PB 24 01 West Essex Highlands Inc Draft Resolution

79. Objectors also introduced testimony from Geof Goll of Princeton Hydro. Mr. Goll opined that using “factors of safety” the slope on the property has a naturally low safety factor. The suggestion of Mr. Goll was disputed by the Applicant’s geotechnical engineer, Mark Seel, who testified that the calculations shown in the Goll report confirmed that the slope was stable and could sustain the weight and mass of building D (the building closest to the ridge line.) Mr. Goll also admitted that the Applicant was not proposing any disturbance east of the ridge line. 80. The Board’s engineering consultant, Samuel A. Kleinberg, of CME provided an opinion as to whether Building D position on the site and proximity to the slope was a potential danger to any of its occupants or surrounding properties. Mr. Kleinberg reviewed the reports and information provided by both Applicant’s engineering expert (Seel) and Objector’s expert (Goll) and issued a report dated October 28, 2025. Mr. Kleinberg testified that he was not provided with the conservative ground water analysis from Langan. Mr. Kleinberg recommended that Langan provide the output study; however, Mr. Kleinberg confirmed that it was unlikely that there would be any slope failure at the site. 81. Mr. Kleinberg testified that both Langan and Princeton Hydro both came out with safety factors of greater than 1.5 which means that both studies indicate that the slope is not unstable. Mr. Kleinberg opined that the 1.5 safety factor was sufficient for this project and the proposed location for Building D did not have any significant impact on slope stability. 82. Mr. Kleinberg considered many scenarios that were highly unlikely but ultimately concluded that the location of Building D was to the west of the slope as required by