We have a very large site (609 acres), a lot of which is non-buildable land (open space, wetlands, slopes). There are about 1400 regular dwelling units and 460 senior housing units, in a continuum of care-type community, including everything from small SRFs for the able-bodied to a dementia unit. The senior area is at one end of the site, and it is designed with gates for motor vehicle access mostly to keep cars form whizzing through and providing a sense of safety for the elderly residents. However, the area is completely open for pedestrian and bike access.
Can the whole senior community area be treated as a health care facility and this be exempted from NPDp3? Or are we OK here because of the bike and walking trails that freely enter the site? Or do we have a problem?