Contract analysis

1. Ellen R. Dempsey, Staff Counsel, ICC Office of General Counsel, Illinois Commerce Commission, 160 North LaSalle Street, Suite C-800, Chicago, Illinois 60601.

2. Andrew S. Peck, Hargrove, Peck & Tillotson LLP, 120 South LaSalle Street, Suite 3100, Chicago, Illinois 60603, counsel for Intervenor Prairie Shore Electric Company.

3. Diane L. Rosenberg, Rosenberg & Dietrich LLP, 33 North Dearborn Street, Suite 2200, Chicago, Illinois 60602, counsel for Intervenor Clean Air Transit Alliance. GENERAL OBJECTIONS MTDC interposes the following general objections to Staff Data Requests, Set 1. These general objections apply to each and every individual data request contained in the set and are incorporated by reference into each individual response

1. Overbreadth and Undue Burden. MTDC objects to each data request to the extent it is overly broad, unduly burdensome, or disproportionate to the needs of this proceeding. MTDC has construed each request in a reasonable manner and has provided responsive information accordingly. Where a request could be read to call for information beyond the scope of the issues presented in this Docket, MTDC has responded to the re

2. Attorney-Client Privilege and Work-Product Doctrine. MTDC objects to each data request to the extent it seeks information or documents protected by the attorney-client privilege, the attorney work-product doctrine, or any other applicable privilege or immunity from discovery. MTDC does not intend, by providing any response herein, to waive any privilege or immunity that may apply to any document, communication, or

3. Deliberative Process Privilege. MTDC objects to each data request to the extent it seeks disclosure of internal MTDC deliberations, including deliberations of the MTDC Board of Directors, its committees, and MTDC management, to the extent such deliberations are protected by the deliberative process privilege or any analogous privilege available to public entities under Illinois law.

4. Third-Party Documents. MTDC objects to each data request to the extent it calls upon MTDC to authenticate, verify, or vouch for the accuracy or completeness of documents or data prepared by third parties that are not in MTDC's possession, custody, or control, or that were prepared by third parties without MTDC's direction or supervision. Where MTDC has provided third-party documents in response to a data request,

5. Reservation of Right to Supplement or Amend. MTDC reserves the right to supplement, amend, or correct any response herein as additional information becomes available, including information obtained through ongoing discovery, further analysis by MTDC's consultants and advisors, or the development of facts during the course of this proceeding. MTDC's responses are based on information reasonably available as of the

6. Form of Response. MTDC's responses are organized by data request number and reproduce the text of each request for convenience of reference. The inclusion of a request does not constitute agreement by MTDC that the request is proper in form or scope. INDIVIDUAL DATA REQUEST RESPONSES Staff Data Request No. 1-1 MTDC Financial Capacity to Meet Local Match Obligation Request: State the total amount of MTDC's required

1. North Garage — 4501 West Lawrence Avenue, Chicago, Illinois 60630. The proposed new electrical load for the North Garage depot charging facility is 18 MW. This is the largest of the three depot installations, reflecting the North Garage's role as MTDC's largest bus operating facility. The Creston study identified the following required distribution-system upgrades for the North Garage site: installation of a new 3

2. West Garage — 1200 South Cicero Avenue, Chicago, Illinois 60804. The proposed new electrical load for the West Garage depot charging facility is 15 MW. The Creston study identified the following required distribution-system upgrades: reinforcement of the two primary distribution feeders serving the area, including conductor upgrades and reconductoring of approximately 1.5 miles of overhead distribution line; insta

3. South Garage — 7800 South Vincennes Avenue, Chicago, Illinois 60620. The proposed new electrical load for the South Garage depot charging facility is 12 MW. The Creston study identified the following required distribution-system upgrades: capacity upgrades to the existing substation transformer serving the area, including replacement of one existing transformer bank; modifications to the service entrance and meter