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 3 Table 1: BMP Soil Test Summary BMP ID - BMP Type Infiltration Area (SF) Number of Tests Provided Number of Tests Required Compliant (yes/no) 1 – Large Scale Infiltration Basin 32,670 3 5 No 2 – Small Scall Infiltration Basin 26,023 2 4 No 3 – Porous Paving 5,227 None 2 No 4 – Porous Paving 12,197 None 3 No 5 – Porous Paving 14,810 1 3 No 6 – Porous Paving 35,719 1 5 No 7 – Small Scall Infiltration Basin 14,375 2 3 No 8 – Porous Paving 10,019 None 3 No 9 – Porous Paving 6,534 1 2 No 10 – Small Scall Infiltration Basin 9,587 2 2 Yes 11 – Porous Paving 45,948 2 6 No 12 – Small Scall Infiltration Basin 4,182 None 2 No As can be seen in the table above, the design engineer has only provided the minimum required quantity of soil tests within BMP 10. The remaining BMPs do not have sufficient testing to demonstrate the BMPs will function as designed. As a matter of fact, four BMPs have zero soil tests. The purpose of the soil tests is to demonstrate the soil below the proposed stormwater BMPs are suitable for the selected stormwater BMP. Since adequate testing has not been performed, the applicant has failed to demonstrate the stormwater system is compliant with the soil testing requirements. The soil testing is also used to demonstrate compliance with the groundwater hydraulic impact requirements at N.J.A.C. 7:8-5.2(h). While the applicant submitted groundwater mounding calculations, they cannot be considered valid because of the missing soil testing data. In the latest stormwater report, an Overall Soil Testing Map (Sheet OA) was provided. It notes locations of new soil tests or potential new soil tests, but any associated test results for these locations were not included. 2.2 GROUNDWATER RECHARGE Based on our review, the application fails to meet the Groundwater Recharge standards set forth in N.J.A.C. 7:8-5.4. In order for the BMPs to be used to satisfy the Groundwater Recharge Requirements, all requirements of Chapter 6 of the BMP Manual must be met. Based on the deficiencies of the soil explorations noted previously, the design does not have the acceptable number of soil tests required to demonstrate groundwater recharge. While the project is not compliant with the

encies of the soil explorations noted previously, the design does not have the acceptable number of soil tests required to demonstrate groundwater recharge. While the project is not compliant with the Groundwater Recharge requirements due to sufficient soil testing, it also reroutes a significant portion of the stormwater runoff in a manner that changes the flow