This tree is obstructing the access to this electrical junction box. It was planted after the box was first installed. We can pick any rule we want where working space and access are required, and the rules will be the same. See Section 110-26 in the 1999 NEC and 110.26 in the 2002 NEC. 110.26 Spaces About Electrical Equipment states, “Sufficient access and working space shall be provided and maintained about all electric equipment to permit ready and safe operation and maintenance of such equipment. Enclosures housing electrical apparatus that are controlled by lock and key (“not a tree”) shall be considered accessible to qualified persons.”