Environmental Assessment Factors Case Study

Aerial view of Town with houses, cars, and trees

Overview

This case study provides details on a hypothetical project and lists the findings from simulated environmental assessment factors and analysis to demonstrate how an environmental assessment should evaluate the impact on different factors and categories that may be affected. The analysis and decision-making presented in this case study pertains to environmental assessments under 24 CFR 58.36 or 24 CFR Part 50 Subpart E, conducted by environmental review preparers such as responsible entities, recipients, applicants, and partners.

  1. Read the background on this new development project in the Town of Green.
  2. Explore the environmental assessment factors and categories to consider:
    • What is the affected environment?
    • What is the impact evaluation?

Background: Town of Green Development Project

The development team proposes to create a new 10-unit multi-family residence on a single 0.6-acre parcel in the Town of Green. The parcel is located within an area zoned for multi-family units and noted within the Town of Green Comprehensive Plan mixed land use (residential and commercial). The property consists of a vacant lot located between a 12-unit multi-family home and a 10-unit mixed-use complex consisting of residential spaces on the upper floors and a commercial storefront on the lower level. Off-street parking is available for use by potential residents and visitors, although 10 spaces will be provided to the rear of the building with alley access. The lot provides for the necessary utility connections (electrical and water).

The new 10-unit multi-family residence will be affordable housing and will not contain commercial uses. As currently designed, the proposed project will consist of one building that is three stories in height and contains 10 multi-sized units. The development of this parcel is anticipated to be only one of several planned developments on vacant lots located throughout the Town of Green.

The subject parcel is within a section of the Town of Green where the need for affordable housing is on the rise. The parcel is located proximate to public transportation, retail, and community services. The Town of Green is encouraging the development of affordable housing that accounts for transit-oriented development goals and the potential to serve lower-income families. The Town of Green prides itself on its small-town character and its goals to preserve its natural amenities.

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Environmental Categories and Factors to Consider

Review each environmental assessment factor and category as they relate to the new development project in the Town of Green.

To jump to a specific factor or category, use the "Find by Category" tool.


Land Development

Want to learn more? Explore the Land Development Category of the Environmental Assessment eGuide.

Environmental Assessment Factor Impact Code Impact Evaluation Mitigation

Conformance with Plans/Compatible Land Use and Zoning/Scale and Urban Design
(2) No Impact Anticipated

The subject parcel will be located on a single lot of approximately 0.6 acres (26,136 square feet) and is located in a residential/commercial neighborhood and a multifamily residential zone which allows for commercial development (i.e., mixed use). The parcel is currently vacant.

The proposed development will be proximate to retail stores, a community center, and multiple bus routes with daytime and evening service. On-street parking is available for existing commercial uses; residential parking tends to be located with alley access.

In its Comprehensive Plan, the Town of Green notes the need for higher-density uses of vacant land, but the town encourages structure development of no greater than a height of six stories to be consistent with the small-town community character.

The development team has proposed a project that is consistent with the Town of Green Comprehensive Plan. The project encourages a higher-density development through the proposal of a multifamily residence, and it adheres to the community zoning ordinance as it will only be three stories in height. In this manner, the building will help to maintain the community character and will not detract visually from the other existing units.

Parking will be offered to the residents; however, this will be located to the rear of the structure. This will limit the amount of traffic on the main street in which the parcel is located. The use of private parking spaces will also limit the use of off-street parking for the residents of the multifamily residence.

 

Soil Suitability/Slope/Erosion/ Drainage/Stormwater Runoff

(3) Minor Adverse Impact

The subject parcel is located on a vacant lot; the current surface consists of crumbling asphalt pavement. When it rains, water pools at the southern end of the parcel. The rainwater rushes to the municipal drainage system; however, the system is almost at capacity. Heavier rainfall projected for the future due to climate change may exacerbate this problem.

Observations of nearby properties suggest that some water issues are present as the stairs leading to the entrances appear to be pulling away from the main buildings. The surface slopes away from existing structures to allow for stormwater to move away from the buildings.

The subject parcel will contribute to the existing stormwater management system. Designs will need to accommodate the slope of the parcel to account for stormwater and impervious surfaces will need to be considered to assist in natural drainage.

The Town of Green is also located in an area that does experience bouts of cold and warm weather. The building design will account for these conditions in the design of its foundation to allow for freeze/thaw associated with the changes in soil and pavement temperature. These considerations will factor in current temperature ranges and ranges adjusted for the localized warming the Town of Green will likely experience in the next 30-50 years due to climate change.

May require some mitigation as indicated in the references for design modifications to accommodate the slope of the parcel to account for stormwater, observations of water issues at nearby properties, and building designs to account for cold/warm weather.

Pervious pavers, bioswales, and other green infrastructure will be used where possible to mitigate pluvial flooding.

Hazards and Nuisances, Including Site Safety and Noise

(3) Minor Adverse Impact

The Town of Green has established a local noise ordinance that limits construction hours to between 7:00 AM – 7:00 PM on weekdays and 8:00 AM – 5:00 PM on weekends and holidays. Construction outside of these hours is not permitted. Construction activities have the potential to expose sensitive receptors to noise emissions that are normally unacceptable.

The Town of Green maintains ordinances to assist with the visual appearance of the town’s residential and commercial streets. Many of the residential and commercial properties within the Town of Green have alley access. Alleys are used for garbage pick-up, parking, and service access. The town maintains zoning codes to enforce alley access and to ensure that they are clear from garbage, parked vehicles, and unauthorized uses.

The project construction will limit activities to the hours noted within the town ordinance. The neighboring residents will be provided with advance notice of the construction.

Construction vehicles will not block access to the alley—they will be parked either in designated spaces made available within the parcel or in public lots located off-site. Garbage and construction debris will be collected.

Socioeconomic

Want to learn more? Explore the Socioeconomic Category of the Environmental Assessment eGuide.

Environmental Assessment Factor Impact Code Impact Evaluation Mitigation

Employment and Income Patterns

(1) Minor Beneficial Impact

The Town of Green is home to commercial and industrial establishments. The labor force consists of numerous skilled laborers, including those in the construction sector. The project is one of a few within the Town of Green requiring new residential construction.

The median household income is approximately $42,000, and the per capita income is approximately $23,000. Among those eligible for work, 62 percent of the population is in the labor force. The poverty rate for the town is approximately 6 percent.

The project will increase temporary labor needs for the construction of the housing unit. Once built, additional employment may be needed to assist in the maintenance of common areas. The project would be anticipated to draw a local labor force. In this manner, it would not greatly impact the local economy through the influx of workers or expenditures associated with the construction period. The project may consider a mentorship program to help local individuals acquire construction jobs.

The project will create 10 individual units of affordable housing that will be priced to allow for a low-to-moderate income (LMI) demographic. In addition, this project will provide housing in a central area that is serviced by public transportation, allowing potential residents access to jobs, retail, and community services.

Demographic Character Changes, Displacement
(2) No Impact Anticipated

The population of the Town of Green is approximately 54,000. Among this total, approximately 16 percent are aged 65 years and older and 24 percent are aged under 18. The population is largely White (65 percent); however, the African American population comprises the next largest group (12 percent).

Housing is generally owner-occupied; the median gross rent is approximately $990, which is below the United States average. Approximately 72 percent of the houses have access to a computer and/or broadband subscription. This is largely consistent with the United States average (78 percent).

As the overall project will have a limited construction timeframe and anticipates the use of local labor, the project would not likely impact the local physical, social, and psychological dimensions of the community. The project would not displace any population as the subject parcel is currently vacant and the project is not anticipated to cause gentrification or significantly alter property values or rents.

The project may assist the community by eliminating a vacant lot and providing for an opportunity for affordable housing. In this manner, the project will also not concentrate and/or isolate low-income or disadvantaged people.

 

Environmental Justice
(3) Minor Adverse Impact

The project is sited near a main, high-traffic road for the Town of Green. As a result, project residents may be disproportionately exposed to harmful air pollutants. The Environmental Justice Indexes for Diesel Particulate Matter and Traffic Proximity from U.S. Environmental Protection Agency (EPA’s) Environmental Justice Screening and Mapping Tool (EJSCREEN) show exposure at the 80th percentile for the project site. Due to the current vegetative barrier separating the highway, exposure is not significant enough to require alternative site selection. On-site mitigation can reduce any environmental injustices.

Project residents have adequate access to schools, transportation services, and the downtown district. Park access is also proportionate with the rest of the Town of Green; however, the developer should coordinate with the local transit authority to ensure the Town of Orange Park District is public transit accessible.

Engage with community organizations and groups to inquire on potentially overlooked environmental justice concerns. It is important to communicate with parties representing the full diversity of community members.

Building management should equip the Heating, Ventilation, and Air Conditioning (HVAC) system with air filters that have a Minimum Efficiency Reporting Values (MERV) rating of at least 11 to ensure safe indoor air quality. If possible, the project should also include another green buffer in front of the building to further limit exposure to air pollutants.

Community Facilities and Services

Want to learn more? Explore the Community Facilities and Services Category of the Environmental Assessment eGuide.

Environmental Assessment Factor Impact Code Impact Evaluation Mitigation

Educational and Cultural Facilities
(2) No Impact Anticipated

The Town of Green has the Purple Elementary School District, which has two schools: one for Kindergarten through 5th grade and one for 6th through 8th grade. The town also has the Blue High School District, which sponsors an evening school. Various private childcare centers are located throughout the Town of Green. No private schools are located within the town.

As the project will consist of only 10 units, the project would not contribute a large enough student population to impact the local school system. Children living within the proposed units would likely be able to walk to school or take public transportation. The project may assist the schools with creating a safe route to school for its residents.

Please note: The Town of Green’s Comprehensive Plan addresses school capacity issues. The Comprehensive Plan may be used as supporting documentation for a number of factors.

The Town of Green was established in 1923. The original town hall is present, approximately five blocks from the subject parcel. The town hall is listed on the National Register of Historic Places (NRHP) due to its importance within the community (local significance) and because its architect was the nationally recognized Mr. C. Green, after whom the town is named. Other cultural institutions within the town consist of the local library and community center.

As the NRHP-listed town hall is located several blocks from the subject parcel, no effect would be anticipated to occur to this property as a result of the project. While the library and community center could be used by the residents, the number of users would not cause an undue burden on these existing facilities, as the residents will likely be drawn from the local population.

Commercial Facilities

(1) Minor Beneficial Impact

The project will be located in an area noted by the Town of Green for its potential for transit-oriented development. Some commercial properties are present within walking distance of the subject parcel, including a grocery store and convenience store. Banks and other service locations are located near the center of town, approximately 5–7 blocks from the subject parcel.

Please note: The preparer should include a map showing the location of the resource.

Local commercial facilities are expected to benefit from an increase of shoppers and greater pedestrian access due to improved walkways. Regional shopping facilities are located in the Town of Orange, approximately six miles from the subject parcel.

Please note: The preparer should include a map showing the location of the resource. Bus service is available to this location on weekdays and on the weekends, though service is limited on Sundays.

Please note: The preparer should include a reference to the bus map and route schedule. The Town of Green recently lifted its ban of private rideshares, as such, in addition to taxis, other sources of transportation are present to the regional shopping facilities.

Commercial facilities are easily accessible through a variety of transportation means. A mixture of facilities will allow the future residents of the 10-unit complex to shop both locally and, if needed, at regional facilities. The available goods and services should be adequate to meet the needs of the potential residents.

The project is not anticipated to influence the type of commercial facilities that may come to the Town of Green. However, as it is not proposed as a mixed-use structure, the Town of Green will not be able to utilize this parcel as a means to assist in its goal of providing for transit-oriented development. However, the scale of the structure will provide for walking traffic, which may benefit proximate commercial facilities.

 

Health Care and Social Services

(2) No Impact Anticipated

The Town of Green has a number of dental and medical offices.

Please Note: The preparer should include a reference to a map showing the doctor and dental office locations. Some of these doctors are affiliated with the main hospital for this area, which is located in the Town of Orange. The main grocery store has a local pharmacy and a nurse on staff that is able to provide some basic services.

While the main hospital, which provides emergency care, is not local, Town of Green ambulances are able to transport potential patients within a short drive.

Please note: The preparer should include a reference indicating consultation with the emergency services provider that confirms ambulances are available and that travel times are within expectations. The ambulances are able to prompt traffic lights and do not have to cross any railroads on the route to the hospital. The Town of Green is looking to fund additional senior ride-shares and shuttle services to the hospital, but it has not yet identified a source to fulfill this need.

The potential residents for the multifamily residence are likely to be local, from either the Town of Green or surrounding communities. In this regard, the project is not anticipated to burden the existing health care and social services available in the community.

The local bus routes provide service to the hospital, patients, visitors, and employees. While the routes have limited service on Sundays, the number of residents within the 10 units should not add to or detract from these existing services. Social service needs for the residents may be accommodated by programs held at the local community center.

 

Solid Waste Disposal/Recycling
(3) Minor Impact Adverse

Solid waste disposal is provided to residents within the Town of Green through a private service provider. Residents may purchase bins that may be placed alongside a front curb or within an alley for pick-up. Annual fees range from $25 to $100 depending on the size of the bins selected.

Recycling services are new within the Town of Green. The residential program requires residents to separate the various types of goods and place them in appropriate containers. This program also requires a payment of an annual fee.

Construction activities will generate a large amount of solid waste that will need to be managed appropriately to avoid creating a negative impact. Likewise, residents are expected to generate standard household wastes once they move in, as such, waste management could present an adverse impact.

The project will need to mitigate these potential adverse effects by addressing solid waste/recycling needs both for construction and for when the building is complete. During construction, waste and recyclable materials will be hauled off-site as part of the construction contract. Approved facilities will be utilized for this disposal/recycling.

Once built, the project will participate in the Town of Green programs for multifamily units. This consists of the placement of a large bin for garbage and recyclables that will be placed in the alley. The unit as a whole may be fined for the improper use of these bins. Therefore, the residents will be provided instructions on these programs upon move-in.

Waste Water/Sanitary Sewers
(3) Minor Adverse Impact

The Town of Green has a combined stormwater/sanitary sewer system. The main facility is located on the outskirts of the town, approximately one mile from the subject parcel. The appropriate connections, however, are still on site from the previous structure. The system is nearing capacity, as it is an old system that was built over 20 years ago.

Please note: The preparer should include documentation indicating that the water and sewer department have been contacted and confirmed capacity. The Town of Green is actively looking for opportunities to replace conveyance pipes, when possible.

The project will connect to the existing Town of Green wastewater and sewer infrastructure. The project will be completed in compliance with the building code. Connections will utilize new equipment and improvements will be made if within the subject parcel and required for services to the potential residents.

The project is not expected to overrun existing capacity in the immediate future since most of the anticipated residents are expected to be currently residing within the Town of Green. However, the U.S. Climate Resilience Toolkit’s Climate Explorer projects an increase in precipitation in the next 30-50 years in the region. Increased rainfall in future years due to climate change will increase the risk of combined sewage overflow events, creating a minor adverse impact.

The increased risk of combined sewage overflow events in the future due to increases in rainfall intensity and frequency will require mitigation. The project will incorporate green infrastructure into its design, including installing at least 2 rain gardens of at least 25 square feet each to improve infiltration. The project will also use pervious pavers in its parking area instead of impervious asphalt, to decrease runoff. Both strategies will be installed prior to project completion.

The Town of Green also has incorporated expansion of its sewer capacity into its capital plan, and the expansion is set to be completed by 2035. This expansion will also help mitigate the increased risk of combined sewage overflow events.

Water Supply
(2) No Impact Anticipated

The Town of Green receives its water supply from the Red Reservoir, which is managed by the Yellow Company. The Yellow Company adheres to the industry standards in its management of the water supply from this reservoir. The project will connect to existing water supply infrastructure in accordance with state and local building codes. To ensure that the proper standards are met, the project will coordinate with the Yellow Company.

The project is not expected to overrun existing capacity since most of the anticipated residents are expected to be currently residing within the Town of Green. As noted in HUD guidance, a user consumes approximately 100 gallons per day per capita, so a minimum of 2000 gallons per day will be needed (assuming an average of 2 residents per unit).

Please note: The preparer should reference a record of consultation with the water provider confirming availability. In this manner, the project does not anticipate the need for additional water supplies or on-site wells.

 

Public Safety—Police, Fire, and Emergency Medical
(2) No Impact Anticipated

A full-time police force serves the Town of Green. The police have crime prevention, investigations, and records units. The police department participates in 9-1-1 calls for emergency reporting. A Crime Free seminar is offered by the Town of Green for owners of rental housing. This seminar helps landlords (or agents) keep illegal activity off of rental property.

The fire department consists of full-time firefighters. The headquarters are located next to the town hall, with a secondary facility located on Second Street. The fire department operates one tower, two frontline engines/trucks, two ambulances, and a command vehicle. The fire and emergency services respond not only to fires, but also to hazardous materials, technical rescues, and water rescues and recovery. The Town of Green has established a goal to have all of the department’s firefighters certified as both emergency medical technicians (EMTs) and paramedics by 2025.

As most of the residents are expected to be currently residing within the Town of Green, no increase on the demand for public safety services is anticipated to occur as a result of the project. The agent responsible for the operation of the housing unit will participate in the local Crime Free seminars.

The multifamily residence will be maintained with proper outdoor and indoor lighting, access restrictions (i.e., locks on doors and windows), and clear pathways/hallways. Sufficient space will be left in the alley to allow for emergency vehicles. Nearby fire hydrants will not be disturbed by the project.

 

Parks, Open Space, and Recreation
(2) No Impact Anticipated

The Town of Green has a number of pocket parks formed on previously vacant parcels and recreation facilities associated with the fields/playgrounds of the Purple Elementary School District and the Blue High School District.

Please note: The preparer should include a map showing the location of established recreation areas. The high school also has a pool. The facilities at the elementary schools are within walking distance of the subject parcel.

A park district is not present within the town, but an agreement has been created to allow residents of the Town of Green to pay resident rates at the Town of Orange Park District facilities.

Please note: The preparer should include a reference indicating the agreement is attached or if the agreement is too large, the location of the agreement.

The Town of Orange Park District offers a variety of recreational opportunities for all age groups and has several facilities; the closest of which is two miles from the Town of Green. The facility consists of a multiplex with baseball fields, soccer/football fields, basketball courts, tennis courts, and indoor and outdoor pools.

A community center is within the Town of Green. Most of the programming is targeted to seniors and toddlers, with some art and music classes for older children and adults. The community center is located two blocks from the subject parcel.

Please note: The preparer should include a reference to a map confirming the community center location.

The project will not increase the demand for parks or open space and will not result in the deterioration of existing facilities. Furthermore, it will not result in the loss of parks or open space that is accessible to the public. While the Town of Green is utilizing vacant lots for park development, the subject parcel was privately owned and not available for the town’s use.

The project will be designed to include green space within the front of the building to account for setbacks required by the Town of Green. Landscaping will be appropriately utilized to offer energy savings, but also to provide some privacy.

 

Transportation and Accessibility
(2) No Impact Anticipated

The Town of Green has an extensive bus network. Multiple routes have stops within walking distance of the subject parcel. Discounted rates are available on the buses for students, seniors, and some qualified low-income residents. The closest stop is approximately 500 feet from the subject parcel.

Please note: The preparer should include a reference to a map showing the proximity of the bus stop and a bus route map.

While the town encourages non-motorized transportation, facilities are also available for motorists. The subject parcel has access to the alley that allows space for vehicle parking. The project will be designed with handicap ramps to allow access to the street and to the alley. Handicap spaces will be provided in accordance with the Town of Green zoning code requirements. Residents will be limited to one car per unit. Visitors will need to make use of off-street parking. An arterial connects the Town of Green to the Town of Orange and provides access to the highway system. This arterial carries the primary traffic to the City of Colors, the largest metropolitan area proximate to the Town of Green.

The Town of Green Comprehensive Plan notes no immediate improvements planned for the street in which the subject parcel is located, but it does show the potential for future bicycle facilities with connections beyond the Town of Green that account for the town’s natural amenities. Space will also be provided for bicycle storage to encourage bicycling.

As the project is limited to 10 units, the amount of traffic that could be associated will increase a negligible amount during construction and will remain generally the same once the residence is constructed. Furthermore, as the alley will be used for access, little to no impacts are anticipated regarding traffic flow and existing traffic patterns.

 

Natural Features

Want to learn more? Explore the Natural Features Category of the Environmental Assessment eGuide.

Environmental Assessment Factor Impact Code Impact Evaluation Mitigation

Unique Natural Features, Water Resources

(3) Minor Adverse Impact

While no unique or natural features are located on or adjacent to the subject parcel, the Town of Green is located along a large creek that flows into the Pink River.

Please note: The preparer should include a map showing the creek location.

A popular area for hikes/picnics is where the creek has a natural drop, creating a small waterfall. The area is surrounded by large trees, with a mixture of deciduous and evergreen. Some of the trees were recently lost due to the Emerald Ash Borer. Due to their proximity to the creek, the Town of Green was cautious in its treatments, so as to not contaminate the creek. They have since issued guidance for developers regarding tree plantings.

The creek is also subject to flooding during heavy rainfalls. One of the Town of Green’s primary roadways is located adjacent to the creek. As a result, rainwater may carry oil and gasoline into the creek.

The project will contain landscaping. It will be designed in such a way as to avoid the introduction of invasive species, and maintenance will be conducted so as to avoid the use of harmful chemicals.

While the creek is not located proximate to the subject parcel, the project will make use of the existing stormwater/drainage systems. Therefore, construction activities will be conducted so as to be cognizant of run-off and disposal of waste products. Best management practices will be used to minimize the potential for contaminants to make their way into surface water and/or groundwater.

Mitigation required to utilize best management practices to minimize the potential for contaminants to affect surface water and/or groundwater.

Mitigation Measure

Implementation of Stormwater Pollution and Prevention Plan (SWPPP)

Vegetation, Wildlife

(2) No Impact Anticipated

The subject parcel is currently devoid of any vegetation, except for small areas in which grasses have grown between broken pieces of the asphalt pavement. A few small trees and bushes are present on the adjacent properties.

As previously noted, the project will contain landscaping. The plants utilized as part of the overall design will consist of native vegetation so as not to harm local wildlife and to fit in the overall character of the community.

Wildlife within the Town of Green is typical of suburban/urban areas. It primarily consists of rodents, squirrels, raccoons, opossum, and a variety of birds. Residents have noted the presence of an owl or two and the occasional sighting of a coyote or fox. Recent surveys conducted for a variety of developments have not noted the presence of state or federal listed or endangered species proximate to the subject parcel.

The project will not damage or destroy rare, threatened, or endangered species or their habitats. In this manner, it also will have no effect on state or federal threatened species, endangered species, or species of concern. While the project will only be three stories in height, the project will utilize bird-friendly designs for its windows. It will consider best management practices to avoid potential collisions.

 

Climate and Energy

Want to learn more? Explore the Climate and Energy Category of the Environmental Assessment eGuide.

Environmental Assessment Factor Impact Code Impact Evaluation Mitigation

Energy Consumption

(3) Minor Adverse Impact

The parcel is located proximate to transportation, retail, and community services.

Please note: The preparer should include a project map showing the location of the services and documentation indicating that utilities are present and available. Existing utility connections are present. It is located in an area noted by the Town of Green as one primed for transit-oriented development.

The parcel is surrounded by existing residential developments. The entrances of all structures are positioned toward a residential street with some mixed uses (i.e., commercial).

This project will convert the parcel from vacant lot into multifamily affordable residential housing; this will lead to increased energy consumption at the project location as compared to its existing use. To the extent possible, the design of the units will incorporate energy conservation measures, such as strategic window placements, ENERGY STAR-certified windows and doors, and insulating against air infiltration, and consider outdoor landscaping to assist with exposure to the sun and to reduce overall energy consumption.

Parking will be limited to one space per unit with access from the alley maintained. Existing utility connections will be used.

Potential residents for the units are expected to come from within the Town of Green or from the surrounding communities.

Climate Change Impacts

(3) Minor Adverse Impact

By following the direction from the Analysis Techniques section for the Climate Change factor in HUD’s eGuide, the Town of Green finds climate change will increase the project’s future flooding risk due to increased regularity and severity of extreme weather.

Please note: The preparer should also consider any potential climate change impacts found here in the other relevant factor sections. The proximity to a river makes this site particularly vulnerable to future flooding events.

The project uses a transit-oriented approach to development. Access to public transportation and bike storage provides residents with alternative transportation options to personal vehicles. The project is also walkable to the downtown area.

With the knowledge of climate impacts from the Impact Evaluation, mitigative actions, such as utilizing permeable pavers, bioswales, and other green infrastructure, will reduce the likelihood and severity of future flooding events.

Developers plan to utilize low-carbon building materials throughout project development. The adoption of Energy Star certified appliances, windows, and doors reduces long-term building emissions and monthly utility costs for residents.

Other Factors
(2) No Impact Anticipated There are no other factors to consider for this project.