O30 Princeton Hydro Report Dated 9 3 25

i PRINCETON SCIENCE ENGINEERING DESIGN =f DRO April 29, 2025 Colleen Keller Watershed & Land Management Program New Jersey Department of Environmental Protection Bureau of Coastal & Land Use Compliance & Enforcement Mail Code 501-02A 501 East State Street PO Box 420, Trenton, NJ 08625-0420 colleen.keller@dep.nj.gov RE: — PB-24-01 West Essex Highlands, Inc Block: 179 Lot: 32 Zone: IH-1 Warner Road West Orange Township, Essex County, New Jersey Permit No. 722-04-0001.1 LUP230001 Dear Ms. Keller, At the request of our clients, We Care NJ Corp., Princeton Hydro, LLC has performed an independent technical review of the proposed West Essex Highlands development project (hereinafter termed Project) located in West Orange Township, New Jersey as part of the municipal Planning Board approval process. The applicant, West Essex Highlands received a permit, No. 722-04-0001.1 LUP230001, for activities regulated under the Freshwater Wetland Protection Act and Flood Hazard Area Control Act. NJDEP. It is our understanding that the New Jersey Department of Environmental Protection (NJDEP) reviewed the stormwater management plan for compliance with the New Jersey Stormwater Best Management Practices Manual (BMP Manual) and the Stormwater Management rules at N.J.A.C. 7:8 as part of the issuance of Permit No. 722-04-0001.1 LUP230001. The permit states “[t]he Department has determined that this project meets the requirements of the Stormwater Management rules at N.J.A.C. 7:8.” Although approved by the NJDEP, Princeton Hydro's review of the Township submission identified substantial issues regarding the project's stormwater management design that fail to comply with the requirements of New Jersey's Stormwater Management Rules as well as the New Jersey BMP Manual. One of the concerns regarding this project is that municipalities often view the NJDEP as the state's stormwater expert since they developed the regulations as well as the municipal ordinance that municipalities must review development projects for compliance. When the NJDEP grants a permit prior to or during the municipal review process, municipalities are often pressured by applicants into issuing an approval based simply on the fact that the NJDEP already granted a permit. However, in this case the municipality is confronted with a number of serious compliance issues related to the Site’s stormwater

roval based simply on the fact that the NJDEP already granted a permit. However, in this case the municipality is confronted with a number of serious compliance issues related to the Site’s stormwater management plan that should ultimately result in the denial of the application. It is in this light that we request the NJDEP suspend the permit based on the conditions set forth at N.J.A.C. 7:13-22.7 Suspension of a ‘> PrincetonHydro.com ©