O30 Princeton Hydro Report Dated 9 3 25

PB-24-01 West Essex Highlands, Inc. Block No. 179, Lot No.32, West Orange Township, Essex County, New Jersey September 2025 details on determining whether saturated soils are present, the guidance document published by NRCS, "Field Indicators of Hydric Soils in the United States” may be used. When developing soil logs for test pits, one must look for mottling at any season. Not once was mottling observed in the soil logs and never do the logs follow the guidance found in the “Field Indication of Hydric Soils in the United States”. Princeton Hydro performed their own soil logs just outside of the property boundary in a few different locations and found evidence of mottling. These soil logs have been provided to the Board. A reasonable person is left to conclude that the only reason redoximorphic features were not noted is that the person documenting the test pits was not looking for them. The NJDEP BMP Manual requires one to specifically look for evidence of seasonal high groundwater and in the rare occasion it is not found, only then can alternative methods be used to establish the SHWT. Princeton Hydro believes that the person responsible for these soil logs should provide testimony about the methodology they used to document the soil logs. In addition, CME's position that applicant's engineer's method of determining the SHWT is consistent with the NJ BMP Manual is an overly simplistic interpretation of the Manual's requirements. For example, the soils mapped on the development site and shown of the applicant development plans possess a restrictive horizon or fragipan. The NJDEP BMP Manual has specific requirements for logging soils (Subsection 2c, page 22) that includes the identification of restrictive horizons such as a fragipan. Not a single soil log identified a restrictive horizon. The NJDEP BMP Manual also requires “the depth, or the elevation and thickness of each soil horizon" and that the soils are colored using the Munsell system of classification for hue, value and chroma. The soil horizons described appear to lump layers into several feet thick soil layers. This approach is not consistent with the NJDEP BMP Manual and fails to identify discrete horizons that may include restrictive horizons as should be expected based on the soil mapping. As stated in the Princeton Hydro report of April 29, 2025 (Attachment A) the failure to identify any

te horizons that may include restrictive horizons as should be expected based on the soil mapping. As stated in the Princeton Hydro report of April 29, 2025 (Attachment A) the failure to identify any restrictive horizons and seasonal high-water table will have a substantial impact on the functioning of the proposed stormwater management system. This resulting design deficiency has real and tangible impacts on downstream residents as it relates to the rate and volume of runoff from the property. It is the sole responsibility of CME to ensure that the proposed system functions in a manner that will satisfy the local ordinance. Despite noting “some discrepancies” on two key comments, the recent CME letter serves to simply document CME's attempt to deflect this responsibility. With respect to the critical issue of peak flow (flood) control and specifically the Time of Concentration calculations, the CME letter states the following: ... Alternative stormwater management measures, removal rates, or calculation methods may be utilized, subject to any limitations specified in this chapter, provided the design engineer demonstrates to the review agency, in accordance with N.J.A.C. 7:8-5.2(g), that the proposed measure and its design will contribute to achievement of the design and performance standards established by this chapter. Although N.J.A.C. 7:8 does allow for alternative stormwater management measures, removal rates or calculation methods, these alternative measures require justification to demonstrate the unique nature of the situation that dictated the need for the alternative method. Section N.J.A.C. 7:8-5.2 (g) states the following: An alternative stormwater management measure, alternative removal rate, and/or alternative method to calculate the removal rate may be used if the design engineer demonstrates the capability of the proposed alternative stormwater management measure and/or the validity of the alternative rate or method to the review agency. However, no justification, documentation or additional context is provided by the Applicant for the use of alternative methods. The justification for each alternative stormwater measure used by the applicant should have been identified by CME and shared with the public in their August 15" letter. Instead, the CME letter uses this generic reference to alternative methods to justify multiple design

pplicant should have been identified by CME and shared with the public in their August 15" letter. Instead, the CME letter uses this generic reference to alternative methods to justify multiple design features, including the time of concentration calculations, despite the fact that these approaches contradict the NJDEP BMP Manual and standard engineering practice as outlined in our March 10, 2025 letter. Princeton Hydro, LLC: 2151.002 2