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

65b96228-b9ab-4f72-9291-fa4a14ff04c8 11 (Pages 41 to 44) Page 41 1 possibly move some of the -- some of the impacts to 2 save some of these trees? 3 A. Well, one of the ways is by -- when we 4 know the lesser desirable trees, the invasive trees 5 that are on this site. 6 And if you target your development in 7 those areas and avoid the larger specimen trees, 8 that's the best way. 9 And maybe, maybe you have to sacrifice 10 one or two of them, but not all of them, you know. 11 So that's basically, you know, you try 12 to make decisions based upon saving the maximum 13 number of trees to the greatest extent possible. 14 Q. So when you look under ordinance 15 section 25-27.7(c), subsection 1C -- 1B, it says: 16 "To the greatest extent possible, 17 specimen trees and other large trees that 18 would be," with a paren, "ten-inch DBH and 19 greater, shall be preserved." 20 Do you believe that the plan achieves 21 that requirement? 22 A. Not to the greatest extent possible. I 23 mean, they are saving some -- some large trees, but 24 they're not -- the largest and most desirable trees 25 on the site are proposed for removal. Page 43 1 yard? 2 A. I have not. 3 Q. Okay. In connection with your review 4 this evening, you mentioned that you reviewed, I 5 believe, TR-01, 02 and 03? 6 A. Could you repeat that? 7 Q. Sure. 8 In connection with your testimony this 9 evening, what plans did you review? I believe you 10 mentioned TR-1, -2, and -3. 11 A. Okay. That's -- those are the only 12 ones I've seen, TR-01, 02 and 03. 13 Q. Did you review -- so you did not review 14 the site plans that were submitted in connection with 15 the project? 16 A. I did not have an opportunity to see 17 them. They were not provided for me. 18 Q. Okay. And did you review any existing 19 condition plans showing the existing and current 20 layout of the site? 21 A. Only from my own personal observations 22 from driving past the facility on a weekly basis. 23 Q. Are you aware of any existing site 24 constraints in terms of underground electrical 25 equipment that may limit the placement of electrical Page 42 1 Q. Okay. 2 MR. TURTELTAUB: At this time I have 3 nothing further for Mr. Linson. 4 CHAIRMAN NEUER: Let me turn to 5 Ms. Porter for cross-examination. 6 MS. PORTER: Yes. 7 Thank you, Mr. Chairman. 8 CROSS-EXAMINATION 9 BY MS. PORTER: 10 Q. Now, Mr. Linson, you indicated that you 11 were the

N NEUER: Let me turn to 5 Ms. Porter for cross-examination. 6 MS. PORTER: Yes. 7 Thank you, Mr. Chairman. 8 CROSS-EXAMINATION 9 BY MS. PORTER: 10 Q. Now, Mr. Linson, you indicated that you 11 were the former forester for West Orange, and that 12 concluded in 2021? 13 A. Yes. That's -- to the best of my 14 recollection, that's about it, yeah. 15 Q. And you also had indicated that you 16 were not involved in the drafting of or the 17 implementation of anything relating to the new tree 18 ordinance that is currently in effect? 19 A. That's true. 20 Q. Have you walked the site in connection 21 with your analysis and testimony this evening? 22 A. I have not walked the site. 23 Q. Okay. Have you ever -- 24 A. I'd be happy to do so. 25 Q. Have you ever been inside the station Page 44 1 equipment on the site? 2 A. I have no knowledge of that at all. 3 Q. Okay. And you had previously mentioned 4 before that in your expertise, you believe that the 5 current tree ordinance is one of the strictest that 6 you've seen. Is that correct? 7 A. That's correct. 8 Q. And are you aware of the reports that 9 were issued by the Township forester, Mr. Kipp, in 10 connection with PSE&G's application? 11 A. I am only aware of his report to the 12 extent that he reported that it fulfills the 13 requirement of the ordinance, which is bean counting. 14 You know, if you take down a 30-inch diameter tree, 15 you're replacing it with seven or eight trees, 16 whatever. 17 So from an -- adding up the total, I'm 18 aware that it fulfills the ordinance from that 19 extent, but not from the intent of protecting 20 existing specimen trees. 21 Q. Are you aware that Mr. Kipp indicated 22 that he reviewed and found everything consistent with 23 the tree ordinance? 24 A. I haven't seen his -- seen his report, 25 so I can't really comment on it.