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

01/14/2026 10:36:25 AM Page 85 to 88 of 144 22 of 55 sheets 85 a 35 percent inclination is safe. I'm asking, how do1 you know that calculation is correct?2 It's based -- it's consistent with references3 A. that talk about rock on rock joints.4 Well, that depends on the nature of the rock5 Q. formation in a given instance. The nature of cracks,6 the nature of fractures and the structure that it7 comprises in order to determine inclination, doesn't it?8 Sorry, inclination is actually measured. We're9 A. talking about friction coefficient.10 Friction coefficient, sorry.11 Q. One is easy to determine the other is not.12 A. Now, you don't have any data about -- you just13 Q. said you have no independent information about one14 aspect of this, namely the friction coefficient, isn't15 that correct?16 Correct, but it's consistent with published data.17 A. Did you see any data that they referred to or18 Q. relied on in reaching this coefficient?19 It was their recommendation as professional20 A. engineers.21 And my -- other than their recommendation, which22 Q. is obviously potentially self interested since they23 represent a client seeking to introduce this project,24 did you see any information to validate that25 86 recommendation?1 Only based on my familiarity with design manuals2 A. that that's a representative friction angle for rock on3 rock contact.4 But there are instances when there are other5 Q. coefficients that will arise, aren't there?6 There are instances, yes. It was -- but they7 A. looked at the drawings and they said we are applying a8 representative value of 35 degrees and that's within the9 handbook values that are referenced.10 They looked at the joints from the surface,11 Q. correct?12 They looked at -- yes. They didn't bore into the13 A. -- well, they did bore into the rock, but.14 Let me ask you, other than their recommendation,15 Q. do you have any information on which you can16 independently evaluate their conclusion of this17 coefficient?18 It's consistent with design manual19 A. recommendations in design. That's the way we work.20 But you have no information as to their21 Q. measurements, their data, their -- any photographs or22 anything else in which they relied to reach this23 conclusion, do you?24 Do I know where -- what, they did not cite a25 A. 87 reference.1 And they did not cite any data, photographs,2 Q. measurements or anything

se in which they relied to reach this23 conclusion, do you?24 Do I know where -- what, they did not cite a25 A. 87 reference.1 And they did not cite any data, photographs,2 Q. measurements or anything else from their inspection, did3 they?4 Only that they said that they had excavated5 A. alongside the outcrops, they did test pits, which they6 logged, and they described what they saw in the logs and7 this was their opinion as experienced engineers. I8 believe Mr. Seel is a geologist.9 Don't you think that if there was a dispute about10 Q. the structural integrity of the site to the point where11 the board wanted it's so called independent evaluation,12 there should be independent tests?13 Our main scope --14 A. I didn't ask you whether you should have done it,15 Q. I'm just asking --16 Well, it sounded like you were asking me.17 A. No, I didn't.18 Q. That's why I answered that.19 A. I didn't ask you whether you should have done it.20 Q. I know you what your scope was, you said that. I'm21 asking you as an engineer retained to do an independent22 evaluation, don't you feel where you have two sets of23 engineers who differ on major issues concerning the24 safety of this project on this ridge, that independent25 88 evaluation and testing should have been done to decide1 on these issues, such as the coefficient?2 No, I don't think the outcrops are significant3 A. enough to justify that.4 You're not a geologist, are you?5 Q. No. Geotechnical engineer.6 A. Do you have any photographs of the outcrops?7 Q. They're included in the Langan reports.8 A. I don't see any analysis in your report about the9 Q. outcrops, I don't see that here?10 Well, we mentioned what the joints, we mentioned11 A. that it was, we looked at it and we looked at their12 description and it seemed consistent.13 Consistent with?14 Q. Well, we looked at, you know, the pieces that15 A. were exposed and it looked consistent with what they16 were describing.17 And are you saying that those conditions will be18 Q. consistent throughout this rock structure?19 Of course. As we already discussed, I can't see20 A. what's buried.21 And so other than the tests they have done, you22 Q. have no knowledge as to the remainder of the structure23 in terms of safety, do you?24 The engineers made assessments that are in the25 A.