Greenville Fire Commissioners Meeting “Follows Protocol”

It started off like every other Fire Commissioners’ meeting. Discussions about expenditures, balancing budgets, training and the like. The difference this time is that it was at the Greenville Fire District’s public meeting room in the basement of the Greenville firehouse but the room was full, with several residents standing along the side of the room. The five commissioners were all in attendance. They are Helene Orce, the Chairperson, whose term expires December 31, 2021; Robert Bruckenthal, whose term expires December 31, 2017; Jonathan Faust , whose term expires December 31, 2020; Walter Groden, whose term expires December 31, 2019; and Michael Rappe, whose term expires December 31, 2018. Of course, the fire chief and the district’s secretary were also present.

After the regular order of business had transpired, the floor was opened for questions and comments from the audience members. Most of the room seemed to be concerned Edgemont residents, but we don’t believe it was entirely so. There were two representatives from the Formation Shelbourne project, although only one spoke during the entire event. This meeting was advertised as one where Shelbourne would be making a presentation to the Greenville Fire Commissioners. The prevailing thought being that they would finally be addressing questions that had been raised and sent to Shelbourne. The audience was told that this was not the case and no presentation would take place tonight.

Edgemont Community Council President Robert Bernstein asked the Board of Commissioners if they had received any resolution to the questions they raised about the Formation Shelbourne project they seek approvals for to build on Underhill Avenue. This location is currently the site of the Sprainbrook Nursery, owned by the Krautter family and has been for a long time, stating at one point that this site was their retirement nest-egg. In fact, they had many friends and relatives come to assorted Town Board meetings and bemoan that point. While we understand and appreciate this fact, we still disagree with the sale to Shelbourne; not because we don’t want something built on the property, rather, we want something appropriate to be built on the site conforming to current zoning, needs no variances and will now blend into the neighborhood. 

During the course of back-and-forth with the audience and the Board, the representatives from Shelbourne often said they followed the procedure. One resident asked about simply sending an answer to the Board, regardless of procedure, and asked why it was seemingly so hard to do? The Shelbourne representative then described the procedure. Really? Since the Fire Commissioners' questions appeared simple enough to answer, why not just answer them in a simple response directly to them? Perhaps one of the Shelbourne representatives could send a simple email answering the questions that were raised?

One missing link not mentioned by either side was that of being a “good neighbor” and trying to do the right thing, especially Shelbourne working with the Fire District. We understand why Shelbourne has circled their wagons against the Edgemont community as they have been vociferously against the proposed facility. But the fact remains that should this project get approval, they are going to need the fire district and fire department as an integral part of the facility’s operation.Additionally, wouldn’t every developer hope that by establishing an open and constructive dialog, they would be more able to streamline the process for their advantage? While this may a good strategy from our perspective, Shelbourne’s representatives seem more concerned with following protocol, which does not include open communication to a major, interested agency. This needs to change. Only then will we get A Better Greenburgh.

The questions that remain unresolved are these, as taken directly from the Greenville Fire District’s website*:


WATER BURDEN
The District wishes to ensure adequate and reliable fire protection water supply (both pressure and volume). GFD has not seen the proposed plan to connect the two area water mains. We request projections of the water flow statistics for review. In addition, we ask for the statistics after the interconnection is complete.

The CND’s proposal that one hydrant be relocated (p. 9) does not appear adequate. An additional hydrant is needed. The District wishes to be involved in discussions regarding the relocation of the existing hydrant and new hydrant.

INACCURATE UNDERSTANDING OF DISTRICT SERVICES
Initially, the CND states on page 7 that: “From a medical emergency perspective, when there is no trained life saving staff (i.e. LPN or RN) present at a site, the Greenville Fire District provides supplementary certified first responder (CFR) and Emergency Medical Technician (EMT) services to supplement the transport, ALS and BLS service provided by the Town of Greenburgh Police Department and paramedic/EMT units.” This statement is incorrect and misunderstands the role and operations of the District. In addition to fire and other emergencies, the District is dispatched by Westchester County's 60 Control to situations requiring an EMS response. We have an Inter-Municipal Agreement (IMA) with the Greenburgh Police Department (GPD) through a tiered EMS System. This IMA requires that the District respond to EMS calls. GPD resources have primacy, and the District provides Basic Life Support (BLS). If District firefighters are first on the scene, we have primary medical responsibility until relieved by a higher level of care. GPD is responsible for transports, but a District firefighter may accompany the GPD transport in exigent cases. To reiterate, we provide an EMS response to all sites in our service area, irrespective of the presence or level of any on-site staff training. To that end, we are a complementary, albeit non­ transporting, BLS response.

The ZBA’s fundamental misunderstanding of our role necessarily means that the CND does not correctly identify impacts the Project may have on the District, or the effect of the proposed mitigation measures. (See the discussion below).

INSUFFICIENTLY SUPPORTED EMS RESPONSE DATA
First, the validity of the annual number of anticipated emergency caJJs assumed by the CND -an essential data point -- is unclear. CND page 8 states:

“The applicant has supplied data from other comparably-sized facilities, indicating that approximately 100 annual emergency calls will be generated (Police and/or Fire-related). Because there has been much debate over the number of potential additional EMS trips the ZBA analysis assumes that 115 calls/year will be generated by the proposed facility.”

It is our understanding that this essential data point is based on your accepting the 100-call figure supplied by the applicant, despite the absence of any indication as to which (or how many) comparably sized facilities were used in the applicant's sample, the percentage occupancy of such facilities at the time of the tallies, or whether those other facilities are purely assisted living in nature or mixed-use with nursing staff. The CND then increases the analysis to 115 calls/year using a methodology that remains unclear to us. We expect that a proper and independent study of this issue would rely on a more statistically rigorous, corroborated, and independently validated data from “comparably-sized” facilities regarding likely added EMS call volume. Indeed, there may be pre-existing industry data available.
Second, the CND states that “115 additional EMS-related trips are less than the number of trips that are expected to have been generated by the existing nursery use (477), which had no trained medical personnel on-site.” We simply do not understand the utility, validity or predictive value of comparing the 115 assumed anticipated emergency trips to an assisted livingfacility as against the 477 non-emergency trips to a nursery during presumably peak usage (we understand that the 477 figure was based on a June study; nursery visit in winter presumably are much lower). So, the nursery trips used as a “comparable” for purposed of the CND’s analysis is inflated and irrelevant. The foregoing apparent flaws in the analysis methodology underscore the need for a thorough and independent traffic study in order to more properly identify and quantify potential impacts. This will provide you (as Lead Agency) and us (as an Interested Agency) with the data we need to assess the number and effect of any additional calls.
 
FAULTY ASSERTIONS ABOUT EFFECT OF ON-SITE LPN/RN 
The CND notes at page 8 that the applicant has agreed to provide an LPN or an RN and states: “The 24/7 presence of a LPN or RN at the site would reduce the volume of response to the facility because such staffing reduces the need for secondary non-transporting response from the Greenville Fire District, which otherwise would act to supplement (with fire trucks) Town of Greenburgh EMS response, for non-fire related calls.” The CND notes, however, that actual EMS calls will remain the same (115) even with an on-site LPN or RN.

However, the proposal to mitigate impacts on the District by requiri ng an on-site LPN or RN is entirely incorrect and ineffective because it is based on the above-described misunderstanding of the District 's EMS role -- the District is not a "secondary" or "supplementary" EMS provider; rather, we respond to all calls. Since the CND concedes that the presence of an LPN or RN will not reduce anticipated EMS call volume, the impact on the District is unchanged. Moreover, the proposed mitigation method is not supported by any data or independent study. It is entirely possible that an on-site LPN or RN will lead to more calls to the District as Project residents take advantage of readily accessible staff to seek medical assistance more often. A substantiated assertion would compare call volumes at similar facilities with and without a single onsite LPN or RN. We would welcome such a third-party analysis; we cannot accept ipse dixit. Separately, we note that an LPN or RN likely would call the District for “lift assists” to safely handle frail patients that have fallen.

The CND's premise that the Project will require less District coverage because it will have an RN or LPN is highly problematic on another level: it creates a scenario of differing levels of response/service within the District. That is diametrically opposed to our mission of providing all residents with the same consistent level of care. Besides being antithetical to the foregoing principle, it is possible that rendering dissimilar services may expose the District (and its taxpayers) to liability.
 
ROADWAY CONDITIONS
The ZBA correctly notes the “curvilinear and sloping portion of Underhill Road.” But neither the Applicant nor the ZBA has provided, or offered to provide, any study that would assess the danger present and the extent to which the proposed alterations will impact on the safety risks for both District employees and other motorists. The CND simply assumes that the conditional improvements proposed would materially reduce the safety risks of running a substantial increase of emergency traffic along the identified dangerous road segments. An independent study must be completed which: (a) measures both the risks of the road condition and the utility of improvements (whether proposed or other available options); (b) analyzes existing road conditions against the benchmark for road conditions expected for a facility like the Project (e.g. county road or collector road). The District has not, and will not, take a position on the overall merits of the Project or its propriety for the community. Such matters are outside our mandate. However, we are compelled to take issue with the CND insofar as it lacks adequate analysis, is based on erroneous assumptions, and proposes solutions that are based on unsound footing.

* http://fdgreenville.com/
Terminology: 
GFD - Greenville Fire Department
ZBA - Zoning Board of Appeals
CND - Conditional Negative Declaration
ALS/BLS - Advanced Life Support/Basic Life Support (Paramedic/EMT respectively)
LPN/RN - Nursing staff deliniations
EMS - Emergency Medical Services
EMT - Emergency Medical Technician (as a rule not able to do injections/intravenous)
Paramedic - Medically superior to EMT (able to inject, do IV’s) 
CFR - certified first responder