V3 RESUBMISSION ENVIRONMENTAL IMPACT STATEMENT Rev 2 Dated 11 03 2022

ENVIRONMENTAL IMPACT STATEMENT PREPARED FOR DAUGHTERS OF ISRAEL 1155 PLEASANT VALLEY WAY LOT 12, BLOCK 171 SUBMITTED TO: WEST ORANGE ZONING BOARD OF ADJUSTMENT PREPARED BY: PETRY ENGINEERING, LLC 155 PASSAIC AVENUE FAIRFIELD, NEW JERSEY 07004 OCTOBER 29, 2021 REVISION 1: MAY 18, 2022 REVISION 2: NOVEMBER 3, 2022 155 Passaic Avenue, Suite 350, Fairfield, New Jersey 07004 973-227-7004 963-227-7074 (fax) www.petryengineering.com

INTRODUCTION This Environmental Impact Statement was written as part of an overall redevelopment plan for the existing Daughters of Israel (DOI) property which is located at 1155 Pleasant Valley Way in the Township of West Orange in Essex County, New Jersey. This report was prepared by Petry Engineering and has considered all environmental regulations that have been outlined by the necessary authorities of the Local, State and Federal government. Petry Engineering, LLC has performed a detailed review of the West Orange Land Use Regulations as well as the Essex County Site Plan Standards. In addition, we have reviewed the NJDEP GeoWeb mapping for the area to establish potential constraints and regulatory requirements. Since the property is currently developed and has been functioning as a Skilled Nursing Facility for many decades, the property is significantly disturbed. The proposal that is before the Board calls for redevelopment that is almost exclusively within previously-disturbed areas. Based upon information contained in the GeoWeb, our firm engaged an outside consultant to perform a review of potential wetlands within the wooded area in the rear of the parcel. The determination was made that there are no on-site wetlands within the subject property. Offsite wetlands and their associated transition areas are well beyond the limits of our proposed disturbance. As part of the approval process, Daughters of Israel will be required to seek approvals from the Township of West Orange Zoning Board of Adjustment, the Essex County Planning Board, and the Hudson-Essex-Passaic Soil Conservation District (which issues the Soil Erosion Control Permit and RFA). In addition, the project may be subject to NJDEP Permits for the redevelopment of the property which include Treatment Works Approval (Sewer Permit) and NJDEP BSDW (Water Extension Permit). 2

The plans and this report have been revised since this application was originally submitted to the Board for their consideration. These changes are as a direct result of the Site Plan Advisory Review Committee meeting and the Board Engineer’s comment letter dated June 20th. The most significant change to the plans is that the overall disturbance footprint has been reduced. This has led to a reduction in the amount of steep slope disturbance along the northern, western, and southern portions of the property. Subsequently, this resulted in a reduction in the number of trees to be removed. The previous application called for 395 trees to be removed, whereas the proposed plan calls for only 232 trees to be removed (40 of which are dead), resulting in the removal of only 192 live trees. EXISTING CONDITIONS Daughters of Israel is a licensed nursing home that is licensed for up to 303 beds. The facility sits on a campus setting that contains approximately 18 acres of land. It is located along the westerly side of Pleasant Valley Way, just south of its intersection with Route 10 (See Fig. 1). The parcel is directly across the street from the Essex County Golf Course (Byrne) and includes two separate driveways for ingress and egress (See Fig. 2). The parcel is bordered to the south by Kessler Institute for Rehabilitation as well as the Kessler Foundation. It is bordered to the north and to the west by a residential development that includes Parson Drive and Skyline Drive. Approximately 60 percent of the property is currently developed, while the remaining 40 percent is primarily wooded buffer located along the abutting properties (See Fig. 3). Within the developed portion of the property, there are a series of buildings that are interconnected, having been constructed over several decades. These buildings are serviced by an asphalt parking lot that includes a total of 236 parking stalls. We note that DOI has several vehicles, one of which is utilized as a shuttle for employees to and from public transportation and others are strictly for deliveries. All vehicles are stored on-site when not in use. 3

Over the past 20 years, the maximum occupancy of the facility was between 270-280 residents. Over that same period, the maximum staffing on any given shift at the facility was approximately 250 employees. The impact of Covid-19 has caused a significant reduction in both the number of residents and the associated staffing. PROJECT DESCRIPTION The proposed development has been designed to accommodate an Age-in-Place community that will allow its community members the opportunity to be part of a continuum of care facility that offers independent living, assisted living and skilled nursing units all under one roof. The goal of the project is to allow a portion of the existing nursing home to remain functional while the remainder of the project is constructed. This will require the removal of a number of the existing buildings and a staged coordination of the development. The project will be completed in several phases, which will remove and replace the existing buildings on the site as the existing buildings are able to be isolated and removed. (The site plans accompanying this application include a Phasing Plan which shows generally how construction will be phased.) The construction will include a complete reconstruction of the parking area. The proposed development will be completed within the same general development limits as the existing development. The new development will be comprised of the following: 85 one- bedroom independent living units, 97 two-bedroom independent living units, 64 assisted living beds, and 80 skilled nursing beds. It will include parking for 266 vehicles in a surface lot as well as 115 parking spaces for Independent Living residents in a covered parking lot beneath the building (See Fig. 4). COMPATIBILITY WITH PLANNING DOCUMENTS The existing development represents a non-conforming use within the existing R-2 zone. West Orange Zoning only permits Nursing Homes as conditional uses in several zones including RT, RG, RM 7 OB-1 zones. 4

The proposed use blends the Nursing Home use with an Assisted Living Use and Independent Living use to establish an Age-in-Place facility. Overall, the proposed use is not defined in the ordinance, but from a planning perspective, it represents a use that is more residential in character than the existing use. As such, it becomes marginally closer to compatibility with the existing Zone Plan and Zoning Ordinance. INVENTORY OF EXISTING ENVIRONMENTAL CONDITIONS The existing property was mapped for Steep Slopes as part of this submittal. Included in the appendix of this report is the Steep Slopes Analysis (Fig. 5) and the Steep Slopes Map (Fig. 6). These two documents have been prepared based on the survey that accompanies the application, which provides more detail than the ordinance requires. A significant portion of the existing property is mapped as Steep Slopes. The majority of that steep slopes area is the original woodland that separates the existing use from the abutting neighboring properties. A portion of the steep slopes area is the existing front lawn area and lawn/stormwater management area that separates this property from the adjacent Kessler property. Overall, the redevelopment remains within the existing disturbed areas. While minor areas of the steep slopes are being disturbed, the vast majority of the existing wooded buffer will remain in their natural state. The steep slopes figures have been revised to include the steep slopes exemptions outlined in §25-28c. Based on the existing improvements and review of historic aerials, the majority of the front portion of the site has been disturbed over time due to the construction of the existing improvements and associated grading activities. As shown on Fig.-6 very the proposed development complies with the allowable disturbance to steep slopes for all of the slope categories except for slopes greater than 25%. The ordinance does not allow any disturbance within this area. The proposed plans 5

call for 2% of slopes over 25% to be disturbed, which is less than 5,000 square feet. The majority of this disturbance is proposed in the location of the new retaining walls which will help stabilize the steep slopes behind the wall. AREA AND REGIONAL DESCRIPTION West Orange is centrally located in Essex County with nearby access to both NJSH Route 10 and Interstate 280. The area is well served by public transportation and provides easy accessibility to virtually anywhere in the tri-state area via highway connections. The subject property is located along Pleasant Valley Way (County Route 636) which is an Arterial Roadway under Essex County Jurisdiction. The existing development includes two driveways that provide access to the existing 236-space parking lot. These driveways provide access to staff, visitors and service vehicles that utilize the site daily. A detailed Traffic Study is included as part of the overall submittal. ASSESSMENT AND MITIGATION OF THE ANTICIPATED IMPACT OF THE PROJECT Soils – While significant re-grading is proposed, there are no changes to the on-site soil types. An initial investigation has been performed to identify depth to rock within the existing disturbed areas. This investigation identified high bedrock in the southwest areas of the existing building. Rock elevations dropped moving both easterly and northerly, as the front portion of the site appears to have been filled over the course of construction. In an effort to limit rock removal, the proposed main floor elevation of the new building has been elevated about twelve inches above the existing main floor elevation. The lower floor area has been dropped in the easterly portion of the building to limit the building height. Along the easterly facade, the building is located in fill material. 6

Wetlands and Waterbodies – NJ GeoWeb indicates that there is potential for wetlands in the wooded area to the rear of the existing parking lot. Due to these findings, we engaged an environmental consultant to conduct a study on the site. The study was performed by Vincent Agovino, Phd, PWS and it was determined that there are no wetlands present at the site of Daughters of Israel. Wetland areas within the rear wooded portions of the Kessler property were well beyond the limits of disturbance associated with this proposed project, even when one considers the potential transition areas associated with those wetlands. No portion of the property is categorized as flood plain. Water Quality – The proposed development calls for a reduction in motor vehicle surface. As such no water quality treatment is required at the site. This conclusion is made based on the most recent NJDEP stormwater regulations and standards which incorporate water quality as one of the components. Groundwater Pollution – No Changes Sewage Disposal – The existing property is serviced by an 8” sanitary sewer lateral that provides for discharge to the West Orange system in Pleasant Valley Way. The existing Nursing Home (Skilled Nursing Facility or SNF) produces a total of 37,875 gallons per day based upon the NJDEP projections (125 gpd/bed) for a 303-bed nursing home. Those same criteria show the proposed project would generate 50,975 gallons per day for the proposed use (based upon 150 gpd for each 1-bedroom, 225 gpd for each 2-bedroom, 100 gpd for each Assisted Living Facility (ALF) bed and the same 125 gpd for each SNF bed). Based upon the increase in residential units, the proposed project will require an NJDEP Treatment Works Application (TWA) for sewer extension. Solid Waste Disposal – Both the existing facility and the proposed facility will be serviced by private haulers. They will continue to provide for separated recycling and will continue to utilize 7

a compactor for trash. While there will be an increase in unit count, the anticipated removal schedule will likely remain unchanged. Vegetation – The proposed project calls for the removal of approximately 232 trees as defined by the ordinance (40 of which are dead), resulting in removal of 192 live trees. The majority of those trees are in existing disturbed areas and are part of the overall landscape of the built environment. A complete tree removal plan has been prepared and accompanies the Tree Removal Application that was simultaneously submitted with the application for development. The proposed Site Plan includes a Landscape Plan, prepared by the architectural firm, that incorporates replacement trees and shrubs. Wildlife – Because the existing wooded buffer will remain largely untouched, there should be no affect on the wildlife that utilizes that area for habitat and/or foraging. Unique, Scenic & Historic Features – The site is not identified as Unique, Scenic or Historic Air Quality Degradation – The proposed site improvements include Soil Erosion and Sediment Control measures to protect against sediment as well as dust control. The measures called for are accepted by the State as reasonable solutions for the short-term impacts of construction. We do not anticipate any long-term impacts as the proposed use is dominantly residential in character and this type of use poses no real impact to air quality. Noise – Short-term impacts of construction are generally not considered permanent impacts. The construction hours will be limited in accordance with the Municipal Ordinance requirements. In this instance, it is anticipated that the demolition and construction may be phased, causing these impacts to extend longer to accommodate the phasing. However, the long-term impacts are limited due to the type of use proposed. 8

Items like roof-mounted HVAC equipment will be screened, which provides for sound attenuation. This is in contrast to the equipment servicing the existing building, which is both old and largely un-screened. Neighborhood Deterioration – There are no anticipated impacts on the neighborhood associated with this project. Access will remain via the existing driveways on Pleasant Valley Way. Construction access will utilize those same driveways. All work will be performed from the existing disturbed areas. The wooded buffer that abuts the northerly and westerly property lines will remain. Public Services – No Changes Traffic Report – A traffic report prepared by Dynamic Traffic, LLC has been submitted to address traffic conditions. Health, Safety and Welfare of Existing Residents – The existing occupants of the Nursing Home will remain in place during the course of construction. There are no anticipated health, safety and welfare issues associated with the construction that cannot be addressed utilizing standard OSHA measures. The surrounding neighborhood will be largely unaffected from a health, safety and welfare perspective due to the design steps taken to limit rock removal, as well as the stormwater management and utility design efforts that are included in those documents. ALTERNATIVES The existing Daughters of Israel facility is an older model facility that has exceeded its life expectancy. In order to remain active, the facility needs a complete overhaul. This particular approach was chosen by the DOI Board, since it provides the best opportunity for the facility to 9

remain feasible for the coming decades. Failure to move forward with a redevelopment of this type would ultimately lead to a continued decline of the facility until such time as it became financially impossible to operate. If this facility were to be obsolete, one would likely see another use come in for a redevelopment of the entire property. Because of the existing facilities and the uses permitted within this zone, the logical alternative would likely be for a hospital use. In the alternative, a senior citizen housing use is permitted within this zone. Either of these two alternatives would require extensive rehabilitation and/or expansion of the existing buildings. Another option would be to demolish the entire site and provide for residential uses. While it is highly unlikely that a developer would consider detached single-family homes on the property, it is possible that this alternative could be considered. It would likely involve the destruction of the existing wooded buffer and construction of a series of tiered walls to accommodate the steep slopes. Finally, a conditional use that could be accommodated on a site of this size, would be a House of Worship. Given the overall size of the property, a large house of worship could be constructed and meet the required setbacks set forth in the conditional use requirements. One would anticipate a plethora of accessory uses that would be incorporated into a site of this size, should that alternative be selected. In this writer’s opinion, the alternatives to the proposed development would likely cause equal or greater impact on the environment while bringing little in terms of community service to the area. As such, we offer that the proposal before you represents the most reasonable approach for the redevelopment of the property. LICENSES, PERMITS AND APPROVALS The subject redevelopment project requires the following approvals: 1. Township of West Orange Zoning Board of Adjustment 2. Essex County Planning Board – Site Plan Approval 10