October 29, 2025, Planning Board Special Meeting - WEHI Transcript

3 of 59 sheets Page 9 to 12 of 149 11/19/2025 04:42:31 PM 9 they really are and there's never any record of any1 notice of mottling. I think they took 100 test pits and2 we found that very suspicious. So what we've actually3 done is we had gone out on our own, we went near the4 site, we were not on the site, but we did four of our5 own test pits, we only went a few feet deep and each6 time we were able to find evidence of mottling within 127 inches of grade of the surface. Now, I am not saying8 that they would've always found mottling in all their9 test pits, but I did find it strange that we went four10 for four and they went from like zero for 100. So it's11 not, I don't think that they didn't see it, I just don't12 think they really ever were looking for it. So I think13 that's a little, I think those flow records are flawed14 and I just needed to point that out. And for the15 record, where we looked it's, we have the soil borings16 and the locations are in the O-30 record that we17 submitted and two of the test pits are within about 30018 feet of, at most 300 feet of Basin 1 and the other two19 are within about 300 feet of Basin 7. So while they're20 not on-site we're not terribly far away either from21 where these basins are and where you'd think if we saw22 mottling you would think they would have saw mottling as23 well.24 So I know that CME also said that, you know,25 10 they need to do additional testing and when they do more1 test pits that should be a condition of the approval. I2 think that's a really risky way to approach it. Because3 if we're right and the seasonal high water table is4 actually higher than we suspect, a lot of these basins5 are going to lose storage pretty quickly. Especially6 the aboveground storage basins. You know, you lose a7 foot, you lose two feet, you lose a significant amount8 of volume and then it starts to become very, very tricky9 of how you find that additional volume on the site,10 because you don't go down you have to go out and as11 everyone's seen on the plans there's a lot of site12 constraints. The designs very tight and I don't know13 where they would find extra volume and so then suddenly14 you're in a situation where they're building, what are15 they going to do. How are they going to change the16 design to meet the requirements of the DEP and local17 ordinance and it's in the middle of a

u're in a situation where they're building, what are15 they going to do. How are they going to change the16 design to meet the requirements of the DEP and local17 ordinance and it's in the middle of a construction18 project. All right. That's about all I wanted to say19 for the mottling and the lack of mottling in any of the,20 or in any of the soil profiles or stormwater report.21 Next I would like to talk about there is a22 discussion using alternative methods for groundwater23 mounding, TC calculations, or the Time of Concentration24 calculations, which result -- which are used to figure25 11 out the peak flow elevations. CME's right. In the DEP1 manual you actually use alternate methods to get to2 these stormwater calculations. But what's funny about3 when you read the stormwater report from the applicant,4 is they never really talk about using alternate methods.5 You read it, it seems like they're following, following6 it straight like as per code. They never cite an7 alternative reference and they never provide a8 justification for an alternate method. For example, I9 had talked about how they, when you have a flow path10 there's not a way of calculating velocity. This is a11 way of calculating how long that water takes to go down12 the flow path and they're definitely using an older13 method where you just classify it as unpaved. And the14 latest method requires you to look at the slope and the15 actual land uses and the forests and meadows, the16 street, so the newer method is a more conservative17 approach. The older method that the applicant uses18 it's, it makes the design more easy. I would think if19 you're going to use alternate methods you need to cite20 the method that you used, but then also cite the21 justification why this methods more appropriate then22 what the standard is. And they never do that. And it's23 not justified in the -- CME's report also does not say24 what the method is or why this method is better and more25 12 appropriate in this scenario. So alternate methods in1 some scenarios are more appropriate but there was two2 specific things that came with the TC runoff, the Time3 of Concentration runoff calculation. We didn't classify4 them as alternate methods. We classified two math5 mistakes -- not math mistakes, two analysis mistakes6 wherein one of the watersheds, one of the drainage areas7 when you calculate Time of

classify4 them as alternate methods. We classified two math5 mistakes -- not math mistakes, two analysis mistakes6 wherein one of the watersheds, one of the drainage areas7 when you calculate Time of Concentration you have to8 calculate it for the entire flow path of -- throughout,9 from the highest point to the bottom. It's called,10 point of analysis. They only calculated about half of11 the flow path. We couldn't figure out why. That was a12 mistake that would make the design easier to do. It13 seemed like a mistake, but it wasn't an alternate14 method, at least it's not a method that I'm aware of, or15 anyone else that I know of, that would be applicable.16 Again, that's a scenario where I think you would have to17 cite the method, cite the reference of the method and18 why this is more appropriate. I will just give you an19 example of the method the DEP requires or cites in their20 references are, they come from the National Engineering21 Handbook that was written by the USDA and the Natural --22 the Natural Resources Conservation District. So this is23 typically the reference that we use when we're trying to24 do the stormwater calculations. It's a handbook, it's25