Trinity installs solar panels on residences, and operates in New Jersey, Maryland, Pennsylvania, New York, Connecticut, Massachusetts, Rhode Island, and Florida. (Tr. 637-638; J-1 ¶¶ (c)(1), (3)). Over 30 years, Trinity has grown from a five-employee heating and air conditioning company serving commercial and residential customers to a residential-only solar panel installation company employing 3,236 workers. (Tr. 637-638; J-1 ¶ (c)(3)). Trinty’s revenue exceeded $10 million dollars in 2022. (J-1 ¶ (c)(4)). Trinity averages 40-70 jobsites on a given day. (Tr. 435).
In October 2022, Trinity was engaged in solar panel installation on a two-story single-family home in South Orange, New Jersey. See, e.g., Ex. C-1, C-3 (photographs of the worksite); (Tr. 65, 80). As relevant to this case, the multi-day project entailed installing solar panels on two separate roofs of the residence – the upper roof which was at 22 feet height and the lower roof which was at 12 feet height. (Tr. 66, 72, 603, 798).