December 11, 2024 Planning Board Special Meeting Transcript - WEHI

15 of 38 sheets Page 57 to 60 of 100 01/08/2025 12:06:06 PM 57 So if they have 2 or 3 times more trees on the1 Q. site calculated and they're right, that means the2 average lost trees will probably be closer to 15,0003 rather than 6,390?4 Seeing this is a statistically flawed study, I do5 A. not think they're right. But if their math is correct,6 obviously the math is the math. You put in a variable,7 the variable gives you a result. You change the8 variable the result changes.9 So if their study is right, that means you get a10 Q. lot more trees lost then you're using?11 If their math is correct then there would be a12 A. higher tree removal theoretically per acre of the13 survey, correct.14 I didn't ask if the math was correct. I simply15 Q. put of point to you. If their study is right then16 there's going to be a lot more lost trees, correct?17 But their study is predicated on math. So their18 A. math has to be correct. For their math to be correct19 their variables and inputs to do the calculations for20 total trees, the variables they enter, must be correct.21 If they're wrong then it's wrong.22 I'll move on. It's not my purpose in life to23 Q. beat the horse dead. I'll move on.24 Now, what's interesting to me is that you knew25 58 about the 2007 plan when you did your own tree report,1 isn't that correct?2 This document, 0-3?3 A. That's not what I asked you.4 Q. I'm asking you for clarification.5 A. I'm asking the questions. You knew about the6 Q. 2007 development proposal from the developer?7 Yes. I knew there were prior development8 A. proposals, yes.9 And you knew there was a 2007 proposal, correct?10 Q. I couldn't speak to the year, but I knew there11 A. was a prior one. I couldn't speak to the year.12 Well, it's actually, it says here, West Essex13 Q. Highlands Affordable Housing Development 202314 Presentation. You recall that, right?15 As I said, I knew there were prior plans. I just16 A. couldn't speak to the exact year off the top of my head.17 Okay.18 Q. And that document you refer and actually put on19 the site plan, 2007 Housing Development Plan, on this20 site, correct?21 If you show me the document, which one that22 A. occurred. I have done several presentations, I'm not23 sure which one you're talking about.24 CHAIRMAN BAGOFF: Mr. Afran, you entering25 59 that document into the record?1 MR. AFRAN: I think -- I think it's

ed. I have done several presentations, I'm not23 sure which one you're talking about.24 CHAIRMAN BAGOFF: Mr. Afran, you entering25 59 that document into the record?1 MR. AFRAN: I think -- I think it's already2 entered.3 MS. McGOVERN: Yeah, identify it so we know.4 You're holding onto something.5 MR. AFRAN: Yeah, I will in a second. I'm6 sorry, it is very hard to work on this station. I need7 a moment to get the right page.8 MS. McGOVERN: Sure.9 Mr. DeFeo, I'm showing you what we'll mark as10 Q. O-4. And its headed, as I said, West Essex Highlands11 Affordable Housing Development 2023 Presentation.12 Public information presented by William DeFeo, Lead AP13 Environmental Compliance Officer, West Orange. Do you14 recall that?15 Yes.16 A. Okay.17 Q. (West Essex Highlands Affordable Housing18 Development 2023 Presentation is marked as Exhibit 0-419 for identification.)20 MS. McGOVERN: Counsel, we need a21 description better. You went really fast.22 MR. AFRAN: I apologize.23 MS. McGOVERN: You need to give a copy to24 Jamilet so we have it for the record.25 60 MR. AFRAN: The documents headed, West Essex1 Highlands Affordable Housing Development 2023. And it2 has some other text, but then towards the bottom it3 says, Public Information Session, May 10, 2023.4 Presented by Wayne DeFeo, Environmental Compliance5 Officer, West Orange.6 MS. McGOVERN: Okay.7 MR. AFRAN: Sorry I spoke to quickly.8 MS. McGOVERN: Thank you.9 Mr. DeFeo --10 Q. MS. McGOVERN: Do you have an extra copy?11 MR. AFRAN: I think we do. I can give you12 this one.13 MR. PLOCKER: Is this part of the document14 posted? It is not. Okay. I was just wondering.15 MS. McGOVERN: To be fair Mr. Afran, before16 you give to it Jamilet, would you give it to the17 applicants attorney to take a look so he can see what18 you're cross examining.19 Was -- Mr. Plocker had a good point, let me just20 Q. identify it.21 Was this presentation the one you made at the22 hotel?23 It appears to be. I don't have it in front of me24 A. but that would be roughly the date I recall.25