California Water Management: Foreshadowing a World of Weather Extremes? with Chris White

California is in the middle of a historic drought. And since 1990, average annual water allocation to growers from state water systems has been cut in half as water resources dwindle. So how do growers plan for their crop when faced with an unreliable water supply? On this episode, Chris White, General Manager of the San Joaquin River Exchange Contractors Water Authority, is going to explain how they get water to the 240-thousand acres of agricultural land east of the Diablos. He'll give an in-depth explanation of water transfer markets, including how much it costs and how transportation affects water quality. He'll also talk about regulatory decisions that have affected water use and distribution in the area, including one which pushes water agencies to achieve groundwater balance by 2040. Plus, Tom and Sally will be telling us about farmers in the Netherlands protesting government restrictions on nitrogen fertilizer use, how even banks are targeting net-zero scope three carbon emissions goals, and how data-sharing by growers can help negotiate more realistic and effective sustainability practices.

Episode Transcript

Chris White:

Many families in California came in here and bet their family legacy on being able to farm with these allocations. But over the past few decades, we've seen multiple different regulatory decisions that impact water distribution in California. These are very complex, but the impact on water reliability is very clear.

Dusty Weis:

Welcome to The Future. Faster. A sustainable agriculture podcast by Nutrien Ag Solutions with our very own Tom Daniel, director of North America Retail and Grower Sustainable Ag, and Dr. Sally Flis, senior manager, North America Sustainable Ag and Carbon. This is your opportunity to learn about the next horizon in sustainable agriculture for growers, for partners, for the planet.

Dusty Weis:

To us, it's not about changing what's always worked. It's about continuing to do the little things that make a big impact. On this week's episode, we're joined by Chris White, executive director of the San Joaquin River Exchange Contractors Water Authority to learn about how one of the longest running most ambitious water management initiatives in North America metes out water allotments to growers in central California and what we can learn from it as water scarcity becomes an increasingly important topic, plus why are growers protesting in the Netherlands and why it's an important lesson for us here.

Dusty Weis:

But if you haven't yet, make sure you're subscribed to this podcast in your favorite app. Also, make sure you follow Nutrien Ag Solutions on Facebook and Instagram. I'm Dusty Weis, and it's time once again to introduce Tom Daniel and Sally Flis.

Dusty Weis:

Tom and Sally, farmers endure all kinds of changes in regulation, and we grumble, we might complain about it with our neighbors or when we're going for coffee or a beer, after a day in the fields, but over in the Netherlands right now, they're doing a little more than that. They're actually protesting. What can you tell me about that, Tom?

Tom Daniel:

Yeah. So if anybody's been following the news the last few weeks, they've noticed that all the tractors, I think in the Netherlands, have come upon the capital and are protesting it. What their protest is is that the government there has made the determination that the entire country is going to be at a net zero number on or about 2030. It's such a huge agriculture area. In fact, I didn't know, Sally, but this is the number two largest food exporter in the world, is the Netherlands.

Tom Daniel:

Because of that, they have a large amount of nitrous oxide emissions that comes from their nitrogen fertilizers, and so they're being asked to reduce their nitrogen fertilizer used by 50%. In lots of cases, it's going to put a lot of farmers out of business. They won't be able to produce enough food on those given acres to economically sustain themselves. The government recognizes that.

Tom Daniel:

Sally, I think what scares me about this whole thing is that the government is choosing environmental change over food. That to me is almost scary.

Sally Flis:

Yeah. There's similar stuff coming out in Canada. We've seen their announcement about a 30% reduction on nitrous oxide emissions from fertilizers. So we've got some work we're doing there and discussions with different groups on how can we help support what's really going on in the field, what growers are doing.

Sally Flis:

I think one of the challenges we run into here, Tom, and we've talked about this before from a data resource aspect and from the importance of growers sharing their data with a sustainability program, whether it's ours or somebody else's, is the reductions that these programs look to make are based on numbers that are out of date.

Sally Flis:

So if we had accurate information on whether it's in the Netherlands or in Texas or California or Canada on what are the real practices occurring in the field, how efficient are growers with the resources they're using, and what are those real resource concerns that growers need to address, versus using globally set numbers to estimate emission reductions that need to be made, I think is one of the biggest and alarming challenges we have right now, is everybody wants to set a goal to make a reduction, whether it's a country or a company, around numbers that aren't accurately portraying what's going on in the field.

Sally Flis:

Every grower's got some improvements they can make. Growers are on a sliding scale of how much improvement they can make, but adverse pressure is being put on growers from companies, from governments to make reductions when we haven't really even accurately accounted for what are the real practices occurring in the field.

Tom Daniel:

So Sally, I'm going to ask a question again, then. Where are we going to get this information? I noticed one of the banking institutions was measuring climate impact, and they were using data all the way back from 2008. We know that agriculture has changed tremendously since 2008. So where is this data going to come from and how are we going to get it put together that really gives us a clear picture of where agriculture is today when it concerns the environment?

Sally Flis:

It's got to come from the growers in the field, whether it's participating in a sustainability program and helping different entities across the board build up this data in privately held databases that we can figure out how to share or generate changes in emission factors, or it's something... and I know they're not simple surveys, but the data we end up using in these is from national government surveys, whether it's the Netherlands or Canada or the United States.

Sally Flis:

So if growers aren't responding to their USDA survey, we can't have better numbers to use about the practice change that's happened and the practice change that we really need in the field. I think one of the other frustrating pieces there, Tom, is if you look at that 2008 data, that's where we get some of these quotes on how much cover crop has been planted in different parts of the country.

Sally Flis:

Well, you and I know as we've gone out and talked to growers about adopting new practices, those cover crop numbers are not accurate of what's happening in the field today. There's still improvement to be made and we still want to help growers make those improvements, but if we aren't reporting on what's happening, we're going to continue to have these poorly set or inaccurately set baselines that we're trying to improve through new practice adoption that, when we go out and talk to growers, a lot of them have already implemented those practices.

Tom Daniel:

Exactly. I'll tell you something else that's come up too, and you and I even had this discussion today. We have a lot of different segments of the ag industry that are impacted by carbon, and especially around what the grower does at the farm level. So it's not just about how many trucks a particular company has going up and down the road burning fossil fuels, that's a measurement of carbon. Many of our downstream, our processors, our grain aggregators, our packaging companies, even our box stores like Walmart and Costcos, they are all accountable for the amount of carbon that was generated on a field in a farm.

Tom Daniel:

It transfers all the way through the system in what we call a scope three category in carbon. The banking industry, and I never had thought about the banking industry having a carbon footprint, but the banking industry today has to account for the dollars they lend to farmers that are going for raising commodities of corn or cotton or whatever the commodity may be.

Tom Daniel:

In fact, I was looking at an article, and we'll post this on the podcast site, but I was looking at an article that Rabobank today is lending $106 billion a year into the ag sector. That's only 17% of their overall bank assets, or what they lend. But out of that 17% of the money they lend that goes to agriculture, it makes up 40% of the bank's financed emissions for their scope three. 18.6 million tons a year of carbon dioxide equivalent that Rabobank is going to be asked to offset.

Tom Daniel:

The only way they can offset that, Sally, is through farm practices on the field. Once again, what's Rabobank basing their emission factor on today, Sally? You just said it a few minutes ago.

Sally Flis:

Yeah. Yeah. They're basing it on those 2008 or 2012 numbers. That's the available data for practices occurring in the field and emission factors from modeling work.

Sally Flis:

I think the flip side of that is, Tom, it's interesting the comment you made on not thinking about a bank's greenhouse gas emissions or what their carbon footprint is, and what you're seeing for pressures on the banks and some other stories that I've listened to recently, is people pushing back on other parts of the supply chain, on technology suppliers, where they rely heavily on financing on a year to year basis, right? They operate off some of the financing that they use.

Sally Flis:

That financing could really be the biggest part of a lot of companies' carbon footprint because they're financing agriculture, they're still financing energy production, and so it gets complicated as we try and figure out how do we really meet these globally set goals and find all the places in the system where we have an opportunity to make improvement, and how do we account for them and report them in a way that we're not double counting for the same practice change, but we are making sure that everybody who has a piece of that footprint knows that we're making the practice improvement on the field?

Dusty Weis:

Well, Tom and Sally, some really timely headlines there, and certainly more than I expect to hear a whole lot about, but water management is another news story that we're hearing more and more about in the news lately. Tom, out by you in Kentucky, they've got far too much of it, but out in California, they're stuck in a historic drought.

Dusty Weis:

So coming up after the break, someone who's been working in California water management for 30 years, Chris White, executive director of the San Joaquin River Exchange Contractors' Water Authority, is going to tell us how they get water to their 240,000 acres of agricultural land east of the Diablos out there. That's coming up in a moment here on The Future. Faster.

Dusty Weis:

This is the Future. Faster. A sustainable agriculture podcast by Nutrien Ag Solutions. I'm Dusty Weis, along with Tom Daniel and Sally Flis, and we're joined now by Chris White, executive director of the San Joaquin River Exchange Contractors' Water Authority. Chris, to kick off our conversation a little bit, can you just tell us a little more about the background, your location, your experience, and the current role that you have in water management?

Chris White:

Sure. Thank you very much for inviting me today. I'm a civil engineer and a licensed land surveyor in California. I've got about 30 years of experience in water resources planning. 15 years before that I was a surveyor and was involved in construction projects and laying out water resources projects. During this discussion at times, I'll say west side. What I'm talking about is the west side of the San Joaquin valley, basically south of the Delta, which is where most of my expertise is, and that's where my agency is located.

Dusty Weis:

The San Joaquin valley, for those that aren't quite as familiar with California's geography, is everything east of the Diablo mountain range between... What is it, about the bay area, San Francisco, all the way down toward Los Angeles then, right?

Chris White:

That's correct, from the Sacramento and San Joaquin Delta, which is located just south of Sacramento, and then going south from there basically 20 miles past Bakerfield.

Chris White:

So I'm the executive director of the San Joaquin River Exchange Contractor's Water Authority. We're a joint powers authority. We were a formed in 1992. We are on the west side of the San Joaquin valley. Basically, if you were to look on a map and find Patterson, which is basically at the north end of my district, to the small town of Mendota, which is at the south end of our district. This is about 80 miles long.

Chris White:

We were formed in 1992 by our member agencies, Central California Irrigation District, San Louis Canal Company, Fireball Canal Water District, and Columbia Canal Company. We represent roughly 240,000 acres of agricultural land on the west side, and my agency is responsible for administering water conservation plans, water transfer programs, water resources planning, as well as advocating for dependable water supplies for our agencies.

Tom Daniel:

So Chris, the other day when we got a chance to talk, you were really giving us a historical look back on water and water management in that central valley area of California. Can you give us a recap of the history of water in California in that central valley?

Chris White:

Yes. When I provide this, it's going to be more centric to this area, but there's some statewide implicational impacts as well. So the water rights that we hold in the exchange contractor service area date back to the early 1870s when the very first canals in this south of Delta area were being built to divert water from the San Joaquin river to the Western part of the central valley, or the west side.

Chris White:

Then as the need for more irrigation and farmable land in the central valley increased, the United States Department of Interior in about 1933 started the Central Valley Project. This was a vast undertaking in California, which the vision was to build reservoirs throughout the state, but mainly in Northern California, and then build transportation system within the central valley, and the dams were to be constructed on the Sacramento, the American, and the San Joaquin rivers.

Chris White:

So this was envisioned in 1933. In 1939, the series of agreements were signed in order to make that happen, both in the Sacramento valley and here locally. They were ag service contracts, they were settlement contracts, and they were exchange contracts. Our project allowed for water to be developed in the central valley and is largely responsible for this region basically becoming the agricultural powerhouse that it is today.

Chris White:

That is that water from the central valley project came in from basically Northern California through a pumping plant in the Delta, down the Delta Mendota Canal and was delivered to the west side. That's what developed agriculture in this area all the way up through today. My organization or my entity supply water to others within our area. A number of different agencies rely on water supply from us, and this is not uncommon, especially given the fact that we've been in the water distribution business, the water conveyance business since the 1870s.

Chris White:

We've got six small communities or disadvantaged communities within this area that we either supply water to directly for them to treat, or we jointly with them manage groundwater in order for those residents within the cities to have a sustainable water supply. We also convey water through our district to the local wildlife areas, and that's been a partnership that's been in place for many years going back probably to the 1930s.

Sally Flis:

So Chris, I've always lived in the Northeast kind of quadrant of the United States where having enough water is never generally a challenge, except for very short periods of time. We were dry in New York for about four weeks, five weeks, but now we're back to rain every day and high humidity. So water supply is not a problem. Things like having a water allocation or how does a grower go about determining what their water allocation needs to be, what's the timeline for that, how does a grower even approach planning for their next cropping season when water is really the most important thing they need to grow a crop, and they've got to deal with some of these laws and regulations and supply issues?

Chris White:

That's an important question for those that have received contracts from the federal government or from the state of California for water supply. After the CVP was developed, the state water project built the California aqueduct and some other water distribution facilities here in the 1960s.

Chris White:

But over the past few decades, we've seen multiple different regulatory decisions that impact water distribution in California. So when contracts were given in the 1950s and 1960s, they were based upon a certain yield calculation of how much these systems would produce and be able to deliver. So when I say a 100% allocation, what I'm saying is that grower or that district in that year would receive 100% of their contract allocation. That was based on the original calculation.

Chris White:

So many families in California came in here and bet their family legacy on being able to farm with these allocations. Over the past couple of decades, the regulatory decisions that have come in, these are very complex, have different goals, and they've had mixed results. But the impact on water reliability is very clear.

Chris White:

The average annual water allocation since about 1990, the average annual has been cut in about half. So that's about a 50% on average type of an allocation for a grower in the surrounding ag service, water contractors. So that's really challenging. It's not like you're going to get a 50% allocation every year. It's based upon the hydrology in that year and what's occurring in Northern California and what's occurring locally, but this is how an average of a 50% allocation would occur, or even less than that.

Chris White:

Looking back over the last 10 years, 2014, west side ag service contractors got a 0% allocation. In 2015, they got a 0% allocation. 2016, they got a 5% allocation. 2016 was a fairly wet year, but they were in the process of refilling reservoirs after a dry year when they were pretty much depleted. Then 2017 was a near record wet year, and they received 100% allocation.

Chris White:

So if you took the average of all those, it's about a 30% allocation, which is what we thought before 2019 was the long term average for water supply for west side ag service contractors. So that's the challenge that these folks face, is a very unreliable supply, which it makes it very difficult to plan around.

Dusty Weis:

Yeah, Chris, I'm certainly not a grower, but I spend a lot of time around them. But at the risk of asking you to state the obvious, what's the impact on a grower of receiving a zero or a 5% water allocation? How do they even get by?

Chris White:

Well, what they've been doing is to the extent that they have wells that are available to them, they lean really heavily on their well field. Now that's going to change. Or they go into the transfer market and they buy water from others. There's a transfer market from Northern California to the central valley or to the west side that has typically occurred in which growers are paying high dollar for water, basically to get it south of Delta.

Chris White:

In 2014, in 2015, they were getting into the practice of buying water. As an example, in 2015 in a 0% allocation, they were buying water from Northern California, bringing it through the pumping system into the local San Louis reservoir and parking it there to finish out 2015 from an irrigation season with their well field, but also to carry it into 2016 so they would have a water supply to count on for the next year.

Sally Flis:

What are transfer markets and how do those operate?

Chris White:

Well, they operate differently in different parts of the state, but the part that I'm familiar with is relative to the federal government and the Central Valley Project. There was a law passed in 1992, I believe. It was Central Valley Project Improvement Act, which allowed transfers to happen amongst federal districts within the entire CVP. So that stretches all the way from Shasta in the north south to around Bakersfield.

Chris White:

Each of those areas are in different circumstances, depending on the year type for the amount of water they have available. So in some years, Northern California districts have water available for transfer when south of Delta, because of regulation, they're in a much more extreme drought situation, and so they're able to move water from north to south to satisfy that need.

Tom Daniel:

Chris, just out of curiosity, what would it cost to purchase something like transfer water in that case?

Chris White:

My districts never participated in buying transfer water in '14 and '15, but as I understand it, the water market was about $1200 to $1300 an acre foot. That was buying the water in Northern California, bringing it through the Delta. Part of that water goes to losses. You don't get 100% of the water south of the Delta. By the time you account for losses and transportation and storage costs, it was about $1200 an acre foot.

Dusty Weis:

Who do they pay? Who's getting the money for the water, essentially?

Chris White:

Well, we do some transfers also from within the exchange contract service area during certain year types, they're called noncritical year types, under my contract. So we do those. We have installed systems that can conserve water, either lining of canals to keep it from going into the groundwater, or return systems that can serve water and keep it on farm, and they cost dollars.

Chris White:

So the entities have transferred water to our neighbors and to the local wildlife refuges, and then our districts get paid those dollars in return for the transfer. They have plowed that money right back into the district on further modernization and helping our growers to convert to high efficiency systems and that sort of thing.

Dusty Weis:

Okay, got it.

Tom Daniel:

Obviously, if you look at the news today, we see California's got water issues in lots of areas, as do the rest of the country, out west, especially. But my question is has this impacted acres, crop rotations, or even has it idled some ground and taken it out production?

Chris White:

We have seen ground taken out of production at least annually. As an example this year with the operations plan that was implemented, there were acres in Northern California that were set aside over earlier years because of the operations plan that was prescribed this year and water shortages. So yes, we have seen that.

Chris White:

Moving forward and within our service area, we have a fairly secure water supply based on our water rights situation. Even given that, we are doing things internally in order to secure a better water supply moving forward and projecting forward into the future and trying to prepare for that.

Chris White:

The real challenge here is to put together projects and formulate programs to secure sustainability going into the future. We've been working not only with our growers on water conservation and technologies, but we've also been working with our small communities on groundwater banking projects, recharge and recovery projects to benefit their groundwater going into the future.

Chris White:

So we've been investing pretty heavily over the last several years in those types of projects in order to try to secure some sustainability into the future for our area as well.

Sally Flis:

So Chris, obviously quantity of water is critical for driving crop production in these areas, but quality and what else comes with that water can also be a question as growers go to use it. How do you guys manage quality for things like salinity or nitrate levels or other things that might get into the water as it's being moved the distances that you're talking about to make it available to the crops and the communities in your district?

Chris White:

Yeah, and generally the better water quality is the surface water in my area. It's different depending on what part of the state you're in. If you were on the east side of the San Joaquin valley, your well field would have a little better water quality than we do on the west side. It's just due to the soil properties. The Diablo range had a different soil property. The groundwater on the west side is saltier than the groundwater on the east side.

Chris White:

To the extent you have a better surface water supply, even if it's reduced, if you have a better surface water supply, you can pump saltier groundwater and blend it and use the blended supply. So typically that's what happens.

Chris White:

Now, for agriculture generally, the nitrates are not a real big issue. The nitrate in groundwater is a drinking water issue. To that extent, then it needs to be managed in order to support not just the agriculture but the small communities that are within the area. So there's some management that goes into that.

Chris White:

But from a crop supply, nitrogen's not that big of a deal, but salt is overall. So those are the things that you face, especially when you convert to high efficiency systems. These high efficiency systems, they're basically feeding water to meet the plant's demands over the summer. You're trying not to over apply water where water is going into the groundwater. It's going past the root zone. What that does is you're not flushing the salts out of the soil, and so these high efficiency systems are much more sensitive to these high salt situations.

Chris White:

So you need to consider that when you're thinking about putting in a high efficiency system. What is the source of your water? How much over percolation do you need in order to make that work for your crop?

Sally Flis:

Chris, do growers tend to have a water manager person that just handles all this for them? Because what I think about on managing a farm in the parts of the US where we have plenty of water and this isn't as big of a management issue, I can't see where a lot of growers that I've worked with in the past would have just enough people and enough time to manage all the different elements that you've brought up in this episode around making sure they have one of the most critical parts of growing a crop.

Chris White:

It's amazing to me, these growers are really become experts and do they have separate staff that they hired? Maybe, maybe not. Some of the larger growers have staff assigned specifically, especially if you have a lot of acres, but within our service area, our growers average in size of about 200 acres. We've got some bigger ones, but with grants and loans from the district, we've been installing for many years high efficiency systems, and they've been able to manage those themselves, but it's been an education process.

Chris White:

We have spent on farm about a hundred million dollars in helping our growers convert from, as an example, furrow irrigation, which is the older way of irrigating a crop, and converting them over to drip irrigation or micro sprinklers.

Tom Daniel:

So a follow up question to one I asked a little while ago, we were talking about allocating water to farm operations. So when we talk about reductions in the overall amount of available agricultural water, who am I competing against for the remaining balance of the water that's coming into the system?

Chris White:

Well, we talked earlier about the regulation that's been occurring over the last 20, 25 years, since about 1990, which is reduced agricultural allocations. What that's done is it's redirected water away from ag towards the environment and for different purposes. As I said earlier, there's been different results from those actions.

Chris White:

But as an example, before 1990, there was a different set of standards for how much water needed to flow through the Sacramento and San Joaquin Delta, and then that was upped in 1990 in a water rights decision here in California. Then there's been further regulations since then that has even upped that amount of water even more, and this is for environmental purposes or for fishery purposes.

Tom Daniel:

So Chris, one of the things that we all are concerned about in agriculture is regulations and legislation that actually manages water or some of the natural resources we have. I know there's the Sustainable Groundwater Act that's in your area. Can you give me a description of what that is and how does it really impact water availability?

Chris White:

The Sustainable Groundwater Management Act was passed in 2014 here in California, and it requires water agencies to make progress towards groundwater sustainability. It has a certain definition, but in general it just means a groundwater balance by the year 2040. Now, according to some studies that I've seen that have come out of the water blueprint for the San Joaquin valley and the study done by Dr. David Sunding, there's an estimate that up to one million acres may be fallowed by 2040 in the central valley as a result of reduced ground water and surface water due to the management under that act.

Chris White:

In a balance, that just means that you're recharging as much water as you're extracting. There's been more water in the central valley been extracted over a number of years than has been recharged. That's the issue and it needs to be closed by 2040.

Chris White:

Some of the cities within my area, the small communities that I talked about earlier, they're in a deficit situation. Each agency is responsible for being in balance. We have reached out to the small communities and assisted them in putting together a plan to bring them into sustainability with the district's help and with the identification and construction of projects. So we've got our community on the west side going in a good direction in a sustainable direction. We're also working with other agencies within our area on a variety of projects to provide some dry year reliability to also help with groundwater management.

Chris White:

By that, I mean some of our neighbors are west side ag service contractors that have been chronically short of water and have been heavily depending on wells. We're working on projects to where we can store water in wet year types, either in the groundwater, in a groundwater recharge projects, or banking projects, or in some surface water projects that we're working on that we can store water in wet year types and recover those water in drier year types. So that's the kind of thing that you need to do in a locality or in a region in order to plan for the future and try to be sustainable by 2040.

Sally Flis:

We've talked to a couple previous podcast guests about how is this changing over time, where, as I mentioned earlier, in areas like the Northeast, droughts are really short term things. We get a couple of weeks or a couple of months where we're below that drought monitor number, and then we get some more rain and we come out of it. California and the areas you guys are in really are in more of these long term droughts. How do these long term droughts and all of the items that a grower or a municipality is facing to manage water impact? What do you feel it looks like 5 or 10 years from now in how growers and communities have to approach planning for having enough water?

Chris White:

Yeah, that's a good question. Obviously, we've seen droughts before in California. If you look back, we had a similar a drought cycle in the 1930s. Some folks think that we're in new ground with the drought that we're within. In California, they're looking at this very topic as to how we're going to operate into the future. How do we plan for the competing demands for water supply in California, and how do we manage around that? There are various programs or studies that are occurring at the state level and at the federal level in order to look at that moving into the future. So from a statewide perspective, we're all dependent on getting through these studies and seeing on the backside of that what the water supply operations really are going to look like.

Dusty Weis:

Well, Chris, it's certainly a sobering discussion to have, and as weather extremes become more of an unfortunately commonplace occurrence across North America, there are lessons that we can draw from your conversation here, and certainly the state of California's experience in dealing with its drought conditions over time.

Dusty Weis:

But this has been a great discussion from where we're sitting, and we appreciate your making the time to have it. Chris White from the San Joaquin River Exchange Contractor's Water Authority, thank you for joining us on this episode of The Future. Faster.

Dusty Weis:

That is going to conclude this edition of The Future. Faster. The pursuit of sustainable success with Nutrien Ag Solutions. New episodes arrive every other week, so make sure you subscribe in your favorite app and join us again soon. Visit futurefaster.com to learn more.

Dusty Weis:

The Future Faster podcast is brought to you by Nutrien Ag Solutions with executive producer Connor Erwin, production assistant Beatrice Lawrence, and editing by Larry Kilgore III. It's produced by Podcamp Media, branded podcast production for businesses, podcastmedia.com for Nutrien Ag Solutions. Thanks for listening. I'm Dusty Weis.