December 11, 2024 Planning Board Special Meeting Transcript - WEHI

01/08/2025 12:06:06 PM Page 37 to 40 of 100 10 of 38 sheets 37 Other than bore ash we heard. Then the trees1 Q. that were there on the 2010 survey probably are still2 there, isn't that a fair statement?3 Possibly. Sure, probably. Maybe. That's why we4 A. did an independent tree study in 2019 to make certain5 that we had accurate data. This document is completely6 inaccurate and therefore I discount every bit of data in7 there.8 Even though you never spoke to anybody who did9 Q. the survey?10 Doesn't matter. It's a statistically invalid11 A. document because it did not study sufficient quantity of12 areas, nor does it give you the calculation methodology13 nor anything else. Simple fact is when you have14 something that uses such a very small nonrandomized, as15 far as I can tell, system it is statistically invalid16 and therefore I discount this.17 Can I go to my question now?18 Q. It's your time.19 A. Now, you projected 211 trees per acre on average,20 Q. isn't that correct?21 I think it was 212, but it's been a while since I22 A. looked at that sheet. 212.23 212. Okay.24 Q. Now, on the basis of that, you calculated for the25 38 entire property 25,440 trees, is that correct?1 I would have to look at the slide to give you2 A. that. Hang on. Sounds about right.3 I'm reading it from your slide?4 Q. I'll take your word for it, you wouldn't lie to5 A. me.6 Now, that was your count of 4 inch trees and7 Q. greater?8 Correct.9 A. Now, this study, if you look on the document,10 Q. came up with an average of 558 trees per acre, you see11 that?12 I do.13 A. Okay.14 Q. So that's almost three times larger than your15 average calculation, correct?16 Yeah.17 A. Now, they yield a total of 63,36l trees in a18 Q. range between 2 inches and 6 inches. And they reveal a19 total of 20,666 trees 6 inches and higher, for a total,20 and I've done the math, I don't think it's on there, but21 those two figures together equals 84,027 trees?22 I'll believe your math.23 A. What happened to 60,000 trees?24 Q. This report is statistically invalid and25 A. 39 therefore -- you familiar with GIGO, garbage in, garbage1 out? There's garbage data in and garbage data out. I2 do not give any credibility to this report because the3 data is flawed. The methodology is flawed. The study4 area is flawed. Ergo it is statistically invalid and5 therefore it has -- these numbers are meaningless.6 Why is

ility to this report because the3 data is flawed. The methodology is flawed. The study4 area is flawed. Ergo it is statistically invalid and5 therefore it has -- these numbers are meaningless.6 Why is the study area flawed?7 Q. Well, as I stated earlier, there are three 10,0008 A. square foot plots, that sounds very impression by the9 way. And if I wanted to know what 10,000 square foot10 looked like, it's good, but statistically it's 0.61,11 roughly, percent of the area of study. That is a12 statistically invalid tree study. Ergo the conclusions13 it draws must be statistically invalid.14 Your percent of the area of study is much, much15 Q. smaller, isn't it?16 No, my percent of the area of study that we did17 A. was approximately a little better than 2.2 to 3 percent18 approaching 4 using a running mean, which is acceptable19 in the industry as a statistically valid study.20 You get 2.2 percent only because you're measuring21 Q. against the area of disturbance. Whereas in this study22 they were measuring against the whole plot of the23 forest, isn't that correct?24 You're defining your study area as when you do a25 A. 40 forest survey --1 Mr. DeFeo, you have a constitutional problem2 Q. answering "yes" or "no" to any question?3 You defined --4 Mr. Afran.5 A. -- you define 2.2 percent of the area of6 Q. disturbance and their -- and then you're saying their7 percentage is based on the whole 100 acres of the8 forest, isn't that correct?9 Mr. AFran, I'm going to answer your question10 A. again, as I'm under oath and I have to speak to my best11 professional ability here. A "yes" or "no" answer may12 not be true. Ergo, yes, I have a constitutional problem13 giving you a "yes" or "no" answer if it's not true. Let14 me answer your question.15 No, let me repeat the question. You have said16 Q. that your study covers 2.2 percent --17 Approximately.18 A. -- approximately of the study area, correct?19 Q. Uh-huh.20 A. An you said --21 Q. Yes, I'm sorry.22 A. And you said their study covered 0.6 percent of23 Q. the area of study, correct?24 Correct.25 A.