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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 25 (Pages 97 to 100) Page 97 1 It's either dead, diseased or dying, and then 2 actually considered a dead tree, or it's alive and 3 healthy or semi healthy tree. 4 So there's very little controversy when 5 someone wants to remove a dead or diseased tree. The 6 -- the test comes in when the tree still has life to 7 it, it still has some greenery to it. 8 Can it be treated? Can it be brought 9 back to health? Is there a defect, even though it's 10 alive, that makes it a hazard to the public. 11 So there's -- the -- going through the 12 application process in West Orange, it makes everyone 13 thoroughly consider whether removing the tree is a 14 good idea or not, and if it's a healthy tree that you 15 want to remove to change your landscaping, put in a 16 pool or a tennis court or a sauna or whatever, if 17 you're removing a healthy tree, there are 18 consequences. You're going to have to replace it. 19 And if you can't replace it on your 20 property, you're going to be contributing to a fund 21 which the town will use at its discretion to plant 22 trees elsewhere on public property or public 23 right-of-way. 24 Q. In terms of getting to the point in 25 achieving the minimal destruction of trees, in your Page 99 1 could save this tree or more than one tree. If there 2 are options. 3 If there are no options, then it's 4 necessary to remove the healthy tree. 5 But I am not -- as a tree expert, I am 6 not in a position to say what -- what the options and 7 the configuration of this substation should be. 8 That's for the electrical engineers. And if -- if 9 they have considered as many options as possible and 10 they still come to the same conclusions, then there 11 are no other options. 12 But all I can say is you've got some 13 very nice healthy specimen trees that are there that, 14 wouldn't it be great if we could find a way to work 15 around them. 16 BY MR. TURTELTAUB: 17 Q. You talk about, in the testimony and 18 the ordinance it has, quote, replacement trees. 19 When you plant trees to replace -- as 20 set forth in the ordinance, to replace a large tree 21 that's now being taken down and plant replacement 22 trees, do those trees actually replace what is there 23 today or do those trees do something else? 24 A. That's the -- the intent is that they 25 will replace it. Page 98 1 experience, you look at design alternatives

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trees actually replace what is there 23 today or do those trees do something else? 24 A. That's the -- the intent is that they 25 will replace it. Page 98 1 experience, you look at design alternatives to 2 achieve that goal before you go to the point and say, 3 well, now the tree has to come down or you're allowed 4 to take the tree to come down? 5 A. Well -- 6 CHAIRMAN NEUER: Mr. Turteltaub, he's 7 already testified that he didn't look at the plans. 8 MR. TURTELTAUB: No, I am just saying 9 is the general proposition with the ordinance. 10 I understand what you're saying. We do 11 have two other witnesses who will be testifying, but 12 I'm just getting the generalities out. He was asked 13 some of these questions and I just want to be clear 14 about whether -- whether there should be considered 15 alternatives to a plan as part of the site plan 16 review and/or the site plan development. 17 And that's what I am looking to elicit 18 from him, from his testimony, is his opinion as to 19 whether you should look at alternative plans before 20 you settle on taking down a tree. 21 CHAIRMAN NEUER: He's answered it 22 already, but I'll let it go ahead. 23 Please answer the question, Mr. Linson. 24 THE WITNESS: The thought process 25 should be if -- if I can do this instead of that, I Page 100 1 But, you know, even these -- these 2 large trees, they all started out as a sapling, and 3 -- but over time they -- they got to be the size 4 where, you know, they -- they have a huge canopy 5 coverage and contribution. 6 And the -- the idea of planting 7 multiple replacements is to try to get back to what 8 we were before we -- we removed this tree and when we 9 lost that canopy coverage. 10 But, you know, eventually you have to 11 think that if you take down one tree and you replace 12 it with eight trees, at some point in time those 13 eight trees are going to be too close together, we 14 might have to remove a couple of them so that the 15 other trees can thrive. 16 So it's a -- there's always some 17 maintenance. You know, we're trying to manipulate 18 Mother Nature. We have some pretty nice trees now. 19 We don't want to lose our canopy coverage. We don't 20 want to lose the benefits that these tree are 21 providing. 22 But there is a lapse in recovery. And 23 no matter how many small trees we plant, they're not 24 going to immediately provide the same benefit that 25

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the benefits that these tree are 21 providing. 22 But there is a lapse in recovery. And 23 no matter how many small trees we plant, they're not 24 going to immediately provide the same benefit that 25 one large tree is providing at the present time.

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