9 12 24 West Orange BOA ZB 24 06 PSEG Full size Transcript

Page 87 1 of the -- 2 A. This one right here? 3 Q. Yes. 4 A. That's right in the center of a drive 5 path. 6 Q. Okay. Is that a new drive path or an 7 existing one? 8 A. That is a new drive path. 9 Q. And what is the purpose of that drive 10 path? 11 A. Access to the station. 12 Q. So you're saying you need access to the 13 station all the way around the devices that are 14 being installed? Is that what you're saying? 15 A. Correct. You have to provide multiple 16 access points to get equipment in and out. You also 17 have to provide reliable means to replace equipment 18 if something were to happen. 19 Q. And how often is access required? 20 A. It's not like a regular -- I mean, they 21 access the site every week for routine checkups and 22 regular maintenance. There's no exact number on 23 equipment replacement. It's not something that I'm 24 aware of. 25 Q. How do you know that they access the site