HomeMy WebLinkAbout10.12.2020 R. Schlank CommentsROSEMARY A. SCHLANK
9 Bayberry Lane
Rye Brook, NY 10573
(914) 939-9273
RSchlank@ix.netcom.com
October 12, 2020
Mayor Rosenberg and Honorable Members of the Village Board of Trustees
Village of Rye Brook Offices
938 King Street
Rye Brook, NY 10573
Dear Mayor Rosenberg and Trustees,
Re: Additional Comments on p-FEIS for Redevelopment of 900 King Street
The application for the redevelopment of 900 King Street is still woefully incomplete.
As several comment letters have stressed, there is a critical need for a supplemental
EIS to evaluate the effects of the COVID-19 pandemic. This additional information is
critical because of the mounting evidence that the “big-box” model of senior living
proposed for the site would have serious adverse effects on areas that must be
evaluated as part of the SEQRA process prior to any individual site plan review.
As Attorney Leslie Snyder wrote in her letter dated August 11, 2020:
First and foremost, we respectfully submit that a supplemental EIS is required in
the instant case. Indeed, a supplemental EIS is required when a change in
circumstances arises that may result in a significant adverse environmental
impact. See 6 NYC RR 617 .9( a)(7)(i). We respectfully submit that the COVID-
19 pandemic is a change in circumstances which will result in a significant
adverse environmental impact if the project proceeds in its current form.
Lessons learned from COVID-19
Here are a few of the key points that surfaced in a quick review of the lessons learned
from the pandemic, including quotes from leading industry experts and publications:
1. Calls for reforms of big-box facilities. The infection and death rates in big-box
senior care facilities during the pandemic have been devastating, and this has
led to widespread calls for reforms, including more federal laws and regulations.
The results of an investigation into assisted living facilities that were released
in July 2020 estimated that nearly 7,000 seniors may have died from COVID-
19 in assisted living facilities in the first few months of the pandemic. A
staggering 31% of seniors who contracted the virus in an assisted living
facility died from it. The investigation was led by NY Rep. Carolyn Maloney
and Massachusetts Senators Elizabeth Warren and Ed Markey. Similar to
Rosemary Schlank
900 King Street, page 2
independent living and memory care facilities, assisted living facilities
previously were not subject to federal regulation or oversight.
Other assisted living advocates have also called for reforms and demanded
that the industry be held to a higher standard. These advocates include
Leading Age, an association of nonprofit providers of aging services, and the
American Public Health Association.
2. Shifts in attitudes about senior living facilities. The COVID-19 infection and death
rates have caused a shift in attitudes among seniors and their families.
The Foundation for Research on Equal Opportunity estimates that 40% of
COVID-19 deaths occurred in nursing homes and assisted-living facilities.
Statistics like these have made long-term care decisions more stressful and
agonizing for seniors and their families.
In May 2020, Robert Kramer, who founded the nonprofit National Investment
Center for Seniors Housing & Care, or NIC, and now heads aging advisory
Nexus Insights, warned: “The daily news of tragedies at nursing homes and
stories of families unable to visit loved ones because of quarantines are going
to leave a mark on the industry. There’s a great danger that the boomers will
view senior living as equating to senior dying.”
Stressing the need for reforms and a new approach to senior living, Kramer
added: “When it comes to the senior housing industry and care, there will be
a time when we will see this in the rearview mirror but not a time when we
will return to the old normal.” (Reshma Kapadia, “How Covid-19 will shape
the future of senior living, New Models of Care, More Aging in Place,”
Barron’s, May 29, 2020.)
3. Alternatives to senior dying facilities. Warnings like the one about the perception
of senior dying facilities have been a wake-up call for the industry. Changing
attitudes are affecting the market demand for facilities like the one proposed for
900 King Street. When considering the options for where to live for the rest of
their lives, whether in independent living or assisted living facilities, the clear
trend is that seniors prefer other alternatives now, such as aging in place.
Truthfully, the senior living industry was already in turmoil prior to
COVID-19. Bob Stephen, AARP’s vice president of caregiving and health,
is quoted as saying that surveys routinely find that 9 out of 10 people say
they would like to stay in their homes.
Statistics also show that, prior to the crisis, roughly a fifth of senior living
communities had occupancy rates below 80% - which would make it hard
for them to survive a slowdown due to a pandemic or change in demand.
As a result, some real estate investors and developers have already begun
to voluntarily explore new models for adapting to these trends.
Rosemary Schlank
900 King Street, page 3
4. Warnings for RE investors. Security analysts have added their insights by
warning investors about the risks of being overly bullish on senior housing real
estate. They point to studies that show the aging-in-place alternative is
becoming increasingly viable due to investments and advances in technology.
In November 2019, the Wall Street Journal reported that, “Developers and
senior-housing companies have spent billions of dollars over the past five
years to build facilities that provide housing, food, medical care and
assistance for the elderly. While these properties have been filling up with
people born during the Depression or World War II era, real-estate
investors are eagerly eyeing the massive baby-boomer generation: 72
million people born between 1946 and 1964, or about one in five
Americans... But this wager on elderly care is falling short of expectations,
and there are concerns that it could become one of the biggest real-estate
miscalculations in recent memory, some analysts suggest. “
The warnings about miscalculations are based on known business plans.
The Journal goes on to explain: “That is in part because venture capital
and other companies are expected to invest about $1 billion this year in
these and other “aging-in-place” technologies that are starting to enable
seniors to enjoy similar living standards and access to care in their own
homes.” (Peter Grant, “A Once-Hot Bet on Housing for Seniors Is Cooling
Off,” Wall Street Journal, November 13, 2019.)
5. The next generation of senior housing. Industry experts say the next generation
of senior housing is likely to evolve around the concept that “smaller is better,”
particularly since there is some evidence that smaller facilities tend to be better
at preventing the spread of COVID-19.
Real estate industry sources say the Green House Project founded by Dr.
Bill Thomas is perhaps the best-known example of the small-house model.
Today, there are 268 active Green House homes in the US. These
properties typically house up to a dozen residents in homelike facilities
with private rooms, and they are staffed by “universal workers” who
provide a wide range of services and care. This approach effectively limits
the number of potentially infectious workers who are present at the
facility. As of June 2020, only 9 of these homes had reported a positive
case of COVID-19, which is far lower than the rates for the big-box
facilities. (Tim Regan, “’Smaller is Better’: Cpvid-19 Primes Senior Living
for Rise of Small-House Models,” Senior Living News, June 3, 2020.)
The design of the Green Houses is typically horizontal rather than vertical,
meaning they have fewer stories, though some industry architects have
maintained that the concept could be adapted to taller buildings. These
architects argue that the vertical approach is more cost-effective and
arguably the only possible solution for certain urbanized areas, such as
downtown Manhattan or Chicago.
Rosemary Schlank
900 King Street, page 4
However, one of the results of the pandemic is a growing realization that
cost efficiency is not always the best approach over the long term. “When
Perkins Eastman released its future-looking “Clean Slate Project” in 2019,
the goal was to explore the disruptive forces that might shape the senior
living industry of the future. While technology, the evolving preferences of
baby boomers and climate-fueled natural disasters made the list, the
possibility of a global pandemic was not on the radar at the time,
according to Dan Cinelli, principal at Perkins Eastman. But the disruptive
nature of the pandemic is currently teaching some in the industry that
scale or efficiency in senior housing is not always a good thing.” (Tim
Regan, How Covid-19 is Shaping the Future of Senior Living Architecture
and Design,” Senior Housing News, April 7, 2020, Copyright Sarah
Mechling/Courtesy of Perkins Eastman.)
Environmental Impacts
SEQRA requires an analysis of alternatives. If the applicant insists on submitting
a senior-housing proposal, it should at least submit a small house alternative
now because COVID-19 is a significant change in circumstances that demands
consideration of more effective, flexible, and sustainable alternatives.
By better controlling the risk of infections, the small house alternative would
better protect the health and well-being of the citizens of Rye Brook. It would
also lessen the risk of shutdowns, school closings, and increases in crime. And it
would mitigate the concerns about the required zoning changes and the adverse
effects of the inconsistency of the density with the character of the community.
Just as important, the small house approach would help to ensure the
development will remain competitive and sustainable. This will take some of the
risk and uncertainty out of the projected economic impact, including any
potential increase in tax revenues that might be negotiated in the future. In
contrast, if the applicant persists with the big box approach, any increase in tax
revenues is likely to be short-lived and may even be purely hypothetical.
Attached is a comparison of a small house approach with the big-box approach. Please
do the right thing, acknowledge that the p-FEIS is still incomplete, and require
the supplemental EIS. Thank you for considering my comments.
Yours truly,
Rosemary Schlank
Chris Bradbury, Administrator, Village of Rye Brook, NY
Dan Barnett, President, Board of Directors, Arbors Homeowners Association
Rosemary Schlank
900 King Street, page 5
Small House Model of Senior Living
Hover Senior Living Community; courtesy of Green House Project
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Big-Box Model of Senior Living
Letter submitted by JLL Valuation & Advisory Services, LLC in support of proposed
redevelopment of 900 King Street