​One of the justifications that JHL has given for its proposed 20-story tower on the West 97th Street Parking lot of Park West Village is that it would be the first example of the Green House (GH) model in an urban environment. There are two major problems, among others, with the proposal.
 
First, among national “small house” models, GH is significantly inflexible and its small number of residents per household severely limits reimbursement, which in turn limits staffing. The proposed plan eliminates RNs on the floor,and, in fact, limits all staff with the exception of two aides who would be responsible for cooking, housekeeping, and laundry – in addition to care of the nursing home residents. And it would have only one aide at night. GH is known all over the country for not offering activities– neither meaningful nor meaningless activities – since there simply is not sufficient staff. 
 
Secondly, one main goal of the original Green House model was to give residents the opportunity to participate in local community life, to socialize with other community members and enjoy the outdoors to the maximum possible. By locating frail, elderly residents on the upper floors of a 20-story tower, it is highly unlikely that these residents would have the opportunity to participate in local lifewhen they must wait long periods to get on an elevator.
 
In contrast, on its large existing West 106th Street property, JHL could build two interconnected 8-story wings of a nursing home.The frailest residents could be located on the lowest floors so they would be able to see street life and be accompanied outdoors. Short-stay rehabilitation individuals could occupy upper floors. And on street level, there could be a performing arts center so nursing home residents and their families and neighbors could enjoy plays, concerts, films, and lectures. The facility could become a cultural hub for nursing home and community residents – and show how a committed lower-rise urban nursing home could lead in developing a replicable national model.

JHL’s proposed 20-story New Jewish Home on the West97th Street parking lot of Park West Village presents significant concerns for the quality of life and safety of the frail, elderly people who would reside there.
 
As for quality of life, JHL’s plan would placetheir frailest, long-stay residents on top floors, while allocating rooms on lower floors for people requiring short-stay rehabilitation services. This would have the effect of severing street-level connections for resident likely to spend the rest of their lives in the high-rise tower, while allowingthose who would stay for only a month or two to with easy access to the normalcy of street-level life.
 
As for safety, there is neither a plan nor possibility of evacuation of the tower in the event of a fire or natural disaster. Fire experts have stated that elderly residents in nursing homes are at risk of dying from smoke inhalation. Evacuation from a 20-story tower is problematic when elderly residents are housed on top floors. And JHL’s proposed location is already on a heavily congested block, which takes ambulances and fire trucks as much as threetraffic light rotations to travel just the one block between Columbus and Amsterdam Avenues.
 
Manhattan is severely under-bedded in nursing home beds for people needing long-stay skilled nursing residential services, and the Upper West Side does need a nursing home. Despite this, as its response to the recommendations of the Berger Commission (2006), JHL proposed and the NY State Dept. of Health approved a reduction of 100 beds, or approximately 20 percent of JHL’s current capacity, for the proposed location.
 
JHL’scurrent building on West106th Street has deteriorated. But thatlocation, containing 2.5 acres on a wide street, allows for a lower building that would be safer for its residents, without the traffic and safetyissues at West 97thStreet. That is why it should be rebuilt on 106th Street – as originally approved by the State Health Department in 2008.

​In a New York Times op-ed piece (October 3, 2018), Philip Landrigan, the director of the Global Public Health Initiative at Boston College, and Lynn R. Goldman, the dean of the Milken Institute School of Public Health at George Washington University, warn of the dangers to children’s health by the decision of the federal Environmental Protection Agency (EPA) to place the director of the Office of Children’s Health Protection on “administrative leave” – a  signal that the EPA may close the Office of Children’s Health Protection.
 
These events are significant for the children of the Park West Village neighborhood because the proposed construction of a 20-story nursing tower on the West 97th Street parking lot by Jewish Home Lifecare, next to P.S. 163, would unleash toxic airborne dust containing lead, mercury, arsenic, barium, and other volatile chemicals. The New York State Department of Health, in its Final Environmental Impact Statement for the proposed project, stated, “The most likely routes of human exposure from the hazardous materials evaluated would occur during construction and would include the inhalation of VOCs [volatile organic compounds], the ingestion of particulate matter containing SVOCs [semi-volatile organic compounds] or metals or dermal (skin) contact with hazardous materials that can be released during soil-disturbing activities, such as excavation of soil and extraction of groundwater.” According to Landrigan and Goldman, “Exposure to chemicals is linked to a wide array of pediatric diseases. Lead and mercury can cause brain damage with loss of intelligence.”
 
The State Health Department found that although there were places on the proposed site where lead levels did exceed acceptable soil cleanup objectives, under current federal EPA standards these levels did not indicate a “soil-lead hazard.” However, a federal appeals court has ruled that the EPA’s dust-lead hazard standard is outdated and has ordered the EPA to update it. The court noted that in 2012 the federal Centers for Disease Control acknowledged that there is no known safe blood lead level and recommended a target amount that was half the EPA target amount to trigger a public health concern. To date, the EPA has not only failed to update the dust-lead standard but may be considering closing the Office of Children’s Health Protection and has eliminated the Office of Science Advisor.
 
The airborne dust from the proposed construction of the nursing home would enter P.S. 163 and the nearby Chabad Learning Center, as well as the surrounding buildings on West 97th Street and in Park West Village. The Remedial Action Plan ordered by the State Health Department imposes strict safety requirements for the workers on the proposed site, but for everyone else attending school or living in the area simply requires that “water will be available (and used as necessary) for sprinkling/wetting, to suppress dust, especially in dry weather.” This totally inadequate form of protection from airborne lead dust is an example of the way in which the State Health Department has ignored the concerns of the parents and children and neighbors of the Park West neighborhood regarding the hazards arising from the proposed construction of the nursing home.