On March 4, 2013, the California Water Policy Seminar Series continued at UC Davis with Felicia Marcus as the guest speaker. Felicia Marcus was appointed to the State Water Resources Control Board in 2012, and recently selected by Governor Jerry Brown to become Chair of the Board, replacing the retiring Charles Hoppin. Ms. Marcus has held a variety of distinguished and high-level positions throughout her career, including serving as Regional Administrator for the US EPA’s Region 9 during the Clinton Administration, where she was known for bringing unlikely allies together for environmental progress as well as making the agency more responsive to the communities it serves. She also served as the Western Director for the Natural Resources Defense Council, and was a Schwarzenegger appointee to the Delta Stewardship Council where she served for two years, prior to being appointed to the State Water Board.
During her speech, Ms. Marcus spoke about the challenges facing the Delta and the role of the State Water Board and other agencies in meeting them, as well as the difficulties of ‘egosystem' management.
Felicia Marcus began by saying today she wanted to weave a comprehensive tapestry of the issues at play in the Delta. “It’s an issue that, as the old adage goes, where you stand kind of depends on where you sit,” and is much like the group of blindfolded people who are trying to figure out what an elephant is by just being able to touch a part, and so they think it’s a very different creature.
“That is very much the case in the Delta,” said Ms. Marcus. “I’ve worked at it from a number of different perspectives, including actually running a local government water agency down in Southern California, and frequently the problem is that people only see or work with a particular slice of the issue.”
“I want to say I am not speaking on behalf of the state board … and I’m not just going to talk about what the state board is doing,” said Ms. Marcus. “I am going to talk as an observer and sometimes participant in these efforts.”
“One of my favorite quotes from Yogi Berra is “It’s hard to make predictions, especially about the future.” So I am going to open with my conclusions instead of making you wait to see what they are, and I have to say I’m optimistic … I decided to shed the ‘Era of Decision or Doom’ title that was originally advertised for this speech, but I couldn’t completely drop the fact that it may not come together. So I came up with convergence or collision, which is more appropriate in the governance context.”
“The protagonists in this drama frequently speak in absolutes: it’s all this, it’s all that. If I don’t get everything I want, the whole thing falls apart – which any of you who ever have been in any negotiation or any public policy issue or any legislative issue know, it is not how things move forward,” said Ms. Marcus. “They move forward in this inelegant, imperfect, kind of messy way where at some point, some collection of individuals decide that it’s worth it to compromise on some of their absolute positions, and say yes to something that’s actually in their interests or their clients interests. That’s what I think will happen in the Delta.”
“Over time, as things haven’t happened and as people have spoken in absolutes, things have gotten worse for the fish … and clearly the water supply reliability is more greatly at risk than we thought even a few years ago. So I think a number of things are coming together that are going to lead to a breakthrough,” said Ms. Marcus.
One of the reasons for that is that “overall, the state is taking far more leadership on more fronts dealing with its own water issues and the Delta than in decades. I think the last 5 to 7 years have been astonishing for someone like me who, in the 90s, as a federal official, had to step in and actually set water quality standards for the state of California because the state hadn’t done it.”
“Over the years, there is this sense that California is the most evolved environmentally, and that is largely true, but there are moments when California inexplicably has not taken a leadership role in matters that have to do with its own economic and environmental future,” said Ms. Marcus. “I’m happy to see the agencies are all working all on task. Will it all work out? I don’t know, but people are all working hard and are all focused on the tasks in front of them.”
There is also more appreciation from virtually all the players that it isn’t ‘all or nothing’; dealing with water and managing water in California takes a mix of many solutions, rather than one big state imposed solution or, worse yet, federally imposed solution, she said.
“Phil Isenberg’s point about how the BDCP dialog evolved to where the water users agreed to less than what they wanted in the announcement that came out in July of 2012 was actually really big. It was a move away from the barricades,” said Ms. Marcus. “And earlier this year, a number of people in the environmental community came out with an alternative to be studied that said yes to some form of conveyance and yes to some forms of storage, which is a huge step beyond the absolutes of years before.”
“That was very encouraging because you are seeing it on all sides. Now is there a clear path? No, definitely not. But is there an opportunity to muddle or noodle our way towards a significant series of improvements, and I would say the answer is yes,” she said. “I think I’ll go 60/40 optimist – you can call me on it two years from now. I think it will be a messy couple of years but I think you are going to see more decision making happen in California than has happened in decades, so it should be an exciting time.”
“The question is going to be whether we at the state and federal level can do our job in a way that converges with enough stakeholders to move forward versus just compounding the drama. And again, my prediction is that it will, but it’s not really going to obvious until later.”
“The dialog on a given effort tends to be driven by the people who happen to be in the room at the time with a deal mentality … there are issues that just have to do with the humans who happen to be in the room,” she said. “The challenge of ‘egosystem management’ is actually the biggest challenge, not ecosystem management or economics or politics or legislative hoo-ha, you name it, but actually just dealing with the people who happen to be in the room.”
“So things come together when there are enough players in enough places in and out of government who say they want hold hands and move forward on something versus being comfortable and staying back in their places,” said Ms. Marcus. “It happens in fits and starts, it happens in the individual decisions that the individual players make, on a given day, in a given room, when they wake up in the morning, or when they walk into that room, so there is a certain mystery to things moving forward, but I think there are a lot of opportunities here.”
Most Californians don’t understand what the Delta is or how it works; some say 80% of Californians don’t know about the Delta, and only 20% do. “I think a big bunch of that 20% that say they know what’s going on, they are just lying or they were embarrassed to answer the question correctly because I rarely found people who actually know it beyond a particular fragmentary view,” she said.
“I love the Delta, and if you haven’t spent any time going through the Delta and going to some of the towns there, you’re missing something. I think it is an essential part of understanding the magic and the beauty of the Delta and why people in the Delta are fighting so hard to preserve it, and why sometimes their fears may seem outsized to some of the more jaded participants in these dramas,” said Ms. Marcus. “They have a lot at stake and there’s a lot of wonder in it. Preserving that is important, and is even a part of the legislation.”
About 20% of the flow into the Delta comes from the San Joaquin River, and about 80% from the Sacramento River; the pumps are located in the south, Ms. Marcus explained. “That’s important because as fish, particularly in the San Joaquin River, are trying to find their way out or their way home, the channelization itself poses a problem for them where they got lost. It’s a miracle what salmon can do, getting out to the sea and more importantly, smelling their way home years later, but the channelization of this makes it very difficult.”
Reverse flows make it almost impossible, said Ms. Marcus. “By putting those giant pumps at the bottom when the State Water Project was created, you created a marvel of modern engineering but you also created something that just changes those flows dramatically. As the fish are trying to get home and smell their way to their native streams, if you have reverse flows, they can’t smell their way there,” she said, noting that it was an oversimplification. “As they try to migrate as small smolts, they get caught up in these channels – it’s not like they can read little fish signs that say this way – so they don’t make it to the main stem and they really become food for predators. This is an enormous issue of growing importance, or at least growing interest in the dialog.”
There is a lot of infrastructure in the Delta. “There are oil pipelines, there are gas pipelines, there are telecommunications, there’s a lot, which suggests that there’s actually an interest in the Delta for a lot of people that have no idea that they have an interest in the Delta beyond water,” said Ms. Marcus. The Delta is threatened by earthquakes, but it is a remote risk of catastrophic occurrence; “it’s a low-risk but high-impact event.” However, a possible 55” sea level rise by the end of the century and more intense storm surges “suggest that these fragile levees, even if we bolster them somewhat, are at risk. There is more at risk than water in the Delta, and … there are more exports and diversions from the Delta than just the export pumps at the bottom.”
Groundwater is a huge piece of the tapestry, accounting for 40 to 60% of water use in California in any given year. “We don’t really have statewide governance. And if you didn’t know that, it’s important to know. I am not suggesting that we have to have it, but if you just follow the dialog about California water and the Delta, you’d think it was just about export pumps,” said Ms. Marcus. “Groundwater is regulated at the local level and in some cases, it’s regulated really well at the local level and in other places it’s not.” While the State Water Board has clear authority on water quality issues, they do not have any authority over quantity: “It’s odd thing being in charge of water supply and water rights for the state of CA and not being able to deal with the quantity issues.”
Groundwater overdraft leads to subsidence, which presents all kinds of issues for infrastructure that’s located underground, and can even impair the ability to use gravity for water conveyance if it changes, Ms. Marcus explained. “And if you let it compact enough, you can’t then refill it. This is not just something you can expand back up to the telephone pole. So that’s storage that’s lost to us forever at a time when we really need to be thinking about storage.”
Climate change is a game changer. 50 to 60% of the state’s storage is in the mountains where it falls as snow in the winter and melts out in the spring and summer when it’s needed. However, “that’s estimated to be dramatically reduced, which will make the water picture in CA much more volatile and much more challenging.”
Ms. Marcus then gave a retrospective on the development of water issues in California that have brought the state to this point.
“The Central Valley Project and the State Water Project were built before all kinds of federal and state acts that would have suggested a review and perhaps a decision that the pumps shouldn’t have been put where they were put in the first place,” she said. The peripheral canal was the first attempt to fix the problem: “The peripheral canal would have taken water further up in the Sacramento River. … the idea is that there is more water flowing there and you can take it not create reverse flows. There is still an issue about how much flow the fish need … but you can more effectively take even the same amount of water with less harm to the fish,” she said. “It has always been the right engineering answer, but it devolved into the north-south fear and dialog, and it was an alliance of environmental community people in Northern California and interests in the Delta that were able to have it defeated at the polls.”
“Toward the end of the 80s, the SWRCB was moving forward to set some really good water quality control provisions for the Bay-Delta, and Governor Wilson challenged the federal government … said we’re not going to do this until the federal government and its endangered species agencies, the NMFS and the USFWS, get their act together and deal with this in a coordinated fashion, because we can do what we can do but if they come out with rulings that say stop the pumps, it messes us up. Again, oversimplification,” she said.
Shortly before Ms. Marcus was appointed to the EPA, “the federal agencies, under some really strong leadership from EPA and the Interior in particular, pulled together what we called Club Fed, which at least put the feds house in order. This was a huge governance issue with one hand not knowing what the other hand was doing.”
The next year was spent coming up with the Bay Delta Accord and people said ‘peace had broken out,' we had agreement on what the state would put into its water quality standards, and multiple year period where we worked towards some far reaching agreements on a variety of issues related to Bay Delta in particular, she said. During that time, the peripheral canal was off the table; “I was one of the people who took it off the table because I thought there was no way we could make progress on this whole range of issues if that was in the room; nobody would be able to deal with anything else.”
“Oddly enough today, the discussion is all about conveyance and storage seems to be left off the table,” Ms. Marcus said. “I still don’t understand why that is, although I’ve bought more than a couple of people a beer to get a theory on why that is and what needs to happen.”
The 2000s were a period of stasis; the federal government wasn’t as interested in California. “However, the state did some really cool things under Prop 50 that started the Integrated Water Resource Planning program that were incredible,” she said, noting that this was part of the reason she is so optimistic.
“Incenting people to get to the table who dealt with a particular area but had never really gotten together to figure out how they could work through the issues such as flood control, water supply, water quality, stormwater issues … under the tantalizing opportunity of getting some grant money, it got people in a lot of places to sit in a room and see if they could work something out, and in a lot of places they have,” said Ms. Marcus. “It was really brilliant and I think an effort that’s probably worth study in its own right.”
There was also litigation over the biological opinions coming from the fish agencies, which is to the background and the backdrop to what is happening now, she noted.
By the late 2000s, Governor Schwarzenegger stepped in and created the Delta Vision task force, chaired by Phil Isenberg with quite a few luminaries on it. “It was really quite terrific,” said Ms. Marcus. “Out of the Delta Vision Task Force came enough consensus from enough players to start moving legislation. It’s a very important backdrop and it was very important in the sense that it was the first big step forward in decades.”
The Delta Reform Act is very important from a governance aspect. “People just talk about the water bond, but it actually had four other pieces of legislation and policy.” One is a step forward on urban water conservation, with a goal of 20% by 2020; “some places have been doing that for a long time, particularly in Southern California, but bringing everybody else up to that level, that’s a lot of water.”
The legislation also got ag water conservation started. “Ag conservation is harder than urban conservation; they are not one to one. One person’s ag return is someone else’s source, or a refuge’s source, or it recharges groundwater, so it’s just way more complicated than urban,” she said.
The legislation provided for additional enforcement staff for water rights: “That was a big deal because water rights enforcement just hadn’t been happening, and that’s the fairness and equity piece around all of this.” Groundwater took a baby step forward with each county having to report to the Department of Water Resources what the status of their groundwater basins are, she noted.
The biggest part of the Delta Reform Act was governance, said Ms. Marcus. “Declaring the coequal goals of water supply reliability and ecosystem restoration as the policy of the state. That may seem obvious to you, but it hasn’t been. Basically what the legislature was saying is that it’s not a teeter totter where whoever wins depends upon who is in power, but that the goal is to balance the two of them. Both of them are important to the state, and this has ramifications for the approach people have to be taking to the variety of things that they do.”
The legislation also acknowledged the importance of the Delta as a place – an evolving place and not set in stone and it mandated the water board do what was called a flow criteria report: “It basically was if the fish could talk, what would the fish ask for, and was a counterpoint to what the water suppliers had been asking for, so that as we moved into this planning process, both at the BDCP and the water board, that the fishes voice would be thrown into mix rather than ignored,” she explained.
An important and significant outcome of the legislation was the creation of the Delta Stewardship Council which consists of seven members drawn from a diverse set of places, geographies and experience from across California. “I was on the Council for about 2 and half years. People take it seriously. I think all of us viewed our job as trying to make sure all the voices of California were heard,” she said.
The Delta Reform Act required that the Council develop a Delta Plan with a time horizon of 50 to 100 years. “If you look 50 to 100 years in advance at something like this, you’re going to look at what you need to do today differently. You can’t ignore climate change with a 55” sea level rise. You can’t just be about getting the deal done today; you really have to think about long-term infrastructure issues, you have to think about storage and snowpack, you have to think about alternative water supplies, and the like,” she said.
“A huge amount of controversy has to do with land uses in the Delta behind those levees,” said Ms. Marcus, so requiring those undertaking projects in the Delta to be consistent with the Delta Plan is an important development. “And if an action is inconsistent with the Delta Plan, which is going to come out soon, someone can actually take it to court and challenge it. It hasn’t happened yet, but for those of you who are lawyers or aspiring lawyers watch this space as well,” she said.
“I think one of the most important tasks for the Delta Council is to create a council of governments; they are tasked in the law to bring together all these state agencies who are dealing with the Delta in very many places … and somehow the Delta council gets to be the camp counselor for all that.”
As with most government efforts, if you can get people into the room for a set purpose, either voluntary or directed by law, it actually works, said Ms. Marcus. “This is the ‘egosystem’ piece. I did this with the Grand Canyon Visibility Transport Commission, on tribal issues and the like. Different things happen when you get people that have to work on these issues face to face, rather than just complaining about each other to whoever will listen.”
The Delta Plan reinforces the Delta Reform Act’s requirement to reduce reliance on the Delta. This means “that if a government entity wants to put another straw into the Delta, they can’t do it unless they’ve looked at all of the other things, from recycling to conservation, conjunctive use, etc. – all kinds of alternative water supplies to stretch their supplies further. … it says ‘look, we’re not going to just keep sticking straws into the fragile Delta, so figure out how to stretch your water and use it more responsibly.”
Frequently, when you hear people talking about the Delta, all anyone talks about is flow, said Ms. Marcus. “It’s not just about flow – flow is probably the most important. Fish need water, obviously, and water helps to deal all the other stressors, whether its predators or contaminants or the lack of adequate oxygen within the water because of contaminants, invasive species, you name it, but flow is not the only one,” she said. “There are multiple stressors that are affecting the fish and wildlife, and we have to come up with way to deal with all of them in the appropriate way. It may seem obvious, but in the dialog, it needed to be reinforced.”
The Delta Stewardship Council needs to finish the Delta Plan. “It’s still not done. It’s been hard to give birth to this plan, then they still need to convene that council. They need to prioritize the levees as to where you would actually put some money into beefing them up. They have to figure out financing, and they have to figure out how to incorporate all kinds of plans from a bunch of other agencies, and then of course they have to make the BDCP decision if it is appealed to them.”
The State Water Board is in charge of both water quality and water rights which was created by merging 2 separate entities, explained Ms. Marcus. “We sit as a quasi-legislative group that sets policy on water quality, we also sit in a quasi-judicial fashion to make water rights decisions in proceedings that can take months and years and are quite complex.”
The State Water Board is in the process of updating the 2006 water quality control plan for the Bay-Delta and the San Joaquin River. “What we do in water quality planning, just as regional boards will do for water bodies in your communities … we look at the water body and we determine what are the beneficial uses for that particular water body. It can be fishing, it can be ag, it can be recreation body contact, it can be recreation not body contact, municipal drinking water … any number of things you might think of. Then you come up with a plan that balances the controls on different things to protect the maximum beneficial use of this particular water body. It takes a long time to do, it’s very scientifically based, a lot of hearings, but it’s a logical thing to say what’s the beneficial use of this water body, what’s inhibiting those beneficial uses, and what can we do to maximize those beneficial uses,” explained Ms. Marcus, admitting it was a gross simplification of the process. “It seems very simple but it’s actually fairly complex. If you do it right, it sets a level playing field for folks to know what you’re aiming at, and give some direction to what can happen.”
The State Water Board has some responsibility for some of the stressors in the Delta, such as “hearing appeals from regional board permits for sewage treatment plants that discharge into the Delta, working on stormwater permits where urban stormwater contaminants go into the Delta, or doing appeals of permits for irrigated lands, meaning ag, that sends contaminants into the Delta. So we own a piece of it, we just don’t stand on the sidelines and say what other people should do. We have our own chunk of responsibility.”
There are four phases to the Bay Delta Water Quality Planning process, Ms. Marcus explained. Phase one deals with the San Joaquin River as well as the south Delta water quality issues; phase two is to deal with the rest of the Bay-Delta. “We’re supposed to be done by 2014, per the Delta Plan, then phase three is implementation,” she said, acknowledging that it’s a mystery date for when the implentation phase would be done. “Frequently when we do these things, the parties come together in some sort of a settlement which is a lot faster than going through a mulit-year water rights proceeding but if we need to do that, we will.” Phase four will deal with upstream tributaries.
Ms. Marcus then summed up the key issues. “The coequal goals mean that if we could throw water at this issue, we can’t, because the coequal goals require us to balance.” The State Water Board is supposed to balance under state and federal law, “so we can balance the economics and we can balance water supply reliability with ecosystem restoration, but the fact that its state policy puts an even bolder underline under the fact that we need to figure out how to do this most effectively for fish and wildlife. … That’s the one that’s the most controversial. We need to figure out how to do it with the least amount of water that we can to maximize both, and that’s where all of these multiple stressors come in,” she said.
Ms. Marcus says she hopes someday that water supply alternatives become mainstream, just as alternative energy is now called cleaner, greener power. “We’re going to have to come up with another word for water conservation, water recycling, stormwater capture treatment, reuse, etc, because there’s a lot going on there that can stretch our water resources.”
The salmon and the smelt are big issues, said Ms. Marcus. “Smelt tend to grab more headlines because they are little and they aren’t very cute, so people who hate the smelt’s impact on their water supply tend to focus on them. When you hear environmentalists talk about what needs to happen, they talk more about salmon. You can be the judge of why that happens,” said Ms. Marcus. “Sometimes what those two different species need is different, and we have to balance that as well.”
Predation is another factor, said Ms. Marcus. “Striped bass, a sportfish regulated by the DFW and prized by anglers, have a veritable McDonalds for them in salmon smolt,” she said, adding “there may be some projects where we can find some hot spots and at least create a fairer fight for the salmon smolts in particular.”
When the BDCP comes out, a couple of things can happen, explained Ms. Marcus. It can be appealed to the Delta council where they can determine if it meets certain criteria; it can also be appealed to court which undoubtedly it will be by some people; and the BDCP will have to come to the state board for a water rights proceeding to move the point of diversion. “So moving the point of diversion is part of a water right as much as the quantity, so we will be important in that, and understanding what the Bay Delta needs first is going to be important to be able to make that decision well.”
The BDCP is not a regulatory process, it’s actually an application for a permit to build new facilities and then to mitigate for it with an incredible amount of habitat, which is one of the key things that fish need. “It deals only with conveyance, it doesn’t deal with storage, but it deals with a host of these stressors. It’s a permit that has to meet certain standards, such as the NCCP standard, which under state law, requires not just that you do no harm to species, but that you help restore them. It’s a much higher standard; it’s why the environmental community was willing to say yes to the Delta Reform Act. It needs to meet that standard or else it can’t be included in the Delta Plan. You may say why do we care – because then it wouldn’t get any state funding if it’s not in the Delta Plan.”
“Governance for BDCP is at the heart of the challenge. Fear was a big part of why the peripheral canal was defeated in the 80s,” said Ms. Marcus, noting that fear is still a big issue today. “Obviously the water suppliers down south are afraid that in the current setting, the water supply of California can be knocked out by salt water intrusion if those levees go down … again, I think the earthquake risk is low risk high impact. I think the impact from storm surge is probably more likely, but either way, something that important to 25 million Californians is definitely at risk.”
“The folks in the Delta are afraid that if you move that point of diversion, there won’t be as much incentive to flush freshwater down through the Delta, and not only will their ag water quality be affected and their drinking water quality affected, but then there won’t be as much state interest in helping them pay to raise the levees,” she said. “They are also afraid that this habitat restoration that is going to take place on great swaths of the Delta will deal a death blow to the culture that they love, as well as take a lot of those lands out of ag production. And many in the environmental community fear that if you just put another straw in, you’re going to take twice as much out of the Delta and that will be the death blow for the fish.”
“So fear is really the challenge, and governance is really the key to helping people feeling comfortable with whatever comes out, so my bottom line is that all of these processes are important for this working.“
There are pros and cons for the governance value of each of these processes. “The Delta Stewardship Council has review authority; it has a longer term view, and it can convene the agencies, but it doesn’t really have a lot of power and it hasn’t been tested yet. The BDCP has a governance proposal in process but it’s kind of dense; it’s got a number of groups … but the fish agencies are the ultimate determinants since this would be a permit, and they could cry foul and take the permit away if the rules are violated,” she said.
The State Water Board can set flow limitations which may be of some comfort that twice as much water won’t be going south, she said, noting that the Board is like a court that you can come to see that these things are enforced.
However, the State Water Board hasn’t always been able to step up to the plate, acknowledged Ms. Marcus. “Not because the folks at the water board aren’t terrific, not because even the board members who are political appointees didn’t want to, but sometimes it’s the politics of the moment. You had what Governor Wilson thought was the right thing to do in the 80s. So we haven’t always been able to exercise our authorities, and it can change with different appointees,” she said. “But we do control a lot of the parameters and we do have a pretty good reputation among the players.”
We also need to recognize local solutions as there are some pretty incredible things happening at the local level. In the Sacramento Valley, about 15 years ago, there was a big battle between bird groups and the rice industry over pesticides and water usage. “To make a long story short, the rice industry, the Nature Conservancy and Audubon, they couldn’t be closer now. They are thick as thieves, and they’ve created the most amazing habitat for birds by just figuring out how to be for both. I was just up there on Friday at the Northern California Water Association’s annual meeting, and they had a huge presentation on how to figure out how to do this for salmon,” said Ms. Marcus, adding “they want to generate salmon, but the only problem is they get eaten up when they get down to the Delta, so they want the rest of us to do our job.”
In southern California, the city public works department gave a local environmental group “nearly $100 million to work with to retrofit a watershed of a neighborhood … it was money they were going to spend raising the flood walls. Instead they gave them the money and they’ve put cisterns on those houses, directed gutters into storage basins, built permeable driveways and swales where the water can run into groundwater basins rather than running down the storm drains. It’s a raging success, not just in terms of flood control but it also gives you water quality benefits as well.”
“Last week, I spent two days with a bunch of people who had never been together. … I had people from Superfund, from public health, local water agencies, and the Department of Water and Power, all looking at the San Fernando Valley and the San Gabriel Valley contaminated superfund basins, figuring out how can we clean these up faster so they can be used not just for groundwater treatment and use, but so we can use them to put recycled water and storm water in. … It’s just incredible what is going on,” she said.
“Climate change is a game changer, not only because of the Delta survival threat, but also because of the issue of flooding, water supply, and storage. It makes it so we really have to be pay attention now, we can’t keep passing the buck,” she said. “People are fighting about what they can do in a given deal, but that doesn’t mean we can’t do it.”
“What do we need? We need conveyance. We need storage. We need more conservation, recycling, stormwater capture treatment and storage, and we need to protect the levees a little bit more. Right now, there’s not enough money to do everything all at once, but if we do all of these things, we can both have a more secure water future and we can make our water just go a lot further.“
“We are not at all out of water; we just use it incredibly inefficiently.”