I posted on this topic a while ago.

https://www.electrical-contractor.net/ubb/Forum1/HTML/006773.html

They drove me nuts with this - We were doing work in PSEG territory where it is not required.

The kicker is - our customer (a large international construction management firm representing AT&T/Cingular) was more than willing to pay for the change order if we could either give them a spec that said it was required or a signed letter from JCP&L saying it was required in these cases.

JCP&L could not provide either - unbelieveable