12 12 24 PSEG West Orange BOA ZB 24 06 PSEG 35 Mt Pleasant Ave Condensed

65b96228-b9ab-4f72-9291-fa4a14ff04c8 10 (Pages 37 to 40) Page 37 1 facilities. There's like one, two, three or four of 2 them. There's a linear fashion. 3 The largest tree on the property is a 4 58-inch diameter London plane, perfect shape. You 5 can see it from Prospect Avenue. You look down there 6 and it's a majestic tree, tree number 4203. It's a 7 crime to take that tree down, in my mind. 8 So we have 4203, the largest tree on 9 the site, 58-inch diameter London plane. We have a 10 44-inch diameter London plane. These are, you know, 11 the width of a sheet of plywood. These are that 12 wide. The trees are that wide, tree 4204. 13 Tree 4210, a 36-inch diameter London 14 plane. 15 And then tree 4226, 36-inch diameter 16 horse chestnut. Beautiful tree. 17 Tree 4230, 35-inch diameter horse 18 chestnut. 19 Tree 4235, a 32-inch horse chestnut. 20 Tree 4243, 29-inch London plane. I 21 don't know the -- 22 I'm not an engineer. All I know is if 23 you move that, I believe it's water detention basins 24 or water retention facility, if you move that closer 25 to Prospect Avenue you could avoid all these trees. Page 39 1 ground saturation of water and air, the air 2 filtration through photosynthesis. 3 So that's pretty much where I am coming 4 from. 5 Q. And to preserve trees, you know, one of 6 the -- sometimes the issue of tree roots and the 7 destruction of tree roots therefore could destroy a 8 tree. 9 How far do you have to go, if you know, 10 to protect a tree root if you're going to be doing 11 construction, and where would usually the delineation 12 be here? 13 A. Well, the most accepted standard is to 14 protect the trees within the drip line of the tree. 15 So in other words, the furthest 16 reach -- outreach of the branches covers the majority 17 of a tree's root system. 18 And it's the fibrous roots at the very 19 end that -- that are soaking up the water and the 20 nutrients from the soil. 21 It's, you know, close to the trunks of 22 the trees, within 12 to 15 feet, those are buttress 23 roots that are primarily for the support of the tree 24 under storm conditions. 25 But it's the fibrous routes that go out Page 38 1 So, you know, in my mind it's like what 2 were you thinking? You like targeted the biggest 3 trees on the site to be removed. 4 So to me, this really -- there has to 5 be another way than to remove these 100-year old 6 trees. 7 And, I

what 2 were you thinking? You like targeted the biggest 3 trees on the site to be removed. 4 So to me, this really -- there has to 5 be another way than to remove these 100-year old 6 trees. 7 And, I mean, other towns, you know, 8 they have landmark trees that are smaller than this. 9 These are really significant trees. So I'm a little 10 excited about it. 11 Q. Would the mere replacement of these 12 trees once they're removed, in your opinion, satisfy 13 the goals of the ordinance of tree preservation? 14 A. That's the thing, that the -- the 15 ordinance, you know, and rightfully so, it tries to 16 compensate for the loss of healthy trees. 17 But, you know, the best deterrent is 18 well don't -- if it's a healthy -- a large, healthy 19 tree, nothing wrong with it, don't take it down in 20 the first place. 21 Because you're not going to have the 22 screening, the height screening of the facility that 23 you presently have. 24 And, you know, it's going to take years 25 for these replacement trees to begin to fulfill the Page 40 1 to the tips of the branches -- and, you know, the 2 roots do exceed that. 3 But that -- the drip line of the tree 4 pretty much defines the protected root zone. We 5 really don't want to be removing roots within that 6 area. 7 If you have to remove some of them, you 8 sort of monitor what percentage of roots are -- if 9 it's a -- if it's, let's say, 10 percent of the roots 10 on the tree, the tree will recover from that. 11 But as you get -- doing the trenching 12 or anything closer to the trunk of the tree, then 13 you're affecting the stability of the tree and then 14 the safety of the public or the surrounding 15 structures. 16 Q. And the drip line being the edge of -- 17 the maximum edges of the tree branches. Is that 18 correct? 19 A. Right. 20 It's, you know, it's a radius around 21 the entire tree. 22 Q. Okay. And in looking at the plan 23 itself, did you see opportunities to possibly -- and 24 we'll get into engineering testimony, but just from 25 your perspective and your experiences, ways to