O30 Princeton Hydro Report Dated 9 3 25

PRINCETON SCIENCE ENGINEERING DESIGN ——_ HY DRO Dr. Robert Bagoff, Chair September 3, 2025 West Orange Planning Board 66 Main Street West Orange, NJ 07052 0 \z & RE: PB-24-01 West Essex Highlands, Inc Block: 179 Lot: 32 Zone: IH-1 Warner Road West Orange Township, Essex County, New Jersey Dear Dr. Bagoff, At the request of attorney Bruce Afran, counsel for objectors and We Care NJ Corp., Princeton Hydro has prepared a response to the CME letter dated August 15, 2025 which was addressed to the Chairman and Members of the West Orange Planning Board responding to Princeton Hydro's March 10, 2025 review of the stormwater management system for the above referenced application. Without providing substantial supporting details or evidence, the CME letter generally states that proposed stormwater system is compliant with New Jersey Department of Environmental Protection (NJDEP) design standards and requirements found in NJAC 7:8 and the NJDEP Best Management Practices (BMP) Manual. In lieu of providing any notable supporting reasoning, details or evidence, CME instead simply states and reiterates that the “...Department has determined that this project meets the requirements of the Stormwater Management Rules”. In fact, in reference to two critically important points (Time of Concentration calculation and groundwater mounding analysis) the CME letter confirms that they found “some discrepancies” as they relate to both of these key points. However, instead of describing these “discrepancies” to any extent or offering any critical response to the detailed issues outlined in our original letter, they simply state the NJDEP has issued a permit. As the Municipal Engineer for the Township of West Orange one of their responsibilities is to ensure the stormwater design meets the requirements of the local ordinance. As a Township consultant, they are charged with providing an accurate and independent review of the stormwater system for the proposed West Essex Highlands development. The applicant's ability to secure an NJDEP permit does not relieve CME from their responsibility to provide an accurate, objective and independent analysis of the proposed stormwater plan with respect to the local ordinance. In the following sections we respond to key elements of the CME letter. With respect to the applicant's reported site-wide total lack of any seasonal high

r plan with respect to the local ordinance. In the following sections we respond to key elements of the CME letter. With respect to the applicant's reported site-wide total lack of any seasonal high groundwater indications, the CME letter states: ...[T]he New Jersey Stormwater Best Management Practices Manual (NJ BMP Manual) notes that there are instances where mottling can be absent from a soil profile, therefore, observing mottling in a soil profile is not a requirement. Further, Chapter 12 of the NJ BMP Manual specifically outlines the methods for determining the seasonal high-water table (SHWT) when mottling is not observed in a soil profile. Therefore, based on our review, the Applicant's Engineer's method of determining the SHWT is consistent with the NJ BMP Manual. The NJDEP BMP Manual Chapter 12 Subsection 1d: Seasonal High Water Table (SHWT) Location #1 (page 12) states the following: Where mottling showing redoximorphic features is observed at any season of the year, the SHWT shall be taken as the highest level at which the mottling is observed, except when the water table is observed at a level higher than the level of the redoximorphic depletions or concentrations. For 08-237-5660 P.O. Box 3689 enton, NJ 08629