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

21 of 55 sheets Page 81 to 84 of 144 01/14/2026 10:36:25 AM 81 What you're saying is where my arm is gravity1 Q. works on the rock in this downward direction to the2 east?3 Correct.4 A. Because there's nothing here on the eastern side5 Q. holding back the rock, correct?6 There is. There's friction.7 A. Correct. But gravities working against friction8 Q. and pulling it?9 Yeah, but there's -- but Langan assumed a10 A. representative friction angle on the joints of 3511 degrees, which is two times 17 degrees, which would12 provide enough resistance to keep the block from13 sliding.14 And if you didn't have enough resistance the15 Q. block would slide, correct?16 Correct.17 A. Thank you.18 Q. So we're building this apartment on a structure19 that if this calculation is wrong means this building20 and rock could slide, correct?21 Right.22 A. Thank you.23 Q. Well, sorry. Can I strike that?24 A. No, you can't strike an admission. Only we can25 Q. 82 strike, Mr. Plocker and I and Ms. McGovern, but you can1 not strike. Thank you very much.2 Now --3 MR. PLOCKER: Would he like to explain what4 he was going to say. We're all about a fair and full5 record, Bruce. So I think he should be allowed to say6 what he was going to say.7 You believe the building could slide or the rock8 Q. could slide if the friction elements and analysis here9 are wrong?10 No.11 A. You just said they could?12 Q. I said the rock could slide, I didn't say the13 A. building could slide.14 I see. So the rock under the building could15 Q. slide but the building somehow is going to stay16 straight, is that what you're testifying to?17 No, there is not enough force to move it. The18 A. building is, it's ten to 40 feet beyond the ridge line19 and the ridge line is another 20 or 30 feet of rock20 before the slope ends.21 So why are you referencing this concern in your22 Q. report, again, if you say now it doesn't matter?23 I reference it as a, as a factor that was24 A. observed. It was observed in the Langan report and it25 83 was, I don't remember if Princeton Hydro addressed it.1 Well, you said it wasn't favorable, that means2 Q. there's a problem potentially?3 The direction is not favorable, but they implied4 A. that there is, there is adequate frictional resistance5 to keep it from moving.6 They implied it?7 Q. They said.8 A. One moment they're implying, one moment they're9 Q. saying. What is it,

implied4 A. that there is, there is adequate frictional resistance5 to keep it from moving.6 They implied it?7 Q. They said.8 A. One moment they're implying, one moment they're9 Q. saying. What is it, definitively or is it an inference10 that's just wrong, which is the case?11 They reported in their technical engineering12 A. report that a friction angle of 35 degrees can be13 assigned to the rock joints.14 Do they explain why and what the basis of that15 Q. was?16 No, they did not go into a detailed explanation17 A. of it.18 So you can't really evaluate it because they19 Q. didn't give you enough to do that, can you?20 That was their judgement and they spent time21 A. looking at it and there was, there's, there are criteria22 related to the roughness of the joints and what kind of23 soil filling, if any, there is in the joints and24 whatever they looked at they based on the fact that25 84 they're experienced engineers, they said that 35 degrees1 can be assumed for the rock.2 And based on their assumptions, without any3 Q. documentation or support that you can see as an4 independent evaluator, you're satisfied that must be5 right and this friction inclination is so sufficient6 that there's no danger of rock slide, is that your7 testimony?8 Is that my testimony?9 A. Yeah. Is that what you're saying.10 Q. My testimony is that they said it was 35 degrees11 A. and you have to ask them.12 I'm asking you as the independent evaluator.13 Q. It is in my experience a representative value of14 A. friction coefficient for rock on rock joints.15 I couldn't hear you, I'm sorry. Go ahead, sorry.16 Q. Couldn't hear you.17 It's a representative friction coefficient for18 A. rock on rock joints.19 What do you mean, it's representative? Is there20 Q. some manual that says rock wall has a 35 degree angle?21 There are manuals that you use as references that22 A. based on a description, that's what engineers do all the23 time.24 No, I'm not asking if there are manuals that say25 Q.