2018.11.07 C. Bradbury CommentsPage | 1
VILLAGE OF RYE BROOK
MEMORANDUM
TO: Hon. Paul Rosenberg and Members of the Village Board
FROM: Christopher J. Bradbury, Village Administrator
SUBJECT: Comments on 900 King Street DEIS
DATE: November 7, 2018
The following comments are prepared for your consideration regarding the Draft Environmental
Impact Statement (DEIS) at 900 King Street:
1.3.1.1 EXECUTIVE SUMMARY: SUMMARY DESCRIPTION OF THE PROPOSED ACTION:
PROPOSED ZONING: Existing Zoning:
In referring to a May 26, 1998 Resolution, the last sentence in this section states that
“The Resolution and letter conclude that the existing development of the Project Site
is fully conforming to its original site plan approval in order to provide its lawful
status, i.e., it is zoning compliant (see Appendix B-2).”
More accurately, the May 26, 1998 Resolution determined that all existing conditions,
improvements and information as shown on the Current Site Plan were deemed to
have been developed and in accordance with the Original Site plan and the Town of
Rye Code. The Resolution does not necessarily determine the project’s “legal status”
or that it is “zoning complaint” so those statements should be deleted.
1.5.8.1 EXECUTIVE SUMMARY: SUMMARY OF POTENTIAL ENVIRONMENTAL IMPACTS:
COMMUNITY FACILITIES: Emergency Services &
10.2.3.1 COMMUNITY FACILITIES: EMERGENCY SERVICES RESPONSE: POTENTIAL IMPACTS
OF THE PROPOSED PROJECT: Emergency Medical Services &
21.3 CUMULATIVE IMPACTS: EMERGENCY SERVICES
The Emergency Services section does not fully address the service area or the
revenue sources. The DEIS should more fully explain that the EMS covers three (3)
municipalities, Rye Brook, Rye City and Port Chester (this relationship is briefly
discussed in DEIS Section 10.2.1.1).
The DEIS states that since most of the EMS revenue comes from insurance recovery,
the costs for any increase in calls will be recovered through insurance recovery and
additional property tax revenue. This conclusion is not reflective of the impacts of
the additional calls on the three municipalities in the EMS service area.
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Approximately 70% of the EMS revenues come from insurance recovery, while 25%
of the remaining revenues come from municipal contributions. In terms of the
municipal contributions, 75% of the municipal contributions are divided equally
among the 3 municipalities while the remaining 25% is based on population. As
populations change in the census figures, the 25% share of the municipal
contributions change as well. The potential impact of an increase in Rye Brook’s
population from this development is not discussed in the DEIS. In terms of property
tax revenue offsets, both Port Chester and Rye City would not receive additional
property tax revenues from this project to offset any potential increase in their
municipal contributions.
The DEIS should break down the calls by municipality to more clearly reflect he
number of EMS calls to Rye Brook. The DEIS indicates that there could be as much
as a 7.8% increase in call volume from this site but this in the entire service area, not
just Rye Brook.
In reviewing the potential project impact to an increase in EMS calls, the DEIS
should examine the impacts of the following EMS issues:
· The EMS’s headquarters is at 417 Ellendale Avenue in Port Chester. Based on
staffing and call volume, the EMS positions an ambulance in other locations,
including at the Rye Brook firehouse.
· As calls come in, they will reposition these ambulances as needed based on those
calls and ambulances available.
· When patients need transport, they usually go to Greenwich Hospital or White
Plains Hospital pulling those ambulances out of the response area.
· If mutual aid is needed in their service area, they will typically call Harrison EMS
or Greenwich EMS. Similarly, they will also go to mutual aid calls in Harrison or
elsewhere if needed and staffing is available.
· In order to meet current demand, EMS has hired an additional supervisor. They
are also considering adding an additional ambulance at certain times of the day.
For FY2019, they have requested a 5% increase in their municipal contributions
for the first time since 2010 in order to address the need for additional coverage.
10.2 COMMUNITY FACILITIES: EMERGENCY SERVICES RESPONSE:
The opening paragraph indicates that the PCFD responds “with assistance from the
RBFD”. This should be modified that both the PCFD and RBFD both respond to
calls together and that the RBFD is under the operational control of the PCFD.
10.2.1.1 COMMUNITY FACILITIES: EMERGENCY SERVICES RESPONSE: EXISTING
CONDITIONS: Existing Services:
Under ‘Fire Services’, the DEIS references the 2014-15 adopted budget figures. The
number of RBFD personnel (and their working hours) and the contract with Port
Chester is currently very different in FY2019 compared to FY2015 and should be
updated.
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10.2.1.2 COMMUNITY FACILITIES: EMERGENCY SERVICES RESPONSE: EXISTING
CONDITIONS: Call History of the Project Site:
The DEIS shared information received from the RBFD that the response to the
project site “typically takes less than 1 minute”. While the location is admittedly very
close to the Rye Brook Firehouse, it is unlikely that it would take “less than 1 minute”
to get to the site from the time of dispatch. This information should be verified with
factual information available from 60 Control.
10.2.1.3 COMMUNITY FACILITIES: EMERGENCY SERVICES RESPONSE: EXISTING
CONDITIONS: Emergency Services Experience with Other Senior Living
Communities &
10.2.3.1 COMMUNITY FACILITIES: EMERGENCY SERVICES RESPONSE: POTENTIAL IMPACTS
OF THE PROPOSED PROJECT: Emergency Medical Services:
There is a significant different between 66 and 465 EMS calls per year and the DEIS
indicates that this difference in response rate “could be attributable to a number of
factors, including the relative age and health of the on-Site population.” and that to
“minimize the number of additional calls for EMS services, the Proposed Project
would seek to incorporate physical and operational measures to minimize
unnecessary EMS calls, such as instituting physical improvements and operational
policies to reduce fall hazards throughout the facility.” The differences in the
number of calls, and how this impact could be mitigated, should be more specifically
identified.
10.2.2 COMMUNITY FACILITIES: EMERGENCY SERVICES RESPONSE: FUTURE WITHOUT
THE PROPOSED PROJECT:
The DEIS states that the “Village has no current plans to change the staffing levels or
the number or geographic distribution of EMS services.” The EMS service recently
added an additional supervisor and is discussing the need to add an ambulance on
certain shifts to meet the call demand.
10.4.2 COMMUNITY FACILITIES: OPEN SPACE: POTENTIAL IMPACTS OF THE PROPOSED
DEVELOPMENT:
The DEIS indicates that the Project would include 2.7 acres of space for active and
passive recreation, which exceeds the Section 209-14 code requirement that purpose.
However, the DEIS ignores the first park of the code requirement for “a park or parks
suitably located and usable for passive or active recreational purposes”. The Village
Board should decide if providing the identified open space on the project meets this
code requirement.
END
Revised 10-08-2018 (typo)