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

Page 31 1 A. I'm not sure where they got all of 2 this, but about a year ago, DEP came up with a model 3 ordinance that they were requiring -- well, initially 4 requiring municipalities to adopt. 5 And then we found out it was really 6 just a model which could be improvised. 7 But it did -- the emphasis was -- on 8 the DEP ordinance was water preservation, water 9 quality. 10 And it introduced a schedule for 11 replacement of living trees, trees being a source of 12 recharging water -- water reserve. 13 So the West Orange Ordinance far 14 exceeds the minimum requirements that the State had 15 proposed. 16 Q. Okay. And before you started to talk 17 about the different tree sizes. Could you -- is 18 there an impact on the loss of a tree of different 19 sizes? Do the impacts change? 20 A. Well, the intent is to maintain the 21 tree canopy coverage in the town. 22 And, you know, basically when you're 23 losing the canopy coverage of a large, say an oak 24 tree that's 30 inches in diameter and having to 25 replace it with four or five or more trees, those

Page 32 1 trees are only going to be, you know, 10, 12-foot 2 tall. 3 And so you don't have the intense shade 4 and cooling effect that a large tree will have. 5 And, you know, a 30-year -- 30-inch 6 diameter tree could be a hundred, 150, 175 years old. 7 So you're losing screening and wind break even by -- 8 the goal of replacing trees is great, but the actual 9 fulfillment and restoration takes years for these 10 replacement trees to grow to the size of the tree 11 that was removed. 12 Q. And the replacement schedule, does it 13 alter based upon the size of the tree at all or is it 14 static schedule? 15 A. Yes. 16 In fact, I have it right in front of me 17 right now. If you're removing trees from 18 2-and-a-half to 6-inches in diameter -- 19 CHAIRMAN NEUER: Excuse me, sir. 20 From what are you reading? From what 21 are you reading? 22 THE WITNESS: I am reading from the 23 West Orange Tree Replacement Table, Table A. 24 CHAIRMAN NEUER: From the ordinance? 25 In the ordinance?

Page 33 1 THE WITNESS: That's on page 17 of the 2 ordinance. So... 3 CHAIRMAN NEUER: Thank you. 4 THE WITNESS: So a tree that's 5 2-and-a-half to 6-inches in diameter, it's a 6 one-to-one replacement. 7 As you go to 6 to 13, it's a 8 four-to-one replacement; 13 to 22, it's a six-tree 9 replacement; 23 to 32, it's an eight-tree 10 replacement. Over 33 inches, it's a ten-tree 11 replacement. 12 So it's -- it's very aggressive in 13 terms of the replacement. It's much, much more 14 stringent than the State had proposed. 15 BY MR. TURTELTAUB: 16 Q. And by going to the larger number of 17 trees to replace, does that signify anything to you 18 with respect to the value placed on larger trees 19 versus smaller trees? 20 A. Well, it's supposed to be an incentive 21 not to remove large, healthy trees. You know, so 22 that's -- because in this situation, they're removing 23 -- they're proposing to remove trees that are perhaps 24 70- to 100-foot tall, that presently shield the 25 structure from view from Mount Pleasant and Prospect

Page 34 1 Avenues. 2 Any other replacement trees are only 3 going to be 10-foot tall. And the transmission 4 station is, I don't know, maybe that -- the structure 5 is 100-foot tall. But you're -- right now the trees 6 shield the structure pretty well. 7 Q. And the loss of trees, does it have any 8 impact on the health and safety of the community and 9 the welfare of the community? 10 A. Well, certainly the trees have value 11 for wildlife purposes. And, you know, a large tree 12 is going to be filtering a lot of -- lot of air. And 13 at this intersection, you've got -- you've got 14 traffic stopped and cars idling and the trees provide 15 a filtering affect of the carbon monoxide emitted 16 from the cars. 17 Q. Now, in your review of the -- you said 18 you did review the plan that PSE&G has before the 19 board tonight. Is that correct? 20 A. Yes, I did. 21 Q. Did you come up with any thoughts or 22 comments about the -- what you reviewed? 23 A. Well, the trees on the site, and 24 looking in particular at the tables on TR-2 and -3, 25 the trees are identified by species and diameter.

Page 35 1 And as you look at the -- the species, 2 it's quite obvious that when the substation was 3 constructed, there were certain species of trees 4 which were actually planted. And that would be white 5 cedar, white pine, Colorado blue spruce, Norway 6 spruce, Rocky Mountain juniper, Willow Oak, Little 7 Leaf Linden, London plane, Douglas fir, horse 8 chestnut and serviceberry. 9 So these were trees that were 10 specifically planted, they were purchased from a 11 nursery and installed. 12 And then as time went on and the 13 maintenance of the site was not up to par, we got 14 invasive species coming in. We got box elder, black 15 cherry, black walnut, white ash, Norway maple, red 16 oak, red maple, eastern red cedar crab apple, black 17 locust, Tree of Heaven, oh boy, yellow birch, 18 American elm, white mulberry, and bitter nut hickory. 19 Those trees all were self-planted by 20 nature. And many of them are really undesirable 21 trees to have on a property, but it's indicative that 22 the maintenance of the property was really not up to 23 par. 24 Of the original trees that were 25 planted, what I did was I tried to look at trees that

Page 36 1 had significant diameters to them. 2 And I identified them on my map, 3 circling them, and also in respect to what their 4 proposed disposition was, whether they were going to 5 be preserved or they were going to be removed. 6 And what struck me was that a lot of 7 the development seems to be targeted for the largest 8 trees on the site. And as you enter the driveway off 9 Mount Pleasant, there is tree number 4078, it's a 10 42-inch diameter Little Leaf Linden scheduled for 11 removal. 12 There's a 29-inch diameter London 13 plane, tree number 4087. 14 There is a 46-inch diameter London 15 plane, tree number 4135. 16 And tree number 4102 is a 36-inch 17 diameter Linden. 18 These are significant trees. And it 19 appears to me that wouldn't that be great if we 20 reconfigured the driveway access to go around these 21 trees rather than through these trees. 22 And the same -- the same argument as 23 you -- as you're going from the south end of the site 24 up to the north end of the site along Prospect 25 Avenue, and I believe those are water detention

Page 37 1 facilities. There's like one, two, three or four of 2 them. There's a linear fashion. 3 The largest tree on the property is a 4 58-inch diameter London plane, perfect shape. You 5 can see it from Prospect Avenue. You look down there 6 and it's a majestic tree, tree number 4203. It's a 7 crime to take that tree down, in my mind. 8 So we have 4203, the largest tree on 9 the site, 58-inch diameter London plane. We have a 10 44-inch diameter London plane. These are, you know, 11 the width of a sheet of plywood. These are that 12 wide. The trees are that wide, tree 4204. 13 Tree 4210, a 36-inch diameter London 14 plane. 15 And then tree 4226, 36-inch diameter 16 horse chestnut. Beautiful tree. 17 Tree 4230, 35-inch diameter horse 18 chestnut. 19 Tree 4235, a 32-inch horse chestnut. 20 Tree 4243, 29-inch London plane. I 21 don't know the -- 22 I'm not an engineer. All I know is if 23 you move that, I believe it's water detention basins 24 or water retention facility, if you move that closer 25 to Prospect Avenue you could avoid all these trees.

Page 38 1 So, you know, in my mind it's like what 2 were you thinking? You like targeted the biggest 3 trees on the site to be removed. 4 So to me, this really -- there has to 5 be another way than to remove these 100-year old 6 trees. 7 And, I mean, other towns, you know, 8 they have landmark trees that are smaller than this. 9 These are really significant trees. So I'm a little 10 excited about it. 11 Q. Would the mere replacement of these 12 trees once they're removed, in your opinion, satisfy 13 the goals of the ordinance of tree preservation? 14 A. That's the thing, that the -- the 15 ordinance, you know, and rightfully so, it tries to 16 compensate for the loss of healthy trees. 17 But, you know, the best deterrent is 18 well don't -- if it's a healthy -- a large, healthy 19 tree, nothing wrong with it, don't take it down in 20 the first place. 21 Because you're not going to have the 22 screening, the height screening of the facility that 23 you presently have. 24 And, you know, it's going to take years 25 for these replacement trees to begin to fulfill the

Page 39 1 ground saturation of water and air, the air 2 filtration through photosynthesis. 3 So that's pretty much where I am coming 4 from. 5 Q. And to preserve trees, you know, one of 6 the -- sometimes the issue of tree roots and the 7 destruction of tree roots therefore could destroy a 8 tree. 9 How far do you have to go, if you know, 10 to protect a tree root if you're going to be doing 11 construction, and where would usually the delineation 12 be here? 13 A. Well, the most accepted standard is to 14 protect the trees within the drip line of the tree. 15 So in other words, the furthest 16 reach -- outreach of the branches covers the majority 17 of a tree's root system. 18 And it's the fibrous roots at the very 19 end that -- that are soaking up the water and the 20 nutrients from the soil. 21 It's, you know, close to the trunks of 22 the trees, within 12 to 15 feet, those are buttress 23 roots that are primarily for the support of the tree 24 under storm conditions. 25 But it's the fibrous routes that go out

Page 40 1 to the tips of the branches -- and, you know, the 2 roots do exceed that. 3 But that -- the drip line of the tree 4 pretty much defines the protected root zone. We 5 really don't want to be removing roots within that 6 area. 7 If you have to remove some of them, you 8 sort of monitor what percentage of roots are -- if 9 it's a -- if it's, let's say, 10 percent of the roots 10 on the tree, the tree will recover from that. 11 But as you get -- doing the trenching 12 or anything closer to the trunk of the tree, then 13 you're affecting the stability of the tree and then 14 the safety of the public or the surrounding 15 structures. 16 Q. And the drip line being the edge of -- 17 the maximum edges of the tree branches. Is that 18 correct? 19 A. Right. 20 It's, you know, it's a radius around 21 the entire tree. 22 Q. Okay. And in looking at the plan 23 itself, did you see opportunities to possibly -- and 24 we'll get into engineering testimony, but just from 25 your perspective and your experiences, ways to