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

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