12 12 24 PSEG West Orange BOA ZB 24 06 PSEG 35 Mt Pleasant Ave Condensed

65b96228-b9ab-4f72-9291-fa4a14ff04c8 26 (Pages 101 to 104) Page 101 1 Q. And with respect to Mr. Kipp's report, 2 just to be clear on this, you believe his report only 3 addresses the replacement aspect of the ordinance and 4 not the minimalization of the removal. 5 Is that correct? 6 CHAIRMAN NEUER: Mr. Turteltaub, he 7 said he didn't read Mr. Kipp's report. 8 MR. TURTELTAUB: He was asked -- he was 9 asked questions about it and crossed on the -- 10 Mr. Kipp having found that this report -- Mr. Kipp 11 having said it complies with the ordinance. 12 There was a discussion about bean 13 counting, and I just want to be clear, the board 14 understands what Mr. Linson was saying with respect 15 to Mr. Kipp's -- at least what he was informed about. 16 But there was questioning of him on 17 cross-examination and I just want to be clear because 18 -- to make sure that his -- there's an understanding 19 of what he was trying to convey in his answer. 20 CHAIRMAN NEUER: His answer was clear, 21 and he did not read the report. That doesn't mean he 22 couldn't testify about the conclusion, which he did. 23 But he didn't -- he didn't go through 24 the elements of the report or what Mr. Kipp 25 specifically said and found, other than the Page 103 1 allowed -- I did not overrule the objection. 2 I am allowing the question to go 3 forward, subject to the objection. 4 MR. TURTELTAUB: Thank you. 5 BY MR. TURTELTAUB: 6 Q. And, Mr. Kipp -- excuse me, Mr. Linson, 7 your understanding of what -- what the compliance was 8 that Mr. Kipp was referring to in his report? 9 A. Yes. You know, I believe it's very 10 unusual for a New Jersey licensed tree expert to have 11 a vastly different opinion from another New Jersey 12 licensed tree expert. 13 I trust Mr. Kipp's judgment in 14 enforcing the ordinance. I don't know whether he 15 considered the fact that a tree application could be 16 denied from the standpoint that it's not preserving 17 the maximum possible number of trees and the 18 development of a site. 19 I know that and I trust that Mr. Kipp's 20 analysis on the replacement requirement is accurate. 21 I just don't know that he had the -- had the thought 22 that it could be denied from the fact that not -- not 23 all possible trees could be saved by changing -- I 24 don't know whether he -- he saw the video or was 25 privy to the engineering reports on why the Page 102 1

denied from the fact that not -- not 23 all possible trees could be saved by changing -- I 24 don't know whether he -- he saw the video or was 25 privy to the engineering reports on why the Page 102 1 conclusion that it complies with the ordinance. 2 MR. TURTELTAUB: If it's -- if that's 3 what he's being told that that's what the answer is, 4 that's one thing. 5 But if he's being asked if his opinion 6 whether -- whether he believes Mr. Kipp analyzed all 7 aspects of the ordinance, that's a different story. 8 Because there had been questioning to him about what 9 he meant in his answer. 10 And I just want to make sure it's clear 11 to this board and in the record as to what his answer 12 was. 13 CHAIRMAN NEUER: Well, I respectfully 14 disagree with you. I'll allow you to go forward. 15 MS. PORTER: And I also note my 16 objection for the record, because how can he opine on 17 a report that he did not read in any capacity or 18 dispute findings of a report that he has no idea what 19 it contained, what was looked at and had no 20 conversation with the individual who prepared it? 21 MR. TURTELTAUB: The report is a 22 one-page letter which you read the one line and you 23 asked him a question about it, and that was the sum 24 and substance of the report -- 25 CHAIRMAN NEUER: Mr. Turteltaub, I Page 104 1 installation has to be where it is or why it's 2 proposed to be here. 3 All I know is that in Mr. Kipp's mind, 4 the loss of these trees, pursuant to the ordinance, 5 is compensated by the restoration and planting of 6 replacement trees. 7 MR. TURTELTAUB: And with that, 8 Mr. Neuer, I have nothing further. 9 Thank you. 10 CHAIRMAN NEUER: Thank you. 11 Recross, Ms. Porter? 12 MS. PORTER: Yes, Mr. Chairman. 13 RECROSS-EXAMINATION 14 BY MS. PORTER: 15 Q. Mr. Linson, are you aware that the 16 current forester did walk the site, both externally 17 and internally? 18 A. I would -- I would hope that that's 19 what he did. 20 And as the forester, he would have 21 access to that. I have not been invited on the site 22 and -- but again, I -- I doubt -- I seriously doubt 23 that Mr. Kipp and I would have much difference over 24 any of the condition of any of the existing trees. 25 If he thinks something is defective and

65b96228-b9ab-4f72-9291-fa4a14ff04c8 27 (Pages 105 to 108) Page 105 1 warrants removal, I trust his judgment a 2 hundred percent. 3 I seriously doubt we would have any 4 professional differences in the assessment of a tree. 5 Q. Thank you. 6 Are you aware that the plans that you 7 reviewed, the TR-01, -2 and -3, do you distinguish 8 between viable and non-viable trees being removed, 9 specifically on TR-02? 10 A. You know, basically the unfortunate 11 thing about that report is it doesn't have a column 12 indicating the condition of the tree. 13 So, you know, in looking at it, I have 14 to presume that they were healthy trees if they're 15 not being removed. 16 And, you know, I did -- my emphasis in 17 reviewing, you know, TR-1, -2, and -3 was to look for 18 the largest trees that were existent since the -- the 19 initial planting and development of the site and to 20 try to preserve those. And, you know, I -- I 21 acknowledged a lot of the other trees that were 22 volunteers that were self-planted on the site. 23 But my emphasis was to try to preserve 24 as many trees as possible, but certainly the original 25 planted trees, the -- the Colorado blue spruce, the Page 107 1 -- on the east side of the property were moved closer 2 to the -- to the Prospect Avenue property line, if it 3 were possible to do that, it appears to me we could 4 preserve some trees. 5 So all -- I am asking the question, but 6 I don't have the answer whether all of those possible 7 options, you know, in altering the plans are possible 8 or not. 9 But that's something for the board to 10 consider after hearing the testimony of the other 11 experts. 12 Q. Thank you. 13 Are you aware that additional review of 14 the potential for tree preservation was done after 15 the initial report was received from the township 16 forester and that 17 trees were identified that 17 allowed for them to also be saved, based on the 18 voluntary consideration? 19 A. Well, I'm -- that's news to me and I'm 20 glad to hear it. 21 But the only -- the only reference that 22 I had was TR-01, -02 and -03, and what I could see 23 from the street. 24 Q. And than lastly, you did speak of how 25 the ordinance works in terms of the replacement trees Page 106 1 Norway spruce, the willow oaks, the Little Leaf 2 Lindens, the London planes, the Doug fir, the horse 3 chestnut. 4 Those were the ones that I specifically 5

terms of the replacement trees Page 106 1 Norway spruce, the willow oaks, the Little Leaf 2 Lindens, the London planes, the Doug fir, the horse 3 chestnut. 4 Those were the ones that I specifically 5 noted on my plan and highlighted them and 6 cross-referenced whether they were being preserved or 7 proposed for removal. 8 So, again, I was -- you know, the 9 smaller trees can be replaced, but the larger trees, 10 you know, they provide a benefit, a visual screening 11 of the site that cannot be replaced any time soon. 12 Q. Thank you. 13 Are you aware of any language in the 14 ordinance that mandates that alternatives be 15 considered when -- with respect to designing a site? 16 A. It's kind of subjective in terms of, 17 you know, the purpose and intent of it is to try to 18 preserve trees. So you would hope that all of the -- 19 all of the options to preserve a tree would be 20 exhausted before it becomes evident that the tree has 21 to be removed. 22 So I'm just not aware that all of the 23 options have been considered. 24 And, again, I just -- if the driveway 25 was slightly configured, if the improvements on the Page 108 1 and the intent that, you know, should a tree be 2 removed, that it will be replaced, and that there is 3 the ability for multiple replacements replace one 4 existing tree, depending upon the nature, size, type, 5 et cetera. 6 Are you aware of the fact that PSE&G is 7 proposing an additional 317 trees to the 338 trees 8 on-site for a total of over 700 trees that will exist 9 on the property as part of this proposed development? 10 A. That's news to me. 11 I haven't seen a replacement plan or 12 anything like that. 13 As I say, the only thing I have seen is 14 TR-01, -02 and -03. 15 MS. PORTER: Thank you. 16 I have no further questions. 17 THE WITNESS: Okay. 18 CHAIRMAN NEUER: Thank you, Mr. Linson. 19 THE WITNESS: Okay. 20 CHAIRMAN NEUER: It was good seeing you 21 again. 22 Mr. Turteltaub, who's your next 23 witness? 24 You know we stop at 11. 25 MR. TURTELTAUB: Yes, we'll hopefully

65b96228-b9ab-4f72-9291-fa4a14ff04c8 28 (Pages 109 to 112) Page 109 1 get this started, maybe throughout the direct 2 testimony. 3 This would be Robin Blanton. 4 CHAIRMAN NEUER: Ms. Brill, will you 5 try to find Robin Blanton. 6 MS. BRILL: Sure, he's raising his 7 hand. 8 I'm moving him over right now. 9 There he is. 10 CHAIRMAN NEUER: There he is, is right. 11 Welcome, Mr. Blanton. Your microphone 12 is off, sir, you have to turn it on. 13 Now it's on. 14 Mr. DeLuca, would you be so kind as to 15 swear the witness? 16 MR. DeLUCA: Certainly. 17 Mr. Blanton, if you could please raise 18 your right hand. 19 Do you solemnly swear to tell the 20 truth, the whole truth and nothing but the truth? 21 MR. BLANTON: I do. 22 R O B I N B L A N T O N, PE 23 P.O. Box 1351, Raleigh, NC, having been duly 24 sworn, testifies as follows: 25 MR. DeLUCA: Thank you. Page 111 1 they have, and I'm also a professional engineer in 11 2 states. 3 And I am also -- and one of those 4 states happens to be New Jersey. 5 Q. And do you provide your expertise in 6 any matters? 7 A. Would you ask that question again, 8 please? 9 Q. Do you provide your expertise in any 10 matters and if so, what would those matters be? 11 A. I have testified before the Rhode 12 Island Public Utilities Commission on some matters 13 relating to Rhode Island energy on plans they're 14 wanting to do. That occurred, I want to say, about 15 six to eight months ago on what they're doing in 16 Rhode Island. 17 And I have also, in the course of my 18 work with utilities as manager of engineering, 19 appeared before zoning boards and city and county 20 commissioners to get approval for not only 21 substations but also upgrades, transmission lines and 22 other facilities that were needed to run the utility. 23 Q. Do you have any experience in the 24 design of substations such as that which is before 25 the board tonight, and if so, could you just Page 110 1 CHAIRMAN NEUER: Mr. Turteltaub? 2 3 VOIR DIRE EXAMINATION 4 BY MR. TURTELTAUB: 5 Q. Mr. Blanton, if you could, could you 6 please give the board the benefit of your background 7 and experiences, please. 8 A. I have a bachelor of science degree in 9 electrical engineering and have worked for utilities 10 since I graduated from Clemson University in 1982. 11 I have experience doing substation 12 design, maintenance and responsibility for substation 13 sighting, and

ring and have worked for utilities 10 since I graduated from Clemson University in 1982. 11 I have experience doing substation 12 design, maintenance and responsibility for substation 13 sighting, and worked for mainly municipal and 14 electric co-ops over the course of my career. 15 And then starting in 2017, started 16 working for a consulting engineering firm and a 17 working -- continue to work for a consulting firm and 18 -- to this day. 19 Q. And when you say a consulting 20 engineering firm, what firm is that and what is your 21 position with that firm? 22 A. At the present time, I have my own 23 consulting engineering firm, R.W. Blanton PLLC. 24 I work with a couple utilities and do 25 consulting and assist other consultants with work Page 112 1 elaborate on that, please? 2 A. I have been responsible for the design 3 of substations that -- the upper voltage is 230kV, 4 which I believe is what this site is, and have, over 5 the course of probably the last 25 years, have been 6 involved in 12 to 15 substation designs. 7 MR. TURTELTAUB: And what I'd like to 8 do, Mr. Chairman, if I could is have Mr. Blanton be 9 qualified as a civil engineer in this matter, as well 10 as with his understanding of electrical facilities, 11 substation facilities such as that's before the board 12 tonight. 13 THE WITNESS: I would like to qualify 14 that be as an electrical engineer, not a civil 15 engineer. 16 MR. TURTELTAUB: I'm sorry, an 17 electrical engineer. 18 My apologies. 19 CHAIRMAN NEUER: My silence is due to 20 taking notes. I am not ignoring either one of you. 21 So that, let's be more specific -- try 22 to be specific. The area of expertise, you're 23 seeking to qualify him as an electrical engineer with 24 experience in substation design. 25 MR. TURTELTAUB: Yes.

65b96228-b9ab-4f72-9291-fa4a14ff04c8 29 (Pages 113 to 116) Page 113 1 CHAIRMAN NEUER: Is that correct? 2 MR. TURTELTAUB: Yes. 3 CHAIRMAN NEUER: Board have questions 4 on qualifications? 5 MS. PORTER: Yes. 6 VOIR DIRE EXAMINATION 7 BY MS. PORTER: 8 Q. My question is what specific experience 9 does he have regarding switching stations? 10 A. This is a combination of switching 11 station and a step-down station to go from 230kV down 12 to the distribution voltage as shown on the plans of 13 26kV, and that has been the primary focus of my work, 14 but I've also been involved in designing ring bus 15 switching stations similar to what is existing on 16 this site that is not being -- nothing's being 17 changed as far as the transmission switching. 18 Q. And my only other question would be, 19 what specific experience do you have in New Jersey? 20 A. My experience in New Jersey is limited 21 to working with Sussex Electric co-op, where we were 22 assisting them on getting some transmission -- sub 23 transmission out of a couple of their existing 24 substations for some maintenance work they needed to 25 do. Page 115 1 expert? 2 (No Response.) 3 CHAIRMAN NEUER: Seeing no hands. 4 Mr. Blanton, you said you have a New 5 Jersey license? 6 THE WITNESS: Yes, sir. 7 I'm a professional engineer in New 8 Jersey. 9 CHAIRMAN NEUER: Did you say 10 registered? 11 THE WITNESS: Yes, sir. 12 CHAIRMAN NEUER: You're not a 13 licensed -- 14 THE WITNESS: I am a professional 15 engineer -- I'm a professional engineer licensed to 16 do work in the State of New Jersey. 17 CHAIRMAN NEUER: Are you a licensed 18 professional engineer in the State of New Jersey? 19 THE WITNESS: That is correct, sir. 20 CHAIRMAN NEUER: For how long have you 21 been licensed in New Jersey? 22 THE WITNESS: I want to say it's only 23 been for about five years. 24 CHAIRMAN NEUER: During that period of 25 time -- during that period of time, has your license Page 114 1 So my experience in New Jersey is 2 limited. 3 Q. Okay. So was that with respect to 4 transmission, not -- not specifically with respect to 5 replacement of equipment? 6 A. I have also been involved in numerous 7 substation upgrades or retrofits where you're 8 replacing existing equipment, and one large municipal 9 that we're working with now is upgrading their 10 substations, and we're doing two to three substation 11 upgrades a year where we're

e you're 8 replacing existing equipment, and one large municipal 9 that we're working with now is upgrading their 10 substations, and we're doing two to three substation 11 upgrades a year where we're replacing old existing 12 equipment with newer equipment. 13 You know, and part of that work 14 involved having to maintain power during the entire 15 process to all the members and minimizing the impact 16 that we have with trees and having to stay lots of 17 times inside the existing perimeter of the substation 18 fence. 19 Q. Thank you. 20 But that experience was limited to 21 situations outside New Jersey, correct? 22 A. That is correct. 23 MS. PORTER: Thank you. 24 CHAIRMAN NEUER: Members of the Board, 25 any questions with respect to qualifications as an Page 116 1 ever been suspended? 2 THE WITNESS: My license has never been 3 suspended. 4 I got my -- I am originally licensed as 5 a professional engineer in the state of North 6 Carolina, and I got that license in 19 -- 7 CHAIRMAN NEUER: That's okay. 8 THE WITNESS: -- 1989. 9 I had to look at the plaque on the wall 10 to see the exact date. 11 CHAIRMAN NEUER: And is your New Jersey 12 license currently in good standing? 13 THE WITNESS: Yes, it is. 14 CHAIRMAN NEUER: Then, Mr. Turteltaub, 15 I will recognize Mr. Blanton as an expert in the 16 field of professional -- as a licensed professional 17 engineer with experience in -- oh, I have one more 18 question. I wrote down that you said you've been a 19 consultant since 2017. 20 THE WITNESS: Yes, sir. 21 CHAIRMAN NEUER: Since 2017, have you 22 designed substation replacement or upgrade projects? 23 THE WITNESS: Since 2017, yes, sir. 24 We are working with, like I said, a 25 large municipality in the state of Virginia where

65b96228-b9ab-4f72-9291-fa4a14ff04c8 30 (Pages 117 to 120) Page 117 1 they're replacing existing older equipment, and we're 2 doing two to three substations a year for them, and 3 we've been doing that for about five years. 4 CHAIRMAN NEUER: Okay. You answered my 5 question. 6 Thank you. 7 And as I was saying, you are accepted 8 as an expert, as a licensed professional engineer in 9 the State of New Jersey with experience in substation 10 design. 11 And I thank you. 12 DIRECT EXAMINATION 13 BY MR. TURTELTAUB: 14 Q. But just to qualify, one quick 15 question, Mr. Blanton, if you could. 16 When you talk about the design of a 17 substation in New Jersey versus North Carolina or 18 anywhere else you might design it, do -- does the 19 state matter in how you design it or is it the -- is 20 it the facility itself that tells you what you have 21 to do? 22 A. There are the National Electric Safety 23 Code and OSHA regulations how it has to be designed, 24 and they are the -- NESC and OSHA are -- have been 25 adopted by just about every state, and we design to Page 119 1 the substation, and if there was any way that the new 2 equipment could be moved or relocated or slid in some 3 manner that would possibly preserve trees on the 4 site. 5 You know, and again, there is no -- 6 there is nothing in the reports that I've seen that 7 describe the health of any of the trees that are 8 being removed, so I don't know if they need to be 9 removed because they are -- they have issues. 10 But I'll also go one step further and 11 go, I also understand the idea that sometimes the 12 utility needs to remove trees to maintain a high 13 degree of reliability. 14 We want to keep the power on because 15 that keeps everybody happy. 16 You know, I spent the majority of my 17 career being the one that was getting the call when 18 something major went out, and I had to go out there 19 and fix it. And we never wanted it to be due to a 20 tree falling in the line. 21 Q. So in terms of this site and the plan 22 that's before us, did you have a chance to review the 23 plans that are being presented by PSE&G? 24 A. Yes, I have. 25 I've looked at the site plan Page 118 1 those specs whether the state has adopted those 2 standards or not. Or if they've adopted something 3 more stringent, comply with that. 4 Q. And New Jersey, has it adopted those 5 standards or is it more stringent than that? 6

ate has adopted those 2 standards or not. Or if they've adopted something 3 more stringent, comply with that. 4 Q. And New Jersey, has it adopted those 5 standards or is it more stringent than that? 6 A. They have adopted those standards and 7 are not more stringent. 8 Q. And, in fact, have you done work 9 outside of the U.S. as well? 10 A. I have also worked in Pakistan for 11 about six months working with the distribution 12 utilities there to improve the reliability of their 13 substations and distribution lines. 14 Q. And your skills go there as well? 15 A. Yes, sir. 16 Q. So tonight we're here talking about a 17 substation facility upgrade that is going to happen, 18 PSE&G in West Orange, New Jersey. 19 If you could, for the benefit of the 20 board, to understand what your background is at least 21 in this project, can you describe for them what your 22 assignment was and what you've done to prepare for 23 that. 24 A. What I looked at, my assignment was to 25 look at how the new equipment is being installed in Page 120 1 development for the substation -- the site plan for 2 the substation being -- equipment being added and 3 realizing that, you know, it is obvious that Public 4 Service is removing a lot of the old structures 5 coming off of the three transformers on this site. 6 Q. This type of work and this type of 7 project, in the description of the work that you were 8 giving before when we were getting you qualified as 9 an expert, is this the type of plans that you've 10 looked at before and something you're familiar with 11 this type of a plan in general. 12 I am not talking about this specific 13 plan, right now, but just generally, have you worked 14 with this type of a project? 15 A. Yes, with -- I've worked with this type 16 of project where we're -- again, we're replacing 17 older existing equipment with newer, more modern 18 equipment that will provide a higher degree of 19 reliability for everyone. 20 Q. Okay. And in your review of these 21 plans, did you note anything with respect to the 22 design of it and in particular, what are the issues 23 you had mentioned in your -- in your preamble, which 24 is the protection or minimization of the elimination 25 of existing trees; did you come up with anything on