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

65b96228-b9ab-4f72-9291-fa4a14ff04c8 14 (Pages 53 to 56) Page 53 1 have any opportunities that could save trees, we'd 2 like to see -- see you do that. 3 Q. Thank you. 4 Are you aware of or familiar with 5 provisions governing distances from trees to 6 electrical equipment, with the tree fall area, so to 7 speak? 8 A. Well, it's usually 10 feet to energize 9 conductors, that's the close proximity act. 10 But, you know, we have -- in terms of 11 distribution, we have, you know, single phase 12 electric primary, you have open wire primary on a tee 13 on top of a pole. That requires, you know, greater 14 -- greater clearance, but -- and it, you know, 15 there's all different kinds of configurations. 16 But all I know is 10 feet is about as 17 close as you want to get to anything other than house 18 service. You know, which most tree companies are -- 19 and many public works departments are capable of 20 clearing a house service, but not an electric 21 primary. 22 Q. And have you ever personally 23 experienced or experienced in connection with one of 24 the jobs that you worked on an outage, an electrical 25 outage associated with a tree that fell on a power Page 55 1 Q. Thank you. 2 Do you have any familiarity with 3 IEEE 979, which recommends trees located 30 -- be 4 located 30 feet beyond the fall potential to 5 structures? 6 A. Yeah, that's beyond my knowledge. 7 Q. Okay, thank you. 8 A. I'm not a utility arborist. 9 Q. Are you aware of any trees on PSE&G's 10 site which are, either by statute or by regulation, 11 specifically preserved? 12 A. I'm not aware of any on the site. I 13 just -- I just know you got some pretty large trees 14 over there. 15 Q. Thank you. 16 And, lastly, are you familiar with the 17 topography of this site? 18 A. Visually, yes. 19 You know, just from the outside looking 20 in. 21 Q. So you are familiar with it, how it 22 slopes downward? 23 A. Absolutely. 24 Q. Okay, thank you. 25 MS. PORTER: Okay. Page 54 1 line or power equipment? 2 A. Oh, yes. 3 All the time. 4 Q. And is it your understanding that it is 5 for that reason why there are tree clearance 6 requirements in place? 7 A. Yes. 8 You know, one of the pet peeves that 9 most municipalities have is when a utility attaches a 10 span guide from a utility pole to a tree. 11 And we had a humerus situation in West 12 Orange a few years ago where the tree -- there was a 13 span

municipalities have is when a utility attaches a 10 span guide from a utility pole to a tree. 11 And we had a humerus situation in West 12 Orange a few years ago where the tree -- there was a 13 span guide attached to a town tree, and the tree fell 14 over and it pulled the utility pole down. 15 It is -- so, so there's always -- there 16 is always interaction with the utility companies and, 17 you know, there is always an issue when a tree dies 18 and the cooperation is requested and needed from a 19 utility company in providing assistance to a 20 municipality in removing trees. 21 And, you know, for the most part, you 22 know, West Orange has maintained a good relationship 23 with Public Service over the years. 24 And, you know, it's -- it's, you know, 25 one hand washes the other. Page 56 1 I have no further questions. 2 CHAIRMAN NEUER: Members of the board? 3 Let's start with Mr. Schwarzbaum and 4 work our way through. 5 VICE CHAIRMAN SCHWARZBAUM: So, 6 Mr. Linson, I think you testified that your -- you 7 are opining that certain trees should be removed -- 8 should not be removed, sorry. 9 Is that correct? 10 THE WITNESS: That's correct. 11 VICE CHAIRMAN SCHWARZBAUM: And you 12 also testified that you -- that your opinion -- that 13 you didn't look at what the actual construction needs 14 of the utility are. 15 Is that correct? 16 THE WITNESS: That's correct. 17 VICE CHAIRMAN SCHWARZBAUM: So in your 18 professional opinion, have you ever removed trees 19 because of construction needs? 20 THE WITNESS: Oh, all the time. If you 21 can't make a tree safe, if the root system is 22 compromised, if there is a structural deficiency in 23 the tree, they need to be removed. 24 VICE CHAIRMAN SCHWARZBAUM: So the -- 25 THE WITNESS: Safety first.