Ltr to Chairman Neuer and ZBA Members w EXHIBITS FOR LTR REQUESTING 2 BD MEMBERS REQUSAL 2 10 25 PSEG 325 MT PLEASANT WO

CHIESA SHAHINIAN & GIANTOMASI PC 105 Eisenhower Parkway, Roseland, NJ 07068 csglaw.com JENNIFER M. PORTER Member jporter@csglaw.com O 973.530.2071 F 973.325.1501 February 10, 2025 VIA FEDEX & EMAIL (pdn@neuerlaw.com) Chairman Neuer & Members of the Zoning Board of Adjustment Township of West Orange 66 Main Street West Orange, NJ 07052 Re: PSE&G/325 Mt. Pleasant Avenue, West Orange, Application No. ZB-24-06 Request for Recusal of Zoning Board Member Daniel and Alternate Dubovy Dear Chairman Neuer & Members of the Zoning Board of Adjustment: As the Board is aware, we represent Public Service Electric and Gas Company (“PSE&G”) in connection with its application for preliminary and final major site plan approval with variance relief for property located at 325 Mount Pleasant Avenue (the “Property”) that is presently developed with PSE&G’s West Orange Switching Station (the “Application”). We are writing this letter to request that two (2) of the recently appointed members of the West Orange Zoning Board of Adjustment (the “ZBA”) recuse themselves from participating on the Application due to conflicts of interest for the reasons detailed below. I. Member - Robert Daniel PSE&G respectfully requests that Member Robert Daniel recuse himself from hearing and participating on the Application if he is in fact the individual listed below that resides within 200 feet of the Property, which is the subject of PSE&G’s application. Attached as Exhibit A is a copy of PSE&G’s 200-foot certified property owner list obtained from the Township’s Tax Assessor’s Office. Page 6 of the list contains the following name: Daniel, Robert & Beth, 2B Buckingham Rd., West Orange, NJ 07052 ZBA model rule 2:10-2(a)(1) states “any member of the Board of Adjustment shall disqualify himself from sitting on the hearing of any matter in which he has a disqualifying interest, such as, but not limited to, the following situations…where he owns property located within 200 feet of the property affected by the action.” The Municipal Land Use Law (N.J.S.A. 40:55D-12b) (the “MLUL”) requires notice to be given to all property owners located in the state within 200 feet in all directions of the property which is the subject of the hearing. This demonstrates the legislature’s determination that property owners within 200 feet of the property to be affected by a zoning board proceeding NEW

he property which is the subject of the hearing. This demonstrates the legislature’s determination that property owners within 200 feet of the property to be affected by a zoning board proceeding NEW JERSEY NEW YORK 4896-9548-7511.v2