includes the installation of new or upsized substation transformers, construction of new distribution feeders, upgrading of existing feeder conductor to higher-ampacity cable, installation of new distribution switchgear and protective relaying equipment, and modifications to existing protection coordination schemes to integrate the new service points. All upgrades will be constructed on Prairie Shore's distribution system and will become Prairie Shore assets upon completion.
The design coordination between Creston and Prairie Shore's engineering staff ensures that the upgrades will be fully integrated with Prairie Shore's existing system configuration, protection philosophy, and operational practices. Creston's engineers have coordinated closely with Prairie Shore's distribution planning department to ensure that the upgrades not only serve the new MTDC loads but also provide collateral benefits to the distribution system in terms of enhanced capacity margins, improved voltage regulation, and modernized protective equipment at the affected locations.
C. Proposed Infrastructure Cost-Sharing Agreement
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% = $7,380,000
• Prairie Shore share: 40% = $4,920,000
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 set at the larger proportion of 60%. Prairie Shore, however, will also benefit significantly from the upgrades through multiple channels: it will gain a new large-volume, high-load-factor customer generating approximately 39,420 MWh per year of new energy sales; the upgraded distribution infrastructure will enhance system capacity and reliability for existing customers in the affected service areas; and the new transformer and feeder assets will replace aging equipment that would eventually require replacement under Prairie Shore's normal capital maintenance cycle. These utility-side benefits justify Prairie Shore's 40% contribution to the upgrade costs.
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 eligibility to draw on the grant funds; and (iii) Prairie Shore's receipt of any necessary internal corporate approvals. The agreement also includes provisions addressing construction scheduling, change order procedures, dispute resolution, indemnification, and insurance requirements.
Prairie Shore's outside regulatory counsel, the law firm of Hargrove, Peck & Tillotson LLP, has been actively involved in the negotiation and review of the draft Cost-Sharing Agreement. The lead attorney for Prairie Shore on this matter is Andrew S. Peck, Partner, of Hargrove, Peck & Tillotson LLP, located at 120 South LaSalle Street, Suite 3100, Chicago, Illinois 60603.
The draft Infrastructure Cost-Sharing Agreement is attached to this testimony as Exhibit RKM-3.
D. Reliability and Safety Considerations
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 the expected peak demand, and the protective relaying modifications will maintain full coordination with existing system protection schemes.
All electrical equipment — both on MTDC's side and on Prairie Shore's side of the service points — will be designed, installed, and tested in compliance with all applicable codes and standards, including the National Electrical Code (NEC/NFPA 70), the National Electrical Safety Code (NESC/ANSI C2), and applicable standards of the Institute of Electrical and Electronics Engineers ("IEEE"), including IEEE 1547 for interconnection and IEEE C57.12 series for transformer specifications. The design also complies with all applicable rules and regulations of the Illinois Commerce Commission governing electric service and distribution system operations.
Furthermore, as I noted earlier, MTDC's charging management system will include demand response capabilities. These capabilities will enable Prairie Shore to request curtailment or load shifting of MTDC's charging demand during periods of system emergency or grid stress, providing an additional layer of protection for system reliability. MTDC has agreed, as part of the proposed Schedule EV-T tariff, to participate in Prairie Shore's demand response programs and to maintain the technical capability to reduce its charging load by at least 25% within fifteen minutes of receiving a curtailment signal from Prairie Shore.
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 advisory firm retained by MTDC to provide grant compliance modeling and rate-impact analysis for the Phase 1 electrification project. Dralvecen Reade's headquarters are located at 311 South Wacker Drive, Suite 4500, Chicago, Illinois 60606, and the engagement partner for the MTDC assignment is Lisa M. Quayle, CFA.
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-foot buses and approximately 110 miles per day for 60-foot articulated buses, reflecting the route mix and scheduling patterns at these locations.
• Energy consumption per mile: Based on manufacturer data, industry benchmarks, and the operating experience of peer transit agencies that have deployed battery-electric buses, the analysis assumes an average energy consumption rate of 2.0 kWh per mile for 40-foot buses and 2.8 kWh per mile for 60-foot buses. These rates include the energy consumed by HVAC systems, lighting, door actuators, accessibility equipment, and other auxiliary loads.
• Charging efficiency losses: The analysis applies a charging efficiency factor of 90%, accounting for energy losses during the DC fast charging process, including conversion losses in the charger, battery thermal management energy, and cable losses.
• Annual operating days: The analysis assumes 355 operating days per year (365 days less an allowance of 10 days for severe weather cancellations and system-wide service suspensions).
• Fleet availability factor: A fleet availability factor of 92% is applied, reflecting the expectation that on any given day approximately 8% of the fleet may be out of service for scheduled or unscheduled maintenance.
These assumptions are intentionally conservative and include provisions for seasonal variation (particularly increased HVAC energy consumption during extreme cold and hot weather months), route mix variability, and battery degradation over time. The analysis projects that battery energy capacity will degrade by approximately 2% per year over the first ten years of service, resulting in increased energy consumption per mile as the fleet ages. Even with this degradation factored in, the 39,420 MWh per year figure represents a conservative upper-bound estimate for the initial years of operation.
B. Proposed Rate Schedule EV-T
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 Illinois Commerce Commission as a new tariff filing by Prairie Shore. A term sheet summarizing the key provisions of the proposed Schedule EV-T is attached to this testimony as Exhibit RKM-4.
The proposed blended rate under Schedule EV-T is $0.062 per kilowatt-hour. The rate structure includes time-of-use differentials between on-peak and off-peak periods, as well as a demand charge component, all of which are designed to incentivize MTDC to concentrate its charging load during off-peak overnight hours when Prairie Shore's system is underutilized. The on-peak energy rate is set higher than the off-peak energy rate, creating a meaningful price signal that reinforces MTDC's operational preference for overnight depot charging and discourages on-peak charging except when operationally necessary.
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 utilization during off-peak periods without requiring additional generation or transmission capacity investment. The proposed rate is competitive with rates offered by other major utilities to transit agencies for comparable fleet charging loads, based on Dralvecen Reade's benchmarking analysis of comparable tariffs in Illinois, Indiana, Ohio, and Michigan.
C. Estimated Annual Energy Cost
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 buses. The transition to battery-electric propulsion at an annual energy cost of $2,444,040 represents a gross fuel cost savings of approximately $7,950,960 per year, or approximately a 76.5% reduction in per-bus fuel costs. Even after accounting for the cost of electricity, the net annual fuel cost savings are substantial and are projected to more than offset the incremental capital cost of battery-electric buses over the 12-year useful life of the fleet.
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 contribution to fixed costs. The analysis demonstrates that the addition of 39,420 MWh per year of high-load-factor off-peak load under Schedule EV-T will, if anything, have a modest favorable impact on the rates paid by other Prairie Shore customers by spreading fixed system costs over a larger volume of sales. The rate-impact analysis concludes that the proposed rate does not result in cross-subsidization or cost-shifting and is therefore in the interests of all Prairie Shore ratepayers.
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 dioxide (CO₂): Approximately 27,400 metric tons per year reduction in direct tailpipe CO₂ emissions, equivalent to removing approximately 5,900 passenger cars from the road.
• Nitrogen oxides (NOₓ): Approximately 68 tons per year reduction, contributing to improved regional air quality and reduced ozone formation.
• Fine particulate matter (PM₂.₅): Approximately 1.8 tons per year reduction, directly benefiting communities along bus routes and near depot facilities.
• Carbon monoxide (CO): Approximately 42 tons per year reduction.
These emission reductions represent net figures, meaning they account for the upstream emissions associated with electricity generation on the Prairie Shore system. Because the Illinois grid has been rapidly decarbonizing — and is expected to continue to do so under the requirements of the Climate and Equitable Jobs Act — the net emission benefits of transit electrification will increase over time as the generation mix continues to shift toward renewable and zero-carbon sources.
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 community that experiences elevated levels of air pollution from transportation sources. The electrification of 60 buses operating from the South Garage will eliminate diesel exhaust emissions from those buses during their daily operation on local streets, as well as during idling and warm-up at the garage facility itself. Residents living near the depot will benefit from reduced noise, odor, and emissions associated with the current diesel fleet.
More broadly, transit riders — who are disproportionately lower-income and minority residents — will benefit from improved on-board air quality and a more pleasant riding experience on battery-electric buses, which operate without engine noise and exhaust fumes.
The Phase 1 electrification project is consistent with and advances Illinois state policy objectives for clean transportation and environmental justice, as embodied in the Climate and Equitable Jobs Act (Public Act 102-0662) and the state's commitment to equitable decarbonization of the transportation sector.