November 13, 2024 Planning Board Special Meeting Transcript - WEHI

93 1 specimens. I didn’t get to that yet. I’m asking you 2 very simply, why is it that your report says that with 3 limited exception the trees observed were in the 24 to 4 36 inch category and your histogram shows the exact 5 opposite. 6 A Well, let me try to clarify again. That statement 7 is based on a walkthrough of the area looking for, we 8 were looking for large trees. It was inarticulate in 9 the way I’ve worded that paragraph. I should probably 10 have done it better, but, it is to state that when we 11 walked through it we were looking for bigger trees and 12 we found bigger trees because we looked for them. It 13 is not a statistical analysis, it is not meant to 14 compare to something that was done in a very rigid 15 statistically valid method. That statement is 16 subjective and they would not necessarily match. 17 Q But what seems to be then -- what seems to me 18 that a rigid statistical scientific method would be 19 more reliable than a visual that you do when you 20 casually walk through, isn’t that fair to say? 21 A That’s fair to say which also supports the 22 conclusion that the forest is stagnant and, therefore, 23 needs to be protected. 24 Q Well, it seems to me that if your histogram, 25 which is the scientifically rigid study shows mostly 94 1 smaller trees, four, eight, 12 inches and almost no 2 larger trees, that would be more reliable than what 3 you say at Page 2, 3Ai of your report. 4 A You’re conflating information. I can’t answer a 5 question that’s got conflated data. I’ve tried to 6 explain that but I apparently have been unsuccessful. 7 Q Well, with respect it’s your data. I’m not 8 conflating data, I’m not making it up, it’s yours. 9 A You’re interpreting differently than what I wrote. 10 I have stated what I wrote and what it means. I’ll do 11 it again if you’d like, but, what it says is -- 12 Q No, we can move on. You said what you had to 13 say, we can move on in the point unless you have 14 something new on that point to offer. 15 A I do not. 16 Q Okay. Now, you say your were looking for 17 large trees when you did that walkthrough but, when you 18 did the histogram you weren’t looking for large trees? 19 I’m trying to understand that. 20 A I did not say that. 21 Q Well, it sounds like that and I’m trying to 22 understand what you mean. 23 A What I said was, in the scientific survey when 24 you’re doing a tree survey,

derstand that. 20 A I did not say that. 21 Q Well, it sounds like that and I’m trying to 22 understand what you mean. 23 A What I said was, in the scientific survey when 24 you’re doing a tree survey, you’re looking for what’s 25 there and you do so in a statistically valid method 95 1 using a statistically valid pre-survey methodology. 2 For example, it states that you will use a GPS locator, 3 you will use GIS, you will locate your study plots 4 within a specific area if that is what you were 5 assigned to do. It says further that your study plots 6 must be of a specific size. They’re 100 square feet, 7 actually statistically 10 by 10. You also look at -- 8 and you do counts. You do counts, you do 9 identifications, you then subject all of that to a 10 statistical analysis. 11 What I stated about the trees when we walked 12 through in 2024, which, again, was at the request and I 13 don’t know which meeting, forgive me for not 14 remembering that, it was, can you please walk through 15 and see if the forest has changed. In that discussion, 16 in that walkthrough, we decided to look, again, 17 subjectively, hey, are there any large trees here that 18 are worth saving, let’s start looking at the larger 19 trees and see if there are some things here, we might 20 have some nice specimen trees, let’s see if we can work 21 with the developer later and save some of these 22 specimen trees, which would be to everybody’s benefit, 23 if they can be saved. 24 So, the secondary component is subjective and 25 not a statistically meritorious analysis. It is my 96 1 professional opinion based on observations in the field 2 which, scientifically, observations in the field have 3 value. Can I support those observations with 4 statistical analysis, I cannot. 5 Q Would you agree that the state of deer browse 6 on our forests has been essentially the same since the 7 early 1990's? 8 A I couldn’t answer that. 9 Q Why can’t you answer, you’re a biological, 10 environmental scientist? I thought you had knowledge - 11 - 12 A Are you talking about this forest? I wasn’t here 13 looking at it in 1990. 14 Q No, I’m asking you in general, is the 15 subject, is deer browse in our forest essentially the 16 same over this period of time? 17 A Deer browse has gotten worse since 1990. 18 Q Well, has it -- are you in a position to 19 state the extent of change in deer browse in our New 20

essentially the 16 same over this period of time? 17 A Deer browse has gotten worse since 1990. 18 Q Well, has it -- are you in a position to 19 state the extent of change in deer browse in our New 20 Jersey forests, northern, New Jersey, not the pine 21 barrens, over this time period? 22 A No. You would have to study a specific forest to 23 do that. You’d have to actually have a forest analysis 24 which I did, I add to my report in there for Essex 25 County, where they very specifically hire someone to go