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 5 outlines the conditions that allow the use of exfiltration for routing computations, with the first stating that “all soil testing must be fully compliant with Chapter 12: Soil Testing Criteria of this manual.” As noted in Table 1, none of the proposed BMPs with the exception of BMP 10 have the sufficient number of soil tests to demonstrate the site soils are appropriate for the stormwater design. The erroneous use of exfiltration for routing computations allows the applicant to artificially report reduced peak flow rates in the proposed condition to claim compliance with N.J.A.C. 7:8-5.6. Furthermore, there is a substantial routing error in the stormwater model. The site is broken down into three points of analysis (POAs). After reviewing the drainage patterns in existing and proposed drainage plans, Princeton Hydro has concluded that there should be four POA’s not three. POA2 has two distinct discharge locations on Warner Road and Kuzik Drive. The two roadways are over 500 feet apart. Their flows cannot simply be combined. The drainage area analysis completely ignores any flow in the existing and proposed condition at Kuzik Road. The flows at both points need to be analyzed separately to make sure the stormwater runoff quantity standards as per N.J.A.C. 7:8-5.6 (c). The current design ignores flow at Kuzik Road and risks causing a significant flooding issue unless a separate POA at Kuzik Road is included in the analysis. The current analysis cannot demonstrate that the flow at Kuzik Road meets the peak flow reductions for the 2 -, 10- and 100-year storm. The report and modeling give the false appearance that the proposed design meets the required peak flow reduction rates. Only after the fourth POA is developed and analyzed can the model confirm that the design is compliant. It must also be noted that the existing conditions drainage path for POA 2 stops approximately 700 feet short of the actual analysis point which just another error in the analysis that would need to be addressed as shown in Figure 2 below. Figure 2: Existing Conditions Drainage Path for POA-2, demonstrating how the analysis stops approximately 700 feet short of the POA location.