January 14, 2026, Planning Board Special Meeting - WEHI Transcript

5 of 53 sheets Page 17 to 20 of 122 02/03/2026 04:49:05 PM 17 start doing research through the literature to develop1 that.2 I assumed that. Thank you.3 Q. Now, in addition he refers at a later e-mail to a4 study by Victoria Stevens from Simon Fraser University5 in British Columbia in which she references certain root6 cohesion figures for Obra Forest v. Clearcut Forest7 recovering from clearcut. And if you look at the front8 of the document, the December 9 e-mail, and in paragraph9 1 he has a response in red italic font.10 MR. AFRAN: Now, that doesn't come out, Ms.11 McGovern, the copy you have as well but it's in a12 lighter gray italic font. So the lighter gray is the13 red that's in the original.14 Now, in that lighter gray area he refers to the15 Q. Stevens study indicating that one can use 156 pounds per16 square foot apparent root cohesion in certain17 circumstances. And he also refers to reference in the18 Miao study indicating -- I'm sorry, that's the Miao.19 Study. And then in the Stevens study he references to20 an indication that 522 pounds per square foot can be21 inferred in root cohesion in natural forests. Do you22 see those references on Page 1 of the exhibit?23 Yes, I do.24 A. Okay.25 Q. 18 Now, I assume you have not read the Stevens1 report, is that fair to say?2 That's fair to say.3 A. And the same with the Miao report?4 Q. Same.5 A. And the reason you haven't it's not your area of6 Q. expertise and you wouldn't feel qualified to comment on7 those references, is that fair to say?8 That's fair to say.9 A. Okay.10 Q. It's also true that in the December 9 e-mail, and11 this is one that I don't believe we had earlier, that's12 why I was going through the background.13 MS. McGOVERN: This December 9 on, Tuesday,14 December 9 at 4:52?15 MR. AFRAN: Yes.16 MS. McGOVERN: It's the first page of O-38.17 MR. AFRAN: Yeah, I didn't notice it but we18 looked at the whole file. We didn't have these. We19 didn't have the studies, so we didn't have the full20 record, that's why I'm going through it now.21 MS. McGOVERN: Yeah, we did.22 MR. AFRAN: I didn't see the study. We were23 not given the studies at the last meeting.24 MS. McGOVERN: Okay. Somebody gave it to25 19 me.1 MR. AFRAN: No, you got the study from Mr.2 Kleinberg.3 MS. McGOVERN: I see what you're saying.4 MR. AFRAN: We didn't have the back up for5 these exhibits, that's why we're going through it

o25 19 me.1 MR. AFRAN: No, you got the study from Mr.2 Kleinberg.3 MS. McGOVERN: I see what you're saying.4 MR. AFRAN: We didn't have the back up for5 these exhibits, that's why we're going through it now.6 I can't see that far.7 MS. McGOVERN: Slope stability, there is8 some kind of diagram.9 MR. AFRAN: There are two academic articles.10 MS. McGOVERN: Okay. I'm sorry.11 MR. AFRAN: I will clarify.12 The Stevens article and the Miao article are two,13 Q. I'll call them, academic articles --14 MS. McGOVERN: Attachment to the --15 MR. AFRAN: Yeah. We didn't have those. I16 don't know that those are peer review articles but17 they're written by academics.18 Now, in paragraph 1 of the first page of exhibit19 Q. for identification 1, it refers to natural forests20 having a presumed or inferred PSF capacity of 522. Do21 you see that reference? It's the fourth line from the22 bottom of Paragraph 1.23 Stevens et al, 2006 indicates?24 A. Yes. Right over there. He's saying that using a25 Q. 20 natural forest, that's his language, Mr. Seels, Stevens1 suggests we can infer a carrying capacity or weight2 bearing capacity, resistance capacity, of 25 KPA or 5223 FPS. Do you see that reference?4 Yes, I do.5 A. Okay.6 Q. Now, do you have any knowledge as an expert as to7 when such a PSF is inferred in terms of what type of8 forest exits on the site?9 No, I don't.10 A. So you wouldn't be able to comment on whether11 Q. he's accurately interpreting the Stevens study in that12 regard?13 That's correct.14 A. And if you read the Stevens study you wouldn't be15 Q. able to comment whether Professor Stevens is commenting16 accurately?17 I mean, if I studied it I might be able. I can't18 A. say until I did it.19 Okay.20 Q. He also says in Paragraph 1, "The site has a very21 mature older growth woodland setting." That's a quote22 from the third line bottom of the paragraph.23 Now, it seems on the basis of this he's24 suggesting that's why he's using the Stevens figure of25