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

Page 40 1 to the tips of the branches -- and, you know, the 2 roots do exceed that. 3 But that -- the drip line of the tree 4 pretty much defines the protected root zone. We 5 really don't want to be removing roots within that 6 area. 7 If you have to remove some of them, you 8 sort of monitor what percentage of roots are -- if 9 it's a -- if it's, let's say, 10 percent of the roots 10 on the tree, the tree will recover from that. 11 But as you get -- doing the trenching 12 or anything closer to the trunk of the tree, then 13 you're affecting the stability of the tree and then 14 the safety of the public or the surrounding 15 structures. 16 Q. And the drip line being the edge of -- 17 the maximum edges of the tree branches. Is that 18 correct? 19 A. Right. 20 It's, you know, it's a radius around 21 the entire tree. 22 Q. Okay. And in looking at the plan 23 itself, did you see opportunities to possibly -- and 24 we'll get into engineering testimony, but just from 25 your perspective and your experiences, ways to