December 3, 2025 Regular Meeting - WEHI Transcript

11 of 17 sheets Page 41 to 44 of 68 01/05/2026 02:58:16 PM 41 That's all. We're not building a highway.1 Q. Now, it also says on Page 11, "We were not able2 to obtain additional background information on the basis3 of the classification in time for this review." What4 does that mean?5 The map, referring to the landslide mapping for6 A. Essex County, New Jersey prepared for the New Jersey7 Geological Survey, it's referenced in the Langan report,8 and the report show -- identify a Class 3, I think,9 level of concern. And that's all included in the Langan10 report. And so the, it just, the map just states that,11 but they're not describing why they made that12 classification or what the mechanism of a landslide13 would be in that particular area. You can not find the14 basis for their findings.15 And what does Class 3 refer to?16 Q. It's a Hazus classification, it's a government17 A. agency that investigates certain types of hazards,18 including landslides.19 I mean, what does Class 3 mean?20 Q. It's moderate or -- it's a moderate risk.21 A. Moderate risk of what?22 Q. Landslide.23 A. So Building D is going to be placed just above a24 Q. slope with a moderate risk of a landslide, is that fair25 42 to say?1 Well, there was an investigation done that2 A. indicated that the stability, when it's completed, we3 have a couple others that we asked for that done a more4 thorough investigation, that was done for people who5 made the classification, and so far it hasn't indicated6 instability exists on the slope.7 Yes, but Class 3 was indicated by the agency?8 Q. Right. But they don't do the -- did not do test9 A. borings and stability analyses and that sort of thing,10 as far as we know.11 Then why do you mention as a relevant factor that12 Q. you couldn't get information on the basis of the13 classification if it doesn't matter? Why even bother14 mentioning it.15 Because it needs -- they need it to provide an16 A. explanation in my opinion, otherwise it's misleading.17 Usually the maps have a text on them and this has no18 legend or text or anything on the map.19 Thank you.20 Q. In the last sentence of that paragraph you say,21 "The analyses performed by both Langan and Princeton22 Hydro do not, in our opinion, indicate instability under23 the assumed conditions." What do you mean by, assumed24 conditions, or what are they?25 43 Well, they're the conditions that are

Princeton22 Hydro do not, in our opinion, indicate instability under23 the assumed conditions." What do you mean by, assumed24 conditions, or what are they?25 43 Well, they're the conditions that are shown on1 A. the cross sections and in the project files that are2 done based on the exploration.3 So you're referring to data that was provided by4 Q. Langan?5 Right.6 A. Thank you.7 Q. At Page 12 you say that, "The overburden soils8 were reported to have been classified visually. There9 were no index testing results, such as moisture content10 and grain size tests, included in the report. Two11 unconfirmed compression tests were performed of the12 Basalt bedrock." Now, when you say, the overburden13 soils report to have been classified visually, who did14 that report of the visual classification?15 Langan.16 A. Langan.17 Q. And you said, there's no testing result such18 moisture content and grain size tests. What does that19 refer to?20 That refers to, you take a sive and you, a series21 A. of sive's and you shake the sand through the sive and22 you break it down into different sizes of grains.23 And what's the relevance of finding that24 Q. information out?25 44 It, it provides additional criteria to come up1 A. with soil strength parameters, permeability, a whole2 bunch of engineering properties.3 Are those important?4 Q. Right. There were investigations done by Shore5 A. Engineering for the applicant as well and they did do6 the index testing.7 Thank you.8 Q. At Page 13 you refer to the fact that Princeton9 Hydro reviewed inferred stratigraphy and that Langan did10 a general stratigraphy. Can you explain what those two11 terms mean? Inferred and general stratigraphy.12 That may be a poor choice of words, but inferred13 A. means you do borings 100 feet apart and then you, and14 then basically the practice is to interpolate them15 between the two points that, you know, where the strata16 are and you have to infer that the conditions between17 follow that general trend. They don't necessarily do18 that, but you won't know until you excavate.19 And what about what does general stratigraphy20 Q. mean? You used both terms.21 I know, maybe I should have used inferred twice.22 A. General could be inferred.23 Well, what did you mean by general, because you24 Q. used two different words?25