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

65b96228-b9ab-4f72-9291-fa4a14ff04c8 12 (Pages 45 to 48) Page 45 1 Q. Okay. 2 A. I -- I do acknowledge him as an expert 3 in the field and we have spoken on other matters, but 4 not this one. 5 Q. Thank you. 6 That was actually my next question, 7 whether you had had any conversations with him about 8 this application or about his findings in connection 9 with it? 10 A. No. We've -- we've discussed the 11 ordinance as it pertains to some other situations, 12 because the -- I have assisted some of these licensed 13 tree care operators in fulfilling the requirement of 14 an application because it -- they need a licensed 15 tree expert to sign off that the tree is actually 16 dead or that it's not dead and, you know, what are 17 the implications of removing it, if we're removing a 18 tree that's not dead. 19 So that's why I am familiar with the 20 ordinance. I guess I have been -- I have assisted 21 several local tree companies in filling out the -- 22 the land fee application, the tree removal 23 application. 24 Q. Thank you. 25 And are you aware of or have you worked Page 47 1 practice every day. 2 Q. Specific to -- 3 A. I'm an arborist -- 4 Q. -- utilities? 5 A. I'm an arborist. I'm a forester. I'm 6 a certified tree expert. 7 Q. No, I understand that. 8 And you have specific experience in 9 that capacity in dealing with substations? 10 A. I can't say that. 11 I -- I -- around electricity, yes. I 12 work with trees around electricity all the time. 13 But substations, you know, I -- I -- 14 I've -- I've worked with Jersey Central Power & 15 Light. I've used -- worked with Public Service. 16 I've worked with Butler Electric. I've worked with 17 -- what's the one way up there in, like, West 18 Milford? It's -- it's, like, a New York one. 19 But I've worked with a lot of different 20 utilities over the years. 21 Q. Are you aware of how many existing 22 trees there are on-site that are being preserved? 23 A. Yeah, I have -- they're listed on TR-2 24 and -3, yes. 25 And I'm wondering why you're preserving Page 46 1 with Mr. Farr, who is the prior tree forester to the 2 current tree forester? 3 A. His tenure with the town did overlap 4 with my -- with my tenure with the town. 5 He was -- he was retained after me, 6 but, yeah, I've -- I've known Ron for many years. 7 Q. Are you familiar with Mr. Farr's prior 8 determination requiring the removal of multiple trees 9

he town. 5 He was -- he was retained after me, 6 but, yeah, I've -- I've known Ron for many years. 7 Q. Are you familiar with Mr. Farr's prior 8 determination requiring the removal of multiple trees 9 on site due to their deteriorating condition, as well 10 as due to branches falling that may cause a hazard? 11 A. I haven't seen anything from Mr. Farr 12 on that site -- in regard to the site, but, you know, 13 I -- I know for a fact the trees have not been 14 maintained as -- as they should -- the industry 15 standards of --of pruning trees once every ten years. 16 I know that there's been dead ash trees 17 on the site across from the gas station that have 18 been removed, but I don't have any knowledge of 19 Mr. Farr's presence on the -- on this site at all. 20 Q. Do you have any specific experience 21 with utility arboriculture? 22 A. Do I have experience with arbor 23 horticulture? 24 Q. Utility arboriculture, correct. 25 A. That's -- that's pretty much what I Page 48 1 any of the Tree of Heaven. You're preserving eight 2 Tree of Heaven, which, you know, I'm sure the town 3 would be delighted if you removed them. 4 And for some reason, you're -- you're 5 -- you're preserving a couple of ash trees. And I am 6 wondering, the ash trees that you're preserving, are 7 you treating them to prevent emerald ash borer from 8 -- from their demise? Or why aren't you removing 9 them now? 10 Q. In terms of the ordinance, with respect 11 to the new ordinance, how many specific trees are 12 required? 13 A. Well, that would -- 14 MR. TURTELTAUB: Can you just clarify, 15 when you say "required," required to be removed or 16 required to be -- 17 MS. PORTER: Required to be replaced. 18 MR. TURTELTAUB: Okay. Thank you. 19 THE WITNESS: I haven't -- I haven't 20 done that analysis, but I'm sure that -- that 21 Mr. Kipp has. And I would trust his -- his judgment 22 in making that determination. 23 BY MS. PORTER: 24 Q. Okay. Are you aware or have you been 25 made aware that the Applicant is not legally subject