Exhibit O6 2151002Princeton Hydro West Essex Stormwater Comments 202401115

Stormwater Management and Freshwater Wetlands Review West Highlands, Inc. Block No. 179, Lot No.32, West Orange Township, Essex County, New Jersey November 2024 Princeton Hydro, LLC: 0683.022 2 It is our professional opinion that the application contains critical deficiencies related to stormwater management. For this reason, the permit application should not be approved at this time. 1.0 INTRODUCTION The application entails the proposed construction of multi-family residential development with recreational facilities and a clubhouse for residents of the facility with a limit of disturbance of 1,233,793 sf (28.32 acres). The 120-acre parcel is currently undeveloped. The project has not received any Municipal or State approval. The purpose of this letter is to briefly summarize deficiencies that we have observed in the revised application materials related to critical aspects of the application’s compliance with the New Jersey Stormwater Management Rules at N.J.A.C. 7:8. 2.0 STORMWATER MANAGEMENT The site plans and stormwater calculations have been reviewed to determine if the design engineer has demonstrated compliance with N.J.A.C. 7:8, the New Jersey Stormwater BMP Manual, and the local ordinance. We find the application fails to demonstrate it meets the requirements as it relates to the soil testing requirements and the two of the three of the primary stormwater management performance metrics. The following subsections outline our specific concerns as they relate to these three areas with the application submission. It is our professional opinion that the applicant has failed to demonstrate compliance with the requirements of N.J.A.C. 7:8. 2.1 SOIL TESTING REQUIREMENTS Prior to the discussions of the issues with the compliance with the three primary stormwater management performance metrics, this section will provide a breakdown of the soil testing requirements and its impact to the compliance to the stormwater regulations. As stated in Chapter 12 of the BMP Manual, understanding the character and saturated conductivity of surface and subsurface soils at a proposed land development site is crucial to the design of stormwater best management practices (BMPs) that meet the requirements of the New Jersey Stormwater Management rules at N.J.A.C. 7:8 (the Rules). Section 2 of Chapter 12 further clarifies that saturated soil hydraulic conductivity and depth to

that meet the requirements of the New Jersey Stormwater Management rules at N.J.A.C. 7:8 (the Rules). Section 2 of Chapter 12 further clarifies that saturated soil hydraulic conductivity and depth to Seasonal-High Water Table (SHWT) are of high importance for the design of stormwater BMPs. The total number of soil tests required within the footprint of a stormwater BMP is based on the area of the infiltration area. Chapter 12 of the BMP Manual states that a minimum of two soil profile pits must be excavated within the infiltration area of any proposed infiltration BMP. Additionally, for BMP infiltration areas larger than ten thousand square feet a minimum of one additional soil profile pit shall be conducted for each additional area of ten thousand square feet. Table 1 below is the summary of soil testing within each BMP based on our assessment of the plans and reporting. The table states the BMP number, type, Infiltration area, number of soil tests completed, number of soil test required, and a compliance check.