November 13, 2024 Planning Board Special Meeting Transcript - WEHI

109 1 forest looks like. 2 Most importantly, the specific identification 3 of a specific area of the specific forest is irrelevant 4 because the overall conclusion of this forest shows 5 that walking the forest, the only, as I’ve testified 6 to, the only undergrowth that is there typically, to 7 say only, that’s absolute, the majority of the 8 undergrowth growing there is typically invasive species 9 such as Japanese spill grass and barberry, which are 10 non-native and also not wildlife habitat and throughout 11 the forest there is a dirth, a very strong lack of 12 undergrowth. So, lack of undergrowth -- so the lack of 13 undergrowth in the entire forest indicates that the 14 forest is overly browsed which is supported by at least 15 two documents that have been submitted as additional, 16 per your request, I might add, for additional 17 information showing studies the most recent being the 18 2023 summary of the South Mountain Reservation study 19 done by the Essex County Park system and you will look 20 in multiple documents even up to and inclusive of the 21 Association of New Jersey Environmental Commission’s 22 report on trees, dated 2024, every single report 23 discusses the impact of excessive deer browse leading 24 to a lack of under story growth. So, there are 25 multiple studies saying the same thing with different 110 1 observations. And the different reports that I 2 submitted, you don’t see any photographs in some 3 cases. Some cases it’s a statement of the scientist’s 4 observations. I have given you my scientific 5 observations and my scientific conclusions. 6 Q Is there anything else to add in response to 7 my question as to whether it would be a proper 8 scientific act to document this report more thoroughly? 9 A In my opinion, this report has been documented 10 properly. 11 Q Did you consult any other tree studies on 12 this property, aside from the one that you had Amy 13 Greene do? 14 A I’m not certain I understand the question. 15 Q Have any other tree studies been done on this 16 property? 17 A I don’t know. 18 Q Did you ask the developer if they had done 19 any? 20 A I may have, but, if I had he didn’t have one to 21 the best of my knowledge. 22 Q Do you recall asking the developer if they 23 had done a tree study on this property? 24 A Again, my recollection is, I probably would have 25 but, I can’t say with certainty but, I do not

ledge. 22 Q Do you recall asking the developer if they 23 had done a tree study on this property? 24 A Again, my recollection is, I probably would have 25 but, I can’t say with certainty but, I do not have any 111 1 other studies which is part of the answer, I believe. 2 Q The photograph that’s on the screen, on the 3 slide example of excessive deer browse, would you agree 4 that actually reflects a trail or path that’s been trod 5 over the years? 6 A No. 7 Q That in your opinion there’s no evidence of - 8 - 9 A There’s no trail there. That is not a trail. 10 There are trails on the property, that is not one of 11 them. 12 Q Now, you do recall asking the developer if 13 they had a tree study? 14 A Yes, I do. 15 Q Did you ask the developer? 16 A My recollection is I did, and there wasn’t one. 17 But, I can’t speak to certainty on that. 18 Q How many trees per acre do you calculate in 19 your statistical discussion? 20 A Bear with me, it’s in here somewhere. There we 21 go. Using the analysis provided in the 2019 study, we 22 did a calculation of 212 trees per acre. 23 Q And you based that on what -- what was your 24 analysis that led to the 212 figure? 25 A The statistical tree study performed in 2019. 112 1 2 Q As reflected on the histogram. 3 A No, reflected in the tree study, which is posted. 4 Q But, you didn’t submit the tree study itself 5 to the Board, did you? 6 A The Board asked me for my report which is what 7 they obtained. Subsequently, the Board asked for the 8 original tree study, which I submitted. 9 Q And when did you post that? 10 A As I said yesterday, supplementals were able to go 11 up yesterday because of problems we had last week. 12 Q I just want to clarify, Mr. Bagoff asked me 13 at the next time to focus on that, so that’s one of 14 those documents we will look at. 15 A Okay. 16 UNIDENTIFIED SPEAKER: January 6, 2020? 17 THE WITNESS: That’s when my report is dated, 18 yes. 19 MR. AFRAN: I don’t remember the date off 20 hand but, whatever the date of that 2020 study was. 21 Q Now, the 212 figure comes from, is that an 22 average from the study plots? 23 A Well, statistical analysis doesn’t work quite that 24 way. 25 Q Well, I’m asking you.