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Supporting Documentation · Jan 16, 2025

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

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65b96228-b9ab-4f72-9291-fa4a14ff04c8 15 (Pages 57 to 60) Page 57 1 VICE CHAIRMAN SCHWARZBAUM: Okay. So 2 is there a reason why you didn't look at the 3 construction plans of where the substation is? 4 THE WITNESS: Well, basically I was -- 5 my -- I was engaged only to interact about the trees 6 themselves. I was not shown the replacement 7 landscape plan or any of the -- the soils or -- or 8 even the -- topography map. I didn't see any of 9 that, I just saw TR-01, 02, 03. 10 VICE CHAIRMAN SCHWARZBAUM: Okay. So I 11 guess where -- what I am asking is, you're opining 12 based upon just one item as opposed to looking at the 13 overall project. 14 Is that correct? 15 THE WITNESS: That's exactly right. 16 So, you know, I'm looking at these as 17 specimen trees, and I'm looking at the purpose of the 18 ordinance is to preserve them to the greatest extent 19 possible. And I'm introducing the possibility that 20 maybe -- maybe not all of these trees have been 21 looked at individually as possible candidates for 22 preservation with altering the facility. 23 I would only -- only, you know, an 24 engineer designing the facility can say what the 25 possibilities may be. I just say that there is room Page 59 1 VICE CHAIRMAN SCHWARZBAUM: Okay. 2 That's it. 3 I just have -- I am a having a hard 4 time connecting the dots. 5 That's all I have to say. 6 CHAIRMAN NEUER: Thank you, 7 Mr. Schwarzbaum. 8 Mr. Barbee, you're up next. 9 MR. BARBEE: Initially I did have a 10 question, but Irv did touch on it because of the lack 11 of -- well, no. 12 I have no question. I'll leave it 13 there. 14 CHAIRMAN NEUER: Thank you, Mr. Barbee. 15 Mr. Eben, questions for this witness 16 based on his testimony? 17 MR. EBEN: Thank you, Mr. Chairman. 18 Mr. Linson, in accordance with this 19 last testimony that you were doing answering 20 questioning from -- 21 THE WITNESS: Could you repeat that 22 because I'm a little hard of hearing and if somebody 23 could express that a little louder. 24 Was that a question? 25 MR. EBEN: Hold on, I'm just trying to Page 58 1 closer to Prospect Avenue to run these -- it looks 2 like -- I am speculating that it's -- that it's a 3 water detention facilities, but it seems to me that 4 if they remove closer to Prospect Avenue, should be 5 able to save a number of these trees. 6 VICE CHAIRMAN SCHWARZBAUM: Is that 7 what -- I don't know since I haven't read a

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but it seems to me that 4 if they remove closer to Prospect Avenue, should be 5 able to save a number of these trees. 6 VICE CHAIRMAN SCHWARZBAUM: Is that 7 what -- I don't know since I haven't read a report, 8 is that what that -- this -- the -- who's the 9 engineer? Mr. Blanton is going to -- Ms. Blanton is 10 going to testify? 11 MR. TURTELTAUB: Yes, we'll get into 12 some of that testimony. 13 VICE CHAIRMAN SCHWARZBAUM: I guess 14 I'm -- I'm just asking that, while I respect you as 15 an expert, I'm having a difficult time looking at 16 accepting expert testimony without looking at the 17 overall project. 18 And, you know, as you testified, there 19 are circumstances when you can remove trees. 20 Is that correct? 21 THE WITNESS: That's correct. 22 VICE CHAIRMAN SCHWARZBAUM: And there 23 -- you also testified that we have one of the 24 strictest tree replacement ordinances in the state. 25 THE WITNESS: That's true. Page 60 1 get my thoughts together. 2 You testified -- you testified that 3 tree maintenance is basically every ten years. 4 THE WITNESS: Yes. 5 MR. EBEN: That means whoever owns the 6 property has to come in on the property and direct a 7 contractor what to do. 8 And we -- we don't know or maybe you do 9 know, did PSE&G do that through the course of 10 100 years of owning the property. 11 THE WITNESS: It's -- it's generally 12 accepted that most trees need some form of 13 maintenance at least once every ten years and some 14 trees more frequently than that, particularly some of 15 these older pin oak trees, when a branch dies it's 16 eight inches in diameter and 40-feet long and it's 17 hanging over the street. You know, you can't wait 18 ten years to prune it, you got to get it before it 19 falls and causes damage. 20 So, but, you know, these trees, they're 21 -- there's been a low level of maintenance on this 22 site, and that's why there's been so many invasive 23 species, involuntary species that have popped up over 24 -- over the years, simply because they -- they 25 weren't -- you know, they didn't mow the areas or

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