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MVHS DEIS: Alternatives Considered
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Alternatives Considered
2.1 PURPOSE
As stated in the SEQR Handbook (3rd Edition – 201027) published by the NYSDEC, the goal of the alternatives
discussion in an EIS is to “investigate means to avoid or reduce one or more identified potentially adverse
environmental impacts.” The SEQRA implementing regulations (6 NYCRR 617) further require that the
alternatives discussion include “a range of reasonable alternatives, which are feasible considering the objectives
and capabilities of the project sponsor.”
As previously identified in Section 1, the objectives and capabilities of the project sponsor (MVHS) are as follows:
Consolidation of multiple, existing, licensed health care facilities into an integrated system of care, within the
largest population center in Oneida County (as stated in MVHS’ CON application; see Appendix A). Within its
CON application submitted to the NYSDOH, MVHS indicated that the consolidation will result in the following
public benefits:
» Provision of one integrated location for acute care with greater access to residents of the City of Utica,
Oneida County and the region
» Improvements to operational efficiency, patient satisfaction, and safety for both patients and caregivers
» Creation of a structured delivery system, ending current service fragmentation, and increasing service
integration and coordination of work of the hospitals and other community-based organizations
» Reduction of gaps/inefficiencies in care coordination, alignment with payment reform and rebalance
healthcare delivery through the reduction in the number of hospital beds as care is shifted from an
inpatient care model to an outpatient care model focused on population health
Substantive compliance with the Oneida County Health Care Facility Transformation Program 28, a law enacted by the New York State Legislature in 2015, which provides capital funding ($300 million) “in support of projects located in the largest population center in Oneida County that consolidate multiple licensed health care facilities into an integrated system of care.” (https://www.nysenate.gov/legislation/laws/PBH/2825-B)
The location and centralization of the project within the central business district of Utica, can become a catalyst for ongoing and future development of the region (see Section 8 – Growth Inducing Aspects).
Additional information regarding the public need for the project is included in the CON application provided as Appendix A.
Consistent with the Final Scoping Document (Appendix C), the following alternatives are evaluated in this section:
“No action” alternative
Alternative sites
Alternative scale/magnitude
Alternative design
Alternative timing
2.2 NO ACTION ALTERNATIVE
In accordance with the SEQRA implementing regulations29, the range of alternatives must include a discussion of the “no action” alternative. The no action alternative discussion evaluates the adverse or beneficial site changes that are likely to occur in the reasonably foreseeable future, in the absence of the proposed action.
The "no action" alternative is included in the DEIS to provide a baseline for evaluation of impacts and comparisons of other impacts (i.e., the likely circumstances at the project site if the project does not proceed). The absence of the proposed action (“no action”) is defined as:
The likely continuation of existing conditions within the project footprint, which includes existing businesses,
as well as underutilized, vacant, dilapidated and unsafe properties
MVHS’ continued maintenance and operation of existing aged facilities, despite the State-identified public
need for consolidation of, and improvements to, regional healthcare and its associated public benefit
The forfeiture of project-related funding including $300 million from New York State.
As noted in Section 1, implementation of the project will eliminate the existing operational inefficiencies through the elimination of duplicative and redundant functions between FSLH and SEMC, thereby reducing overall spending. The “no action” alternative is inconsistent with this objective, as well as the additional objectives of MVHS and other stakeholders to provide improved healthcare to the residents of the Mohawk Valley region.
2.2.1 Future Conditions – Downtown Footprint
As indicated in the Phase 1A Architectural Inventory (see Section 3.6), the project site is predominantly characterized by remnant 19th and 20th century buildings vacated during the decline of manufacturing within the City limits. In the late 1950s and 1960s, urban renewal plans led to the demolition of numerous city buildings, which became vacant lots when proposed projects did not materialize. While some of the buildings have been adaptively reused by local businesses, the condition of many other buildings within the project footprint continues to decline due to neglect and vacancy (as illustrated in project photographs; see Appendix E).
Under the “no action” alternative, potential development scenarios range from a continuation of the status quo conditions (i.e., continued operation of existing businesses under a no growth scenario and continued deterioration of already vacated and dilapidated buildings and properties) to a maximum build-out scenario consistent with the City’s existing zoning designation (Central Business District, CBD)30.
While the no growth scenario would not necessarily result in any direct significant adverse impacts on the environment, it would likely, over time, result in potentially significant adverse socio-economic impacts due to the need for funding to demolish uninhabitable, vacated and/or abandoned buildings; repair neglected infrastructure; and/or remediate impacted sites/buildings.
The maximum build-out scenario would require public and/or private investment resulting in potential growth of existing operations and/or adaptive reuse or replacement of existing, vacated buildings or vacant lots. The maximum build-out scenario would result in environmental and socio-economic impacts similar in type and magnitude to impacts identified as a result of construction and operation of the hospital including:
Impacts on Land – Clearing and/or excavation on parcels could expose impacted soils requiring removal and
off-site management.
Impact on Surface Water – Potential to encounter and remediate impacted surface water due to past land use,
as well as the need to manage stormwater runoff due to potential increases in impervious surfaces.
Impact on Groundwater – Potential to encounter and remediate impacted groundwater due to past land use.
Impact on Flooding – Potential increase in stormwater runoff, which could exacerbate flood potential during
storm events.
Impact on Air – Construction and operation-related impacts associated with construction or expansion of
new businesses (i.e., dust; emissions from construction and operations-related equipment; increase in mobile
source emissions due to increased traffic).
Impact on Aesthetic Resources – Temporary construction-related lighting; changes to viewshed due to
modifications to existing buildings, demolition of existing buildings, and construction of new buildings;
potential increases in site lighting.
Impact on Historic and Archaeological Resources – Potential impacts on historic properties and/or
archaeological resources due to construction-related ground disturbances or demolition/renovation of
existing buildings.
Impact on Transportation – Increases in traffic due to expansion of existing businesses and/or creation of
new businesses; associated increase in demand for parking.
Impact on Utilities – Improvements/modifications to existing utility infrastructure to support growth.
Impacts on Noise – Temporary, construction-related noise impacts.
Impact on Human Health – Disturbance of hazardous building materials during demolition activities (e.g.,
asbestos, lead, etc.); potential to encounter impacted soil/groundwater from past land use.
Consistency with Community Character and Plans – Potential to replace or eliminate existing facilities,
structures, or areas of historic importance to the community; potential inconsistencies of new development
with the existing architectural style and character of the area.
Impacts on Solid Waste Management – Increased waste generation during construction and operations.
Environmental Justice – Potential displacement of affordable or low-income housing in NYSDEC-designated
“Potential Environmental Justice Area.”
2.2.2 Future Conditions – MVHS Facilities
Under the “No Action” alternative, the existing MVHS facilities would not be consolidated to an integrated health campus and would continue to operate and be maintained as they are at present. Under this scenario, the greatest impact would be to the community, which would not benefit from the transformative, positive impacts on regional healthcare as identified in Section 1 of this DEIS, as well as in the public need section of the CON application (see Appendix A). Anticipated benefits and positive impacts included:
The desire and need to build a facility with the newest technology, services and advancements in patient safety and quality so that our community can receive the most up-to-date healthcare services that rivals those found in large cities
The growing demand for healthcare due to the rapidly increasing and aging population in this region
The increasing need to improve accessibility and availability by attracting specialists and providing services
that otherwise would not be available to our community
The opportunity to gain greater operational efficiencies through the elimination of duplicative and redundant functions will help to reduce the rate of increase in healthcare spending and to achieve improved financial stability.
2.3 ALTERNATIVE SITES
As described in SEQR guidance materials (e.g., the SEQR Handbook31), a discussion of alternative sites is appropriate when:
A project sponsor has already evaluated alternative sites in developing the proposal for a private action, and
desires to include that analysis in the DEIS.
The suitability of the site for the type of action proposed is a critical issue, in which case a conceptual
discussion of siting should be required.
As both those considerations are true for this project, a conceptual discussion of alternative sites is included in this DEIS.
2.3.1 Conceptual Siting Study Approach
A conceptual siting study (Appendix D) was completed in June 201532, which consisted of the following four steps:
1. County-wide Site Search – Geographic Information System (GIS)-based analysis to identify parcels that could potentially host the IHC; twelve locations were identified for initial evaluation.
2. Level 1 Analysis – Using the results of the GIS analysis, initial sites were screened in a “funnel” process to identify potential “fatal flaws” (see Section 2.3.3) that warranted sites be eliminated from further consideration (i.e., “go/no go” decision).
3. Level 2 Analysis – With the fatal flaws analysis completed, a site selection matrix was created to complete a detailed screening of the top remaining sites.
4. Capacity Analysis – In addition to a detailed evaluation using the site selection matrix, a conceptual capacity analysis33 for the top three sites was prepared, which included identifying areas for hospital operations, hospital expansion areas, parking facilities (surface and structured), medical office building, and patient towers. An initial capacity concept plan was prepared for all 3 sites and two sites (Downtown and NYS Psych Center) were advanced further to consider circulation and functional entrances.
The study relied on previously completed evaluations prepared for MVHS by the Hammes Company34 (Hammes), which identified the preliminary program requirements for hospital operations.35 These requirements consisted of:
440 beds proposed (actual reduction of approx. 164 beds for 3 hospitals)
884,256 square feet (sf)36
40,000 sf Medical Office Building to be programmed as part of development
Estimated Cost: $507.7 M or $527.40/sf
Urban Site Requirements:
» 433,250 sf
» Total acreage = 10±37
Suburban Site Requirements:
» 1,927,500 sf
» Total acreage = 45±38
In addition, sites were evaluated relative to the following key parameters (Hammes 2015):
Size – can the site accommodate MVHS program objectives? Future growth potential – will the site support future growth and expansion?
Accessibility to the region – Does the location provide better access and will that access support MVHS’ role as a regional tertiary care center 39?
Patient experience/convenience – Will a hospital on this site enhance the patient experience, be convenient to MVHS customers (i.e., staff, patients, and clinicians) and enable MVHS to build a modern, healing environment?
Cost – What is the cost premium of the recommended site?
The study findings were summarized in a report, which is included as Appendix D. Additional details for each of the study steps is provided below.
2.3.2 County-wide Site Search40
A GIS-based search was performed to identify sites, which were 50-acres and larger (including multiple, contiguous or adjacent parcels) and could potentially host the new IHC. The search process did not account for: site control, current site build-out, or existing or past land uses (and associated impacts).
Parcels meeting the 50-acre threshold were identified and plotted on a base map, which included: county and municipal boundaries, Oneida County property lines (2011), and topographic relief. To illustrate the location of sites relative to the MVHS service areas, the following socio-economic data was overlaid on the “funnel map”:
MVHS Primary Service Area (PSA)41 MVHS Secondary Service Area (SSA)42 The following additional radii were overlaid on the funnel map to focus the search by identifying potential sites that might be considered as reasonably central to serve PSA and SSA customers: 10-mile radius from the approximate geographic center of Utica 5-mile radius from the approximate geographic center of Utica. Parcels were highlighted on the funnel map, which met the following criteria: Parcels ≥50‐acres43 Parcels ≥50‐acres within the 10‐mile radius and within the PSA Parcels ≥30‐acres and <50‐acres within the 10‐mile radius and within the PSA (≥30‐acre parcels were added to capture additional urban-centric sites) Parcels, which substantially meet required geographic parameters, as well as those parcels, which are not characterized by “unfavorable” environmental conditions. Based on the county-wide search parameters, the following twelve locations, which are illustrated on Figure 4, were identified for additional Level 1 analysis: 1. Yahnundasis Golf Club, Seneca Turnpike, New Hartford, NY 2. Twin Ponds Golf Country Club, Main Street, New York Mills, NY 3. New Hartford Business Park, New Hartford, NY 4. Property adjacent to SUNY Polytechnic Institute, fronting onto Route 12 South, Deerfield, NY 5. Sadaquada Golf Club, Whitesboro, NY 6. Hidden Valley Golf Club, Castle Road, Whitesboro, NY 7. Domenico's Golf Course, Church Road, Whitesboro, NY 8. Downtown - generally bounded by Oriskany Street on the south, Broadway on the east, State St on the west, and City Hall on the north 9. St. Luke’s Hospital Campus, New Hartford, NY 10. NYS Psych Center grounds Utica, NY 11. Tect Utica, Whitesboro, NY 12. Faxton Hospital-Murnane Field, Utica, NY. 2.3.3 Level 1 Analysis The twelve locations were screened in a “funnel” process to identify the potential presence of unfavorable “fatal flaw” characteristics that would warrant a site’s elimination from further consideration. Unfavorable fatal flaw characteristics are existing site conditions, which impact the developable acreage and/or increase development costs and schedule. Fatal flaw characteristics included considerations such as: Wetlands (New York State44 and potential federal45) 100-year floodplain Steep slopes (>15%; created using USGS 10m Digital Elevation Models [DEMs]) Lack of infrastructure (sewer/water) Access limitations Inadequate transportation network Other factors, including challenging permitting needs, that could adversely impact, or create major obstacles to, the development potential of the site as a hospital campus.
Figure 4: Alternative Locations
27 http://www.dec.ny.gov/docs/permits_ej_operations_pdf/seqrhandbook.pdf
28 New York Public Health Law § 2825-b.
31 http://www.dec.ny.gov/docs/permits_ej_operations_pdf/seqrhandbook.pdf 32 MVHS coordinated with Mohawk Valley EDGE (EDGE) to complete a conceptual site analysis for the proposed IHC. EDGE contracted with Elan Planning, Design, & Landscape Architecture, PLLC (Elan) of Saratoga Springs, NY to complete these services. O’Brien & Gere Engineers, Inc. (OBG), from its local office in Utica, provided sub-consulting services to Elan relative to infrastructure and environmental considerations. The work was commissioned in February 2015.
33 The complete capacity analysis, including concept plan illustrations, is provided in Appendix D. 34 Hammes Company is a healthcare project management firm that provides strategic planning, implementation and development services for capital construction projects such as hospitals.
35 While the project planning/design has progressed since 2015, several of these preliminary program requirements have been adjusted/updated, but not to a degree that would substantially affect the findings of the siting evaluation.
36 Current space in the existing three hospitals encompasses approximately 1.3 million square feet.
37 Urban site assumes vertical building construction constrained by street grid; additional land may be necessary for parking, stormwater management, and support facilities.
38 Suburban site assumes less expensive horizontal construction, not constrained by street grid. 39 A tertiary care center is a hospital that provides tertiary care, which is health care from specialists in a large hospital after referral from primary care and secondary care.
40 Although MVHS is a private, not-for-profit healthcare organization, which would typically limit alternative sites to those which the project sponsor owns or has under a purchase option (6 NYCRR § 617.9(b)(5)(v)(g)), the public need for the project, associated support via public funds, and the potential use of eminent domain to acquire property, a County-wide search was conducted. Although MVHS operates in Oneida, Madison and Herkimer Counties, the site search was limited to Oneida County, which was the focus of the Oneida County Health Care Facility Transformation Legislation, approved by the NYS Legislature to consolidate health care services and “support health care facility transformation within the County of Oneida…”
41 The primary service area is where a majority of MVHS patients originate as determined by patient encounters by zip code.
42 The secondary service area is further away from the facility and is typically associated with specific health services (i.e., cardiac, etc.).
43 Including grouping of contiguous or adjacent parcels. 44 Based on NYS Freshwater Wetland Maps published by the NYSDEC.
44 Based on National Wetland Inventory (NWI) Maps published by the US Fish & Wildlife Service.
Next Section: Environmental Setting, Impacts and Mitigation, or return to MVHS SEQR DEIS Index.
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