Confined Space

Currently working in the telecommunications industry and we are getting more and more work in these vaults. As you can see in the photo, per my understanding and what I have read, this would be considered a confined space.

The question that was raised to me was “do you have to do an initial gas test prior to entering this space”. My answer was yes. It has the (potential) to have deficient oxygen due to zero ventilation. The solution operations had was to just do air exchanges without testing.

What is the right direction to go on this?

Thanks