December 10, 2025, Planning Board Special Meeting - WEHI Transcript

01/14/2026 10:36:25 AM Page 69 to 72 of 144 18 of 55 sheets 69 Which doesn't matter any way?1 Q. Sorry.2 A. Which you think doesn't matter any way?3 Q. No, no. What I'm saying is, you know, that it's4 A. important to understand that this is not something that5 doesn't, you know, that doesn't already exist. The6 slope is not being actually built on.7 And yet you decided it was a factor that the8 Q. engineers had to address, is that correct?9 It was a prudent analysis to do.10 A. Now, you agree that this slope has numerous rock11 Q. outcropping, don't you?12 Not sure numerous. There's nine or ten. I think13 A. they're numbered, but there's nine or ten of them.14 Something like that.15 So you say that this is a soil slope not a rock16 Q. slope, that's your opinion?17 Correct.18 A. Now, where in Section 8-13, for example, of the19 Q. Army manual -- well, the Army manual, does it define, I20 asked this earlier, I'm not sure you answered it. Where21 in the Army manual does it give a definition of soil22 slopes. Are you aware of any?23 Precise definition, no, I am not.24 A. A definition?25 Q. 70 It's a slope with a stability where the stability1 A. is controlled by the soil properties not the rock2 properties.3 I asked you where in the Army manual there4 Q. appears a definition of a soil slope. Can you answer5 that question?6 It would be the 1902 manual is a slope stability7 A. manual. So that's, there is a description of what a8 slope is in there.9 There's also a description of a rock slope in10 Q. Section 8-13?11 Well, that's the 2908 manual.12 A. Correct.13 Q. The 2908 is rock foundations.14 A. Well, in many places you have soil thinly15 Q. covering rock, isn't that correct?16 Correct. Including here.17 A. Including here. Including say the Palisades18 Q. Ridge, you have thin soil, which is why you get dessert19 like plants such as cacti living there, correct?20 I am not aware of that, but.21 A. Okay.22 Q. But in many cases on rock outcroppings on cliffs,23 on igneous extrusions that exist we have a thin layer of24 soil over a very large and substantial base of rock,25 71 isn't that correct?1 Correct.2 A. Now -- and now in 8-13 rather than all of 2908, I3 Q. don't see any definition for rock slope that means only4 a slope with no soil. Do you see such a definition?5 Right, but it's a foundation manual.6 A. All right. It's the foundation manual dealing7 Q. with

see any definition for rock slope that means only4 a slope with no soil. Do you see such a definition?5 Right, but it's a foundation manual.6 A. All right. It's the foundation manual dealing7 Q. with rock foundations, correct?8 Correct.9 A. And rock foundation refers not only to the10 Q. foundation on which you put a building, meaning you're11 building it on rock, but also the rock structure on a12 slope that holds up the rest of it, correct?13 Right, but there are no foundations going on this14 A. slope.15 I understand that. But where in Section 2908 do16 Q. you find the definition of rock slope that means only a17 slope where there's no soil and only rock? Where do you18 find such a definition.19 I don't contend that either.20 A. So in other words, whether it's a soil slope or a21 Q. rock slope in your nomenclature depends in some vague22 way, which no one knows, on how much soil there is, is23 that what you're saying?24 An analysis was done by two consultants and did25 A. 72 not identify any slope failure mechanisms that involved1 the rock. The Princeton Hydro reduced the assumed rock2 strength criteria and they still had a safety factor of3 1.7, which --4 On one of the buildings not Building D?5 Q. No, it's not a building. It's -- these failures6 A. services, if you look at the things, the failure7 services do not go through the building.8 Where were they using a 1.7 figure?9 Q. It was in Princeton Hydro's report.10 A. But you're using 1.5, right?11 Q. Right.12 A. And you're saying Langan's using 1.5 is okay,13 Q. right?14 That's my opinion.15 A. So yet there is a difference between the higher16 Q. standard Princeton uses for this residential apartment17 complex and what Langan and Anderson used?18 It's not for the residential apartment complex.19 A. But that's what we're building, right?20 Q. Sorry.21 A. We're building one, right?22 Q. Yeah, but you're not building it on a slope.23 A. Well, we're not doing safety standards for the24 Q. squirrels that live here, we're talking about people who25