Note: The following is not a verbatim transcript of the Zoning Hearing Board meeting; it is simply one person’s summary of the major points made by those involved in the hearing process.  For that reason, quotation marks are not used unless a direct quote was recorded.  For information about obtaining an official ZHB transcript, contact the New Hanover Township office.

What is GR 2?

The meeting started with the cross-examination of Mr. David Horner of Horner and Canter, whose firm conducted traffic studies by Mr. Lawrence Sager, of Sager & Sager Associates, Pottstown. Sager represents Louis Farrell of Atomic International, a company that borders the proposed site.

Sager’s cross-examination centered on trying to portray Horner’s data, methodology, and experience as suspect.  His first question centered on whether or not Horner expected that his numbers would represent correct information no matter what side (Gibraltar Rock or Township) he was on.  Sager asked how Horner could render opinions without doing a traffic impact study in GR1.  Horner said it wasn’t necessary in GR1 to do it. It was only after the township’s traffic engineer said it was needed that they did it.  Sager was trying to make a point that the burden of responsibility shouldn’t always have to be with the citizens or the township (who, in affect aren’t specialists in traffic or other fields).  Horner wanted to hear none of this.

All during the evening, Sager kept using the phrase, “in your quest for the truth” in referring to Horner’s traffic impact studies.

Sager then moved on to trying to get Horner to agree that he (Horner) is bound by the professional standards of the professional organization of which he belongs. This organization, International Transportation Engineers (ITE).  ITE sets standards and provides guidelines for transportation studies.  Sager pushed Horner to admit that in GR1, it was his opinion that he (Horner) did not have to study another quarry for trip generation because it isn’t (explicitly) in the ITE standards. But in GR2 he did.  Again, Horner said it was the township’s traffic engineer that requested the traffic impact study (even though, in his opinion, it isn’t needed).

Sager moved on to trying to find out where Horner got his data on projected trips/day. Horner said all of the information came from Gibraltar Rock.  None of the data came from other quarries, just from Gibraltar Rock’s representatives.  Sager wanted to know if this is typical. Horner said it was.  Sager said, “…in your quest for the truth, most of your data comes from Patankar (Gibraltar Rock’s engineer)…you didn’t talk to any truck drivers at other quarries, didn’t look at any operation plans of any other quarries…” 

Sager then went into the data with Horner and picked some specific times to ask questions about.  At the quarry they did study (Miller’s Quarry), between 4PM and 4:30 PM on a week day, four (4) cars drove past.  Sager was making the point that this wasn’t Rt. 73.  Think about the number of cars that drive past the proposed site between 4 and 4:30 each day and you’ll get the picture.  Yet, Horner responded that the Miller site is representative of the proposed Gibraltar Rock site…because to Horner, it’s not the traffic on the road but the number of trucks the quarry will add to the road---which is about the same between both sites.  Ah, weaseling with numbers.

Sager followed up by asking him is “….in your pursuit of the truth, you didn’t make any effort to locate a quarry that was closer to the proposed site…” It appeared he did not.

Sager then tried to trip Horner up on which copy of the “Trip Generation Handbook.”  This book provides trip data for about 4200 studies that other traffic engineers have conducted.  For example, if a traffic engineer is working on a proposed shopping center, he or she can go to this resource to see what other engineers have found (regarding traffic) for other shopping centers (of the same size).  Horner noted that there is no information in this book for quarries.  Sager ,however, wanted to direct Horner’s attention to other things in the book, specifically the “recommended procedures for conducting traffic studies.”  Sager introduced a few pages of this book…

…into the record.  Horner kept talking about the book with the “Green” cover. Sager said his copy had a “Red” cover.  Mr. Stephen Harris, attorney for Gibraltar Rock believed it was burgundy.  Some of us in the audience thought it more “Maroon.”

Sager unexpectedly ended his cross-examination by reading a passage from the book that said, “surveys of at least 3 sites, preferably 5 should be undertaken…”  Sager was, in effect saying that Horner, by doing only one study of another quarry (Millers) was not following accepted standards and practices in his profession, and without saying it out loud, was saying Horner was not qualified to be an expert witness on traffic. We’ll come back to this in a minute.

The zoning hearing board had a few questions about traffic safety on Swamp Pike.  In past testimony, Horner said that most truck trips will be Rt 73 to Rt 663, to Swamp Pike, to Limerick. One of the board members wanted to know if this would impact safety. Of course Horner said it would not.  He did say that presently 10,000 vehicles a day travel Swamp Pike (any of you remember when it was 100 / day?).  Horner said, “…even though there are 10,000 cars a day on Swamp Pike, it (the road) can safely handle the increased truck traffic from the quarry.”

Harris then was able to re cross his witness.  In his re-cross, Horner said that the three (3) to five (5) surveys mentioned in the Trip Generation book referred to the number of surveys needed if you wanted to provide study data to the ITE for inclusion in the next issue of “Trip Generation”.

At this point we thought the meeting was over, until Sager made a motion to strike from the record all of Horner’s testimony, because in his opinion, “it is not founded on a proper scientific basis, is not reliable, and standards have not been applied properly.”

Ms. Bell, the attorney for the Zoning Hearing Board tabled this discussion until either the next meeting or sometime before the next meeting.

The next GR 2 meeting is March 18, 2004 at the New Hanover Township Building, 7:00 PM.  

See Also:
Summary of the previous Gibraltar 2 meeting (January 22, 2004)