9 19 24 West Orange BOA ZB 24 06 PSEG Condensed

cbd6abed-8cda-4dba-9ebd-560688bcfcb2 14 (Pages 53 to 56) Page 53 1 your practice to not visit the site that you're going 2 to render expert testimony about? 3 THE WITNESS: It is. Like I said, members 4 of my team have been out to the site. So I've been 5 responsible for the plan, overseeing the plan, and 6 responsible for it moving forward as well. 7 MS. BENNETT: Have you seen photographs of 8 the site? 9 THE WITNESS: Yes. 10 MS. BENNETT: And specifically the trees in 11 question? 12 THE WITNESS: Yes, I reviewed those. 13 MS. BENNETT: So your estimates of age of 14 trees is related to photographs and conferring with -- 15 THE WITNESS: And reports. 16 MS. BENNETT: -- conferring with members of 17 your team? 18 THE WITNESS: Correct. 19 MS. BENNETT: Okay. Thank you. In your 20 opinion would you benefit from -- in your opinion would 21 you benefit from an actual review of the site yourself? 22 THE WITNESS: I don't believe it is 23 necessary. Like I said, team members have been out 24 there. I actually have confirmation they've been out 25 there three times in three different season. Again, Page 55 1 that you could design the landscape in a way to 2 preserve trees? 3 THE WITNESS: I wouldn't say it was a 4 heightened requirement; it is a requirement. And as I 5 mentioned, this site in particular we have a number of 6 requirements. We have Federal authorities that have 7 jurisdiction over the site. Federal, state authorities 8 that have jurisdiction over the site, as well as the 9 municipal jurisdiction in the form of the ordinance 10 which we are meeting. 11 And preserving trees is absolutely a part 12 of that, so are the needs of the project itself. So 13 it's trying to find a balance as best as possible and 14 meet the requirements of the town. 15 MS. BENNETT: Understood. Did you confer 16 with the PSE&G Forester? 17 THE WITNESS: Their vegetation management 18 team, they do have foresters -- not foresters but 19 actually arborists on their staff. 20 MS. BENNETT: They also have a forester, 21 correct? 22 THE WITNESS: Forester/Arborist. I don't 23 know that forester is the actual designation, but I 24 know they're arborists. 25 MS. BENNETT: Okay. Only because I've had Page 54 1 based on their input, their reports, and the 2 photographs I have a very good handle, I believe, on 3 the site. 4 MS. BENNETT: Thank you. So I'm not 5 familiar with your area of expertise

ad Page 54 1 based on their input, their reports, and the 2 photographs I have a very good handle, I believe, on 3 the site. 4 MS. BENNETT: Thank you. So I'm not 5 familiar with your area of expertise so I apologize if 6 my questions are not as well stated but -- so a 7 landscape architect, are you responsible personally for 8 the design of the plan of the landscaping at this 9 location? 10 THE WITNESS: Yes. The proposed plan and 11 really specifically in providing a plan that is in 12 conformance with the Township Ordinance, which we have 13 done here. 14 MS. BENNETT: Is it -- does your profession 15 also require you to exceed what an ordinance requires 16 if it's a safer plan or a better plan based on what 17 your profession requires? 18 THE WITNESS: Well, we're always beholden 19 to -- as a licensed professional beholden to provide a 20 safe plan without a doubt. And also specifically meet 21 the requirements of the ordinance. 22 MS. BENNETT: But just a slightly different 23 question, and I'll ask it directly related to this 24 plan. So in your profession does your profession have 25 a heightened requirement to preserve trees in the event Page 56 1 the recent opportunity to meet the PSE&G Forester I 2 know they have a Forester, and I'm surprised that the 3 Forester hasn't -- 4 MS. PARLAVECCHIO: Mr. Chairperson, I'm 5 unclear what the relevance is. Mr. Futey's indicated 6 multiple times that he may have had discussions with 7 the vegetation management at PSE&G. Whether or not he 8 had a specific discussion with what Ms. Bennett refers 9 to as the PSE&G Forester I'm not sure how that has any 10 relevance to this discussion. 11 CHAIRMAN NEUER: It is relevant and I'll 12 allow it. Please continue. 13 MS. BENNETT: Thank you, Mr. Neuer. So in 14 the -- again, I apologize. I'm probably going to 15 inartfully state this, but in the hierarchy of 16 vegetation or tree specialists, is an arborist more 17 expert than a forester? 18 THE WITNESS: I don't know that I can pass 19 judgment on the rankings between them. 20 MS. BENNETT: Okay. So in the event -- so 21 would you confer with an arborist or a forester about 22 the age of a tree? 23 THE WITNESS: Really either. 24 MS. BENNETT: Would there ever be a time 25 where you'd prefer a forester to confer with over an