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The Charlotte Blue Line Light Rail Extension

The Charlotte metropolitan area is one of the fastest-growing and most economically dynamic regions in the United States. Since 1990, the area has grown from 1 million residents to its current population of more than 2.3 million. With this growth, however, has come additional congestion. In response, the Charlotte Area Transit System (CATS) has sought to expand public transportation services, including the construction of light rail transit. 

The National Environmental Policy Act (NEPA) provided CATS with a process to identify the most appropriate route and transit technology combination as well as other design elements and construction practices to meet local mobility needs while minimizing social and ecological impacts.

In 2007, after years of planning and building political support, CATS opened its first light rail segment known as the LYNX Blue Line, which extends south 9.6 miles from downtown Charlotte. Within the first year of service, ridership doubled the preconstruction forecast, providing more than 18,000 weekday trips.

Following the success of the first segment, CATS and local elected officials pushed to extend the Blue Line 9.4 miles northeast to the University of North Carolina at Charlotte. Upon completion in 2018, the Blue Line extension will provide more residents with a safe, affordable, and efficient alternative to driving. Additionally, the extension will support increased residential and commercial density along the corridor, as called for in the city’s updated land use plan.

Before deciding to extend the Blue Line, however, CATS conducted a full alternatives analysis as required under NEPA. This included a review of a wide range of options, including rapid bus, light rail, streetcars, and commuter rail. From this broad set of possibilities, CATS narrowed its analysis to those options that were not “fatally flawed from an engineering or environmental perspective or would be unlikely to meet project goals and objectives.”

CATS conducted detailed analysis of several rapid bus and light rail alternatives as well as one streetcar option. The analysis determined that “The BRT [bus rapid transit] alternatives would serve existing land use patterns better than the light rail alternatives, but light rail would have more potential to support the desired shape of future development.” Thus, CATS used the transportation and land use goals established by the city of Charlotte to inform its NEPA purpose and need statement, which—along with other factors such as cost and ridership—served as the basis for analyzing project alternatives.

Initially, CATS selected a light rail alternative that would have included 13 stations, extending 10.6 miles northeast from downtown. However, due to the severe economic slowdown created by the Great Recession, CATS decided to reduce project costs by cutting two stations, scaling back structured parking, and shortening the line by 1.2 miles. In 2011, CATS adopted the revised light rail design, finding that it caused “the least damage to the biological and physical environment, while best protecting, preserving and enhancing historic, cultural and natural resources.”

As intended, the NEPA alternatives analysis process allowed CATS to answer the macro question of what project should be built to advance the defined local purpose and need. Next, CATS used NEPA to answer the micro question of how to deliver the project in a sustainable manner.

As part of the review process, CATS conducted a detailed traffic impact analysis of 55 intersections along the rail route in order to identify where the line should be grade-separated from existing roadways. For urban rail lines, grade separations affect safety, train run times, cost, intersection delays, and traffic spillover to adjacent intersections. The CATS analysis determined that the extension should include grade separations at all major intersections, railroad crossings, and entry and exit points for U.S. Route 29.37 In total, the Blue Line extension includes 11 new grade separations. For instance, the inclusion of a grade separation of the light rail line with 36th Street will allow intersection performance—known in traffic engineering terms as “intersection level of service”—to remain unchanged at the intersection of 36th and North Davidson. 

To understand the importance of including multiple grade separations, one must consider how the Blue Line extension might have looked if CATS engineers had focused narrowly on delivering fast train run times in the most cost-effective manner possible. For starters, grade separations are expensive compared with standard at-grade crossings, which only require the installation of a flashing gate. CATS could have chosen to construct the line at grade, granting trains travel priority and forcing vehicles to wait throughout the day. This approach would have saved the agency money without sacrificing train run times.

However, while at-grade crossings may save the project sponsor money in the short run, they increase roadway delay and air pollution from idling vehicles traveling within the rail corridor. As a result, the Charlotte region would suffer from reduced economic productivity and more polluted air. Fortunately, NEPA requires project sponsors to take into account how new facilities will affect safety, air quality, and roadway conditions, among other measures of community and environmental impact.

Safety is another core community impact under NEPA. This means that project sponsors must consider how a new facility may increase injuries and fatalities. A portion of the Blue Line will travel along roadways with numerous cross streets that are not signalized, meaning that pedestrian and vehicle movements are not controlled by traffic lights but by stop signs and individuals’ discretion. For roadways with few pedestrians and low traffic volumes, this approach works well. However, the presence of a new light rail line would increase development, travel demand, and pedestrian use. In response, CATS added traffic lights to fully control vehicle and pedestrian movements along U.S. Route 29, Orr Road, Arrowhead Drive, Owen Boulevard, Orchard Trace Lane, and at the University City Station. CATS notes in the environmental impact statement: “With light rail transit running in the median, safety requires traffic signals at all median openings.”

Lastly, NEPA requires project sponsors to look at how a proposed facility will affect low-income communities and communities of color. This mandate stems from a sober and honest recognition that the location, scale, and design of infrastructure facilities have historically affected poor or otherwise disadvantaged neighborhoods at disproportionately high rates.41 In short, the choice to build an infrastructure project can itself be a form of discrimination. This impact may take the form of increased pollution and noise; increased household costs; reduced transportation access; or the loss of local businesses, housing, religious institutions, and social service providers through eminent domain, among other impacts.

As part of the environmental review process, CATS was required to conduct both a demographic analysis based on census data and an extensive inventory of community assets. The Blue Line extension will run through several neighborhoods in which residents are predominantly people of color with incomes that fall substantially below the area’s median household income.

In order to construct the Blue Line, CATS had to acquire 90 acres of land, resulting in the displacement of 14 commercial or industrial businesses but no residential displacement. CATS found that none of the businesses “provide a unique or special service to a community of concern.” Therefore, the project’s most significant impact would be increased noise and vibrations. Eleven residential homes were expected to face a significant increase in noise or vibration. These impacts are considered adverse “due to the intensity of the impacts and disproportionate as no residential noise impacts would occur outside of minority and low-income communities of concern.” In response, CATS made changes to the project design to include the installation of “an automated friction modifier, noise barriers, sound insulation, specially-engineered track work and vibration isolation treatments.”

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Everglades Parkway: the I-75 extension through Alligator Alley

Following the passage of the Federal-Aid Highway Act of 1956, the United States began a national program of highway construction to facilitate more efficient connections between metropolitan areas and provide farmers with better access to local markets. The act authorized the construction of a 41,000-mile system. In 1968, Congress passed another highway bill to expand the interstate system by an additional 1,500 miles. The legislation included an authorization to extend Interstate 75 (I-75) south and east from Fort Myers on the Gulf Coast to an area west of Fort Lauderdale on the Atlantic Coast. The 114-mile extension would become known as the Everglades Parkway.

In 1969, the Florida Department of Transportation (FDOT) began to study alternative routes. Unlike the planning for earlier interstate segments, FDOT was required to comply with the newly-passed National Environmental Policy Act (NEPA). As a result, the I-75 extension included numerous design elements tailored to minimize impacts on the natural environment. Importantly, none of these design elements undermined the original goal of the project: to construct a limited-access, four-lane, divided highway that would connect Gulf and Atlantic Coast population centers, providing increased travel speeds and reduced travel times. 

Large infrastructure projects such as the I-75 extension present states with many technical challenges. Engineers must determine everything from pavement type and interchange design to the sharpness of curves and how to prevent rainwater from forming unsafe pools on the roadway. These challenges share a common thread: They are all related to the design of the roadway. Prior to NEPA, engineers focused narrowly on how to design a facility as opposed to how that facility would affect the surrounding community or natural environment. Part of NEPA’s value is that it requires planners and engineers to widen the aperture of concern. Environmental review necessitates that state and local governments solve the engineering puzzle in a way that minimizes the negative spillover that often accompanies major infrastructure projects. 

Improving flow involved several design modifications. According to FDOT design policy at the time, highways were required to provide at least 100 feet of land between the edge of the roadway and any adjacent body of water. This requirement was intended to reduce the risk of passengers drowning in the event that a driver loses control of a vehicle. In effect, the 100-foot buffer provided a chance for a driver to slow the vehicle and regain control, hopefully avoiding entering the water. In the case of the Everglades Parkway, complying with this requirement would have meant draining additional wetland on either side, further impairing critical habitats and the sheet flow of fresh water. Instead, FDOT chose to waive this policy and add a cable barrier where necessary. The cable barrier would stop wayward vehicles before they reached the water. 

FDOT’s final significant modification dealt with the channels running parallel to the highway on either side as well as the connections spaced at regular intervals that connected the channels on the north and south side of the highway. Experience with the channels along the original State Route 83 showed that the state needed to both modify their depth and regularly remove aquatic vegetation that could reduce sheet flows by as much as 90 percent. FDOT also scheduled construction activity to avoid the heaviest seasonal rains. By adjusting the sequence and timing of work, the state was able to significantly reduce sedimentation—rainwater carrying dirt, rocks, and other loose debris from the construction site into the wetlands.

The environmental review process provided FDOT with the information necessary to make smart and effective changes to the design, construction, and maintenance of the Everglades Parkway, all with an eye toward reducing harmful impacts on the surrounding ecosystem. Far from being a burden, NEPA brought forward the technical expertise of scientists across numerous fields to help the state build a fundamentally better, more sustainable facility that continues to provide benefits to this day.

 

[1] “Environmental/Section 4(f) Statement Interstate Route 75: State Road 82 near Ft. Myers in Lee County to U.S. Route 27 at Andytown in Broward County” Florida Department of Transportation. August 25, 1972.

[2] Florida Wildlife Federation v. Goldschmidt, 506 F. Supp. 350 (S.D. Fla. 1981). Available at: https://law.justia.com/cases/federal/district-courts/FSupp/506/350/1653901/

[3] August Burghard. Alligator Alley: Florida’s most controversial highway. (Washington: Lanman Company, 1969).

[4] “Final List of Nationally and Exceptionally Significant Features of the Federal Interstate Highway System.” U.S. Department of Transportation, FHWA. Available at: https://www.environment.fhwa.dot.gov/env_topics/historic_pres/highways_list.aspx

 

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Disaster averted: California’s Bolinas Lagoon

Located 15 miles northwest of San Francisco between the communities of Bolinas and Stinson Beach, Bolinas Lagoon and its ecosystem provides a rich habitat for shorebird and waterfowl, fish, and special-status plants and animals. It also provides an important habitat for several endangered species including the steelhead and coho salmon that move through the lagoon on their journey upstream to spawn within the lagoon’s watershed.

In 2006, the US Army Corps of Engineers proposed dredging nearly 1.4 million cubic yards of sediment from the lagoon, claiming the project would preventing the lagoon from silting in.

The subsequent environmental review, conducted under the National Environmental Policy Act (NEPA), told a very different story. It found the Bolinas lagoon was not at risk of silting and that the proposed plan would have actually increased siltation and degraded the lagoon’s water quality. 

As a result, the misguided plan was abandoned, saving taxpayers $133 million.  The non-federal sponsor then worked with scientists, local stakeholders, environmental groups, and state and federal agency representatives to develop a series of community-supported recommendations for the restoration and management of Bolinas Lagoon that were finalized in 2008. 

Thanks to NEPA, a disastrous Army Corps of Engineers project was abandoned and the Bolinas lagoon remains one of the most pristine tidal lagoons in all of California.

The NEPA review process exposed the devastating impacts of the Army Corps of Engineers’ plan to dredge the Bolinas Lagoon, one of the most pristine tidal lagoons in California. While the Army Corps claimed that the dredging project would prevent the lagoon from silting in, the environmental review process found that the lagoon was not at risk of silting in and that the proposed plan would actually increase siltation significantly degrade the lagoon’s water quality. 

 

[1] “Draft Environmental Impact Statement: Bolinas Lagoon Ecosystem Restoration Project Feasibility Study.” U.S. Army Corps of Engineers. June 2002. Available at: https://www.marincountyparks.org/~/media/files/departments/pk/projects/open-space/bolinas-lagoon/draft-bolinas-lagoon-ecosystem-restoration-feasibility-study-and-draft-eir-eis.pdf

[2] “Bolinas Lagoon Ecosystem Restoration Project: Recommendations and Restoration Management.” A Working Group of the Sanctuary Advisory Council Gulf of the Farallones National Marine Sanctuary. August 2008. Available at: https://www.marincountyparks.org/~/media/files/departments/pk/projects/open-space/bolinas-lagoon/bolinas-lagoon-ecosystem-restoration-project—recommendations-fo-restoration-and-management.pdf

 

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Montana’s Route 93

For years, US-93, located north of Missoula in western Montana, saw an increase in traffic fatalities and injuries on a heavily traveled stretch heading toward Glacier National Park.

To address concerns, the Montana Department of Transportation (MDT) proposed to widen a 56-mile segment from two lanes to a five-lane undivided highway. This segment runs through the Flathead Indian Reservation, including territory in the heart of the Rocky Mountains – a popular recreational destination – and the Ninepipe Wetlands Area, which supports unique and fragile species of wildlife. 

Thanks to the National Environmental Policy Act, Confederated Salish and Kootenai Tribal Government, and citizen groups had the opportunity to participate in the project design process. Under NEPA, federal agencies are required to make and evaluate EIS reports in order to determine the consequences of a proposed action, analyze action alternatives, and share the results with other agencies and the public.

The Confederated Salish and Kootenai tribal government and grassroots citizen groups such as Flathead Resource Organization (FRO) challenged MDT, first on the validity of the initial Environmental Assessment (which evaluated only a seven-mile stretch of the 56-mile project), and later on the Environmental Impact Statement (EIS).

In essence, by forcing MDT to carry out an environmental review, tribal members and concerned citizens made MDT look for creative solutions and consider alternatives for the highway that could negatively affect safety, environmental issues, and lack of protection for tribal culture and family farms.

Amanda Hardy, research ecologist at the Western Transportation Institute at Montana State University, was involved with the design and evaluation of the wildlife crossings. She said NEPA allowed “the public and agencies an opportunity to comment” so alternatives like these could be pursued.

“US-93 became a project dramatically different than what the DOT had ever done,” said Sipes. “NEPA gave us more weight so our voices could be heard — without it, US 93 would have been a standard four-lane highway with destructive impacts to the community,” she added.

The final design successfully addressed all safety, environmental, and cultural concerns. Slow curves in the roadway were planned along the most scenic areas to discourage speeding and follow the contour of the land. One mile of the highway was relocated around the Ninepipe Wetlands area and wildlife crossings and fencing were added at the request of the Tribes to make the roads safer for commuters and wildlife.

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Saving Puerto Rico’s El Yunque Rainforest

At just under 30,000 acres, El Yunque is our country’s smallest national forest and the United States’ only tropical rainforest in the national forest system. For Puertoricaños, El Yunque is a cultural jewel, largely as a result of its unique Taíno petroglyphs (rock engravings) made by their ancestors – the Taino people.

Puertoricaños were understandably upset when the Federal Highway Administration (FHWA) proposed to slice the preserve in half to rebuild a long-closed portion of Highway PR 191 (“Highway 191”) back in 1992.

Citing a ten-year-old Environmental Assessment (EA) dating back to 1982, FHWA determined that an EIS was not essential for deciding whether to reopen the road and issued a “Finding of No Significant Impact” (FONSI) to continue with the construction project. In failing to complete a full environmental review, FHWA sought to willfully ignore the proposal’s potential impacts on the island’s endangered species as well as the increased likelihood of rock slides.

When a court found that FHWA had circumvented the National Environmental Policy Act (NEPA) review process, the judge promptly ordered that a full environmental impact assessment should be carried out before any construction began. FHWA subsequently decided to drop the project rather than undertake the study and disclose the project’s full impacts on El Yunque rainforest.

Today, the rainforest remains intact and the drive around it to the new Forest Service recreation area on its far side takes a mere 25 minutes on existing roads.

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Seismic Surveys in Clark, Wyoming

In 2004, Windsor Wyoming Inc. proposed a seismic survey on land owned by the Bureau of Land Management (BLM), the Forest Service, and private landowners. The environmental analysis called for the drilling of 3,420 seismic shot holes in a 47-mile area surrounding Wyoming’s Clark River – the state’s only designated Wild and Scenic River.

Under the proposal, explosive charges would be fired into the holes to create a 3-D picture of the area’s available resources. After reviewing the draft plan, nearby private property owners represented by Powder River Basin Resources Council — a bipartisan community group — noted that it failed to consider how these explosions would affect scarce water resources, elk and other game species, hunting opportunities,

“I am against all this blasting because of the danger to the water wells,” resident Art Lovell said at the time.

“Most people are concerned about the water,” said another local resident. “We depend on water.”

This public input led BLM to re-examine the initial environmental assessment and consider the use of a new survey technology called “passive seismic” to mitigate the damaging effects of the explosive charges. Agency officials readily admitted it was public involvement that brought these issues to the forefront and pushed BLM to consider alternatives.

Thanks to NEPA, local residents, land managers, and industry achieved a seismic exploration plan that protected game species, tribal sites, private property rights, and critical water resources.

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A road map to smart decision-making: Michigan’s US-23

In the early 1990s, the Michigan Department of Transportation (MDOT) strongly pushed for the construction of a four-lane freeway parallel to the existing two-lane US-23. The expansion would have rerouted US-23 through undeveloped country in the northeastern part of the state, causing the largest single wetlands loss in Michigan and severely compromising protected wildlife habitat, state and national forestland, coastal wetlands, and the Au Sable River Corridor. Friends of the Earth went so far as to list the US-23 expansion among the nation’s “Fifty Most Wasteful Roads in America.” 

Residents opposed the expansion, instead preferring to fix the existing highway by adding passing lanes and making other safety improvements. “Right from the start, that was our whole focus: Fix what we have and don’t build a new, billion-dollar freeway,” said Paul Bruce, founder of People for US-23 Freeway Alternatives, a citizens’ group in Alpena. The original draft Environmental Impact Statement, made public in 1995 only considered only two choices: build the extension or do nothing.

Upon discovering MDOT’s lack of due diligence and failure to fully consider other project alternatives, the Federal Highway Administration stepped in and rejected the proposal, instead directing MDOT to upgrade the existing highway or study the creation of a less-damaging boulevard. The largest and most expensive project canceled in Michigan’s history, FHWA also recommended resident-supported alternatives such as the addition of passing lanes and turn lanes and traffic signal upgrades.

Kelly Thayer, transportation project coordinator at the Michigan Land Use Institute, said the intervention called it a huge success. “NEPA kept alive the public’s opportunity to give input,” said Thayer.

Thanks to the NEPA process, Michigan taxpayers saved over $1.5 billion and local communities were spared the devastating impacts of unneeded and unwanted expansion.

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Arkansas’ Shady Lake Recreation Area

Buried deep in Arkansas’ Ouachita National Forest, the Shady Lake Recreation Area includes more than 90 campsites, a swimming beach, a playground, hiking trails, a picnic shelter, and a grass boat ramp. It’s ideal for day hiking.

The existing Recreation Area entrance road, FS 38 (also known as Caddo Road, Shady Lake Road, or County Road 64) was constructed by the Civilian Conservation Corps in the 1930’s and traveled through several private properties before entering Forest Service land. Seasonal high use of the entrance road resulted in high traffic volume that causes conflicts with the private property owners. 

For this reason, in 2011 the Forest Service proposed constructing a new entrance road to the Shady Lake Recreation Area to improve visitors’ experiences, provide safe vehicular access, and minimize conflicts with local residents living nearby.

While the Federal Highway Administration and Forest Services’ original Environmental Assessment proposed that the new visitor entrance should not be opened until the multi-phase project was complete, following public input mandated by the National Environmental Policy Act (NEPA), the Federal Highway Administration and Forest Service decided to open the new road to public traffic upon completion of the project’s first phase.

The decision ensured that visitors would be able to effectively access the area and that nearby residents would benefit from diminished traffic as soon as possible.

 

[1] “Environmental Assessment for the Construction of a New Entrance Road to the Shady Lake Recreation Area” U.S. Federal Highway Administration. July 2011. Available at: https://flh.fhwa.dot.gov/projects/ar/shady-lake/documents/EA-159-1(2).pdf

[2] “Finding of No Significant Impact on the Environmental Assessment for the Construction of a New Entrance Road to the Shady Lake Recreation Area.” U.S. Federal Highway Administration. October 3, 2011. Available at: https://flh.fhwa.dot.gov/projects/ar/shady-lake/documents/fonsi.pdf

 

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NEPA protects the Grand Mesa, Uncompahgre, and Gunnison National Forests from clear-cutting

In 1989, the U.S. Forest Service was all but ready to approve a plan to clear-cut every aspen grove in the Grand Mesa, Uncompahgre, and Gunnison National Forests in western Colorado. The timber was to supply a waferboard plant operated by Louisiana Pacific Corporation.

A combination of three separate National Forests located on the western slope of the Colorado Rockies, the Grand Mesa, Uncompahgre, and Gunnison National cover some three million acres of public land south of the Colorado River that make for some of the most spectacular scenery in the Rockies.

The Forest Service’s plan was rightly met with outrage from the public, who argued that the scenery, wildlife habitat, and water quality in the forests essential to the region’s quality of life and recreation-based economy could be gravely damaged. 

Clearcutting operations have historically increased the risk of large, unnatural fires by removing the largest and most fire-resistant trees from forests and can have profound impacts on local rivers. Clearcutting also destroys habitat for a wide variety of animals, including many endangered species.

After receiving a record-setting number of letters during the National Environmental Policy Act’s (NEPA) mandated public comment period from private citizens, businesses, and local officials, the Forest Service substantially scaled back its clearcutting proposal. Forest Service rangers and scientists acknowledged that the initial proposal was more than the land could bear, but said they had felt pressured to “get the cut out.” Absent the NEPA public review process, hundreds of thousands of acres of majestic Rocky Mountain landscapes would have disappeared.

By demanding that federal decisions are made based on the best available science, NEPA ensured that no single use or priority eclipsed another.

 

[1] “Amendment of the Land and Resource Management Plan and Final Supplement to the Environmental Impact Statement.” USDA, Forest Service. September 1991. Available at: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev7_003093.pdf

[2] “Final Supplemental Environmental Impact Statement: Grand Grand Mesa, Uncompahgre, and Gunnison National Forests.” USDA, Forest Service. July 1, 1991. Available at: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev7_003097.pdf

 

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A NEPA success story: Canyons of the Ancients National Monument

Designated as a National Monument in 2000 by President Clinton, Canyons of the Ancients in southwestern Colorado is home to the highest known density of archaeological sites in the United States. Home to some 6,000 archaeological sites representing Ancestral Pueblan and other Native American artifacts, its designation was necessary to protect the sites from vandalism and looting, oil and gas development, and destructive grazing practices.

As a result of its designation as a National Monument, existing oil and gas leases on the land were permitted to run their course, but they would not be renewed after their current term expired.

On the eve of the lease’s expiration in 2002, however, lessees proposed a new seismic exploration project for the land that would have resulted in catastrophic damage to numerous archeological sites.  In an effort to protect these irreplaceable areas, a coalition of groups led by San Juan Citizens Alliance filed suit in federal district court and were granted an emergency injunction on the grounds that the Bureau of Land Management’s (BLM) original Environmental Assessment was based on inadequate cultural resource surveys, and, as a result, allowed exploration on the edges of several sensitive sites, including standing “towers” and multiple collections of artifacts.

As mandated by the National Environmental Policy Act (NEPA), BLM facilitated negotiations between a diverse number of stakeholders including local government, conservation groups, and the lessees to work out a compromise that reflected local input and consensus.

The result was an exploration project that enabled lessees to obtain the seismic information they needed while avoiding the National Monument’s most significant cultural features and fragile habitats. It was a rare win-win that exemplified effective multiple-use management of the public lands, balancing energy exploration with cultural resource protection.

What’s more, economic data shows that in the decade since the National Monument’s designation, Montezuma County has experienced strong economic growth. The Monument has not impaired natural resource extraction outside the Monument’s boundaries and travel and tourism continue to grow.

 

[1] “New Energy Project at Monument.” Los Angeles Times. August 13, 2002. Available at: http://articles.latimes.com/2002/aug/13/nation/na-drill13

[2] “Energy Exploration Approved in Colorado Monument.” Institute for Agriculture and Trade Policy. September 25, 2002. Available at:
https://www.iatp.org/news/energy-exploration-approved-in-colorado-monument

 

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