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

65b96228-b9ab-4f72-9291-fa4a14ff04c8 27 (Pages 105 to 108) Page 105 1 warrants removal, I trust his judgment a 2 hundred percent. 3 I seriously doubt we would have any 4 professional differences in the assessment of a tree. 5 Q. Thank you. 6 Are you aware that the plans that you 7 reviewed, the TR-01, -2 and -3, do you distinguish 8 between viable and non-viable trees being removed, 9 specifically on TR-02? 10 A. You know, basically the unfortunate 11 thing about that report is it doesn't have a column 12 indicating the condition of the tree. 13 So, you know, in looking at it, I have 14 to presume that they were healthy trees if they're 15 not being removed. 16 And, you know, I did -- my emphasis in 17 reviewing, you know, TR-1, -2, and -3 was to look for 18 the largest trees that were existent since the -- the 19 initial planting and development of the site and to 20 try to preserve those. And, you know, I -- I 21 acknowledged a lot of the other trees that were 22 volunteers that were self-planted on the site. 23 But my emphasis was to try to preserve 24 as many trees as possible, but certainly the original 25 planted trees, the -- the Colorado blue spruce, the Page 107 1 -- on the east side of the property were moved closer 2 to the -- to the Prospect Avenue property line, if it 3 were possible to do that, it appears to me we could 4 preserve some trees. 5 So all -- I am asking the question, but 6 I don't have the answer whether all of those possible 7 options, you know, in altering the plans are possible 8 or not. 9 But that's something for the board to 10 consider after hearing the testimony of the other 11 experts. 12 Q. Thank you. 13 Are you aware that additional review of 14 the potential for tree preservation was done after 15 the initial report was received from the township 16 forester and that 17 trees were identified that 17 allowed for them to also be saved, based on the 18 voluntary consideration? 19 A. Well, I'm -- that's news to me and I'm 20 glad to hear it. 21 But the only -- the only reference that 22 I had was TR-01, -02 and -03, and what I could see 23 from the street. 24 Q. And than lastly, you did speak of how 25 the ordinance works in terms of the replacement trees Page 106 1 Norway spruce, the willow oaks, the Little Leaf 2 Lindens, the London planes, the Doug fir, the horse 3 chestnut. 4 Those were the ones that I specifically 5

terms of the replacement trees Page 106 1 Norway spruce, the willow oaks, the Little Leaf 2 Lindens, the London planes, the Doug fir, the horse 3 chestnut. 4 Those were the ones that I specifically 5 noted on my plan and highlighted them and 6 cross-referenced whether they were being preserved or 7 proposed for removal. 8 So, again, I was -- you know, the 9 smaller trees can be replaced, but the larger trees, 10 you know, they provide a benefit, a visual screening 11 of the site that cannot be replaced any time soon. 12 Q. Thank you. 13 Are you aware of any language in the 14 ordinance that mandates that alternatives be 15 considered when -- with respect to designing a site? 16 A. It's kind of subjective in terms of, 17 you know, the purpose and intent of it is to try to 18 preserve trees. So you would hope that all of the -- 19 all of the options to preserve a tree would be 20 exhausted before it becomes evident that the tree has 21 to be removed. 22 So I'm just not aware that all of the 23 options have been considered. 24 And, again, I just -- if the driveway 25 was slightly configured, if the improvements on the Page 108 1 and the intent that, you know, should a tree be 2 removed, that it will be replaced, and that there is 3 the ability for multiple replacements replace one 4 existing tree, depending upon the nature, size, type, 5 et cetera. 6 Are you aware of the fact that PSE&G is 7 proposing an additional 317 trees to the 338 trees 8 on-site for a total of over 700 trees that will exist 9 on the property as part of this proposed development? 10 A. That's news to me. 11 I haven't seen a replacement plan or 12 anything like that. 13 As I say, the only thing I have seen is 14 TR-01, -02 and -03. 15 MS. PORTER: Thank you. 16 I have no further questions. 17 THE WITNESS: Okay. 18 CHAIRMAN NEUER: Thank you, Mr. Linson. 19 THE WITNESS: Okay. 20 CHAIRMAN NEUER: It was good seeing you 21 again. 22 Mr. Turteltaub, who's your next 23 witness? 24 You know we stop at 11. 25 MR. TURTELTAUB: Yes, we'll hopefully