In 2014 California enacted the Sustainable Groundwater Management Act (SGMA) which mandates that areas that depend upon groundwater achieve sustainability by 2040. Meeting the requirements of SGMA will mean a net reduction in groundwater overdraft of about 2 million acre-feet per year. The social, economic and environmental consequences—intended or otherwise—of this change in water policy are vast.
Dr. Jeffrey Mount is a Senior Fellow with the Public Policy Institute of California Water Policy Center. In this keynote speech given at the Groundwater Resources Association’s Groundwater Sustainability Plan Summit, Dr. Mount argued that the state needs to take a comprehensive look at what it is going to take to achieve groundwater sustainability and develop pathways that minimize or mitigate unwanted effects. He also noted that his speech would draw on the work of his colleagues at the Public Policy Institute of California’s Water Policy Center who have been working on the San Joaquin Valley to envision a future for the Valley under SGMA and what the consequences would be.
Is SGMA good policy? “We know SGMA is transformational and that this is probably the most significant water policy, certainly in a generation and possibly in the last 100 years,” he said. “So the question is, how do you know if it is a success? What does success look like?”
Currently, the focus is on developing Groundwater Sustainability Plans that have indicators, thresholds, measurable objectives and sustainability goals, with SGMA giving the basins until 2040 to reach sustainability. Sustainable groundwater management is defined in the legislation as the management of groundwater supplies in a manner without causing undesirable results, which are defined as:
Chronic lowering of groundwater levels indicating a significant and unreasonable depletion of supply
Significant and unreasonable reduction of groundwater storage
Significant and unreasonable seawater intrusion
Significant and unreasonable degraded water quality
One of the first milestones of the implementation of SGMA was for the high and medium priority basins to create Groundwater Sustainability Agencies to manage them. “I thought our first test of SGMA is to see if chaos ensues in the development of the GSAs, and it didn’t,” Dr. Mount said. “That’s really important, because one sign of policy success is that it didn’t.”
The signs of policy success
So is SGMA good policy? And will it be successful? Dr. Mount presented a slide with the three general dimensions of policy success, noting that the picture is Hiram Johnson who was the governor at the time when the legislature was negotiating what is considered to be the state’s modern water rights program in 1913. “He is responsible for the fact that we had to wait 100 years to get around to groundwater reform, because while they were negotiating, they basically excluded groundwater from the consideration of water rights at that time and left it as a property right,” he said. “So let’s blame him for the fact that you’re suffering so much now.”
The question of whether or not it is good policy can be broken into three categories:
Was the process legitimate? “There will be people in this room who will disagree over whether or not the process was legitimate, but were there coalitions, was there good technical support for making this policy in the first place, and was the legislature well informed as they were doing this? I will argue they probably were.”
Is it a programmatic success? “We’re in the middle of whether or not it is a programmatic success and we are seeing extraordinary, even Herculean efforts on the part of DWR to try and help this along, but this is whether or not you are meeting the objectives of the original legislation, and you’re in the middle of all of that right now.”
Is it a political success? “The jury is still out on that, but in the paper by Marsh and McConnell, they talk about political success as to whether somebody was hung for this, whether politicians were dragged into the street and shot; it’s how politically popular was it. I think it’s pretty surprising, we just had local elections and I hadn’t heard anything related to SGMA in the local elections where a politician was dragged out into the street and justifiably shot.”
Dr. Mount said he would add a fourth dimension: All big policy instruments have social, economic, and environmental consequences that either were anticipated or unanticipated, and there are a vast array of these.
“This is where you start to think about where are the big policy issues that are going to need a correction along the way and those corrections are in many ways,” he said. “It can involve new legislation, but it can be something as simple as changes in practice. It will inevitably involve litigation, the litigation wars haven’t begun in SGMA but they will be. You know it. It’s water. There will be litigation.”
The challenges of SGMA Implementation in the San Joaquin Valley
“I want to talk about the San Joaquin Valley as the test case, because SGMA was largely written for the San Joaquin Valley. We all know that what was going on in the San Joaquin Valley during the drought was so dramatic that it actually got the attention of the legislature. I’m going to give the 40,000 foot overview of what’s going on to highlight where the big policy tests are coming, or are likely to be coming with SGMA.”
The San Joaquin Valley is the richest agricultural region in California, if not the nation, and some argue even in the world, Dr. Mount said. “Farms use about 90% of the region’s water so it is extremely important to the local economy, it plays a major role in public health and the environment, and it is the state’s largest user of groundwater as a region,” he said. “Agriculture is an important industry but it accounts roughly for 2-3% of the GDP of California. … It’s extremely important in the San Joaquin Valley where it accounts for 15% of the GDP; there isn’t an industry close to it in the San Joaquin Valley. It plays a major role in employment and revenues, particularly at the county level. So it is really important at the local scale, and we worry about that. Policy worries about local-scale effects.”
“They import a lot of water and they are also relying on mining groundwater,” he said.
Dr. Mount then presented a graph showing the change in San Joaquin Valley groundwater storage from 1988 to present (lower, left). “What you see is the predominance of overdraft and quite extensive overdraft in all that time, such that you now have a structural deficit in that basin of 1.85 MAF per year. It’s probably closer to 2 MAF per year, but basically we went back to 1988 and you look at it, you have a structural deficit.”
“I’m calling it a structural deficit because an entire farm economy within that Valley is based upon that structural deficit. It’s the same kind of problem that they are having in the Colorado Basin where they have a structural deficit; they are using more water than is available in that basin, and they are going to have some major policy thresholds associated with it.”
SGMA has pushed us to that policy threshold, Dr. Mount said, noting that 1.85 MAF per year is 13% of their water supply. There are other extensive challenges for groundwater management in the San Joaquin Valley which are tests of the policy, such as thousands of dry wells, sinking lands, the loss of storage, and increased pumping costs. He noted that the pumping costs during the drought were substantial, estimated at half a billion dollars in increased pumping costs associated with loss of storage and lowering groundwater tables during the 2014-15 drought. There were also significant water quality declines and the latest study shows that arsenic is being squeezed out of the rocks as the groundwater levels are lowered.
Dr. Mount noted that there are major environmental challenges; this is an issue that might need a course correction. “You’ve lost 95% of the wetlands in the San Joaquin Valley and 80% of the annual runoff is diverted and consumed, and you have these novel ecosystems that have developed within, mix of native and non-native species which is a challenge to manage,” he said. “Again, the Groundwater Sustainability Agencies are likely going to have to face this in trying to deal with this in their Groundwater Sustainability Plans, and that’s going to be challenging.”
Under SGMA, sustainable groundwater management means two things: supply augmentation or demand management, and you’re going to have to strike a balance between the two, he said. “For supply augmentation, cost is a limiting factor, and even in a basin as dry as the San Joaquin Valley, it’s all about the cost of the water,” he said.
For groundwater pumpers in the Central Valley, the two questions you want to know are how much water can I pump and how much will it cost. Cost is going to be a limiting factor when putting together a Groundwater Sustainability Plan, said Dr. Mount. “Yet we’re in a funny phase where there are unicorns apparently in the valley that will deliver massive amounts of new water,” he said. “I sometimes feel like the PPIC views every policy from the Ice Bucket Challenge view, meaning how can I throw a cold bucket on that policy? So I’m going to throw a little cold water on this.”
“First of all cost, cost matters,” he said. “Augmentation is going to be extremely important, but you may want to start by focusing on whether things are cost effective. There are fantastic ideas out there … the most popular is Temperance Flat. I think based on what we’ve seen from the Water Commission, this might not happen, because it’s not going to get a lot of state dollars, so it is going to be very expensive, extremely expensive water. Eric Averett gave us an interesting magic number of $500 an acre foot. If water starts costing more than $500 an acre-foot, it’s darn hard to make a living on it if you are farming.”
Dr. Mount acknowledged that many of his colleagues in the UC system are incredibly excited about the idea of forest management and the yields that can be created from forest management. “I have to caution you, no one to date has shown that you can make this economically viable,” he said. “You can increase yields from those watersheds, but the amount of investment you might have to make in those yields is extremely high.”
Don’t look to move more water out of the Delta either, he cautioned. “There is nothing in the current planning put forward by the state or the federal government that would indicate that that’s likely to be a new source of water coming into the basin.”
Relaxing environmental standards will not make large amounts of new water will appear, Dr. Mount pointed out. “It turns out, it’s not large volumes of water,” he said. “It probably makes a difference in the middle years but in dry years, we recalculated the outflow of the Delta, which many members in politics in the San Joaquin Valley were decrying that any water was flowing out the Delta to the sea was water wasted to the sea … all that water that was wasted to the sea, most of it was to keep the Delta fresh enough so you could use it. Because if you don’t have an average of 4.5 MAF flowing out of the Delta into the San Francisco Bay on average every year, you can’t use the Delta; it salts up. The tides start pushing salt in.”
“So beware,” said Dr. Mount. “You could go ahead and eliminate all environmental regulations, you could get rid of the State Board, you could get rid of the federal government and everybody, you still have to run 4.5 MAF of water out through the Delta so you can use it.”
And don’t think that the Trump Administration’s policy of relaxing federal environmental regulations are going to make much of a difference, he pointed out. “The State Water Board is really in control of setting standards, and as many of you know, they are in the middle of setting standards in a water quality control plan and they have proposed to almost double the amount of water that is coming out of the San Joaquin for environmental purposes. So it’s going the opposite direction, and the state government is the first line of control; we have our own Endangered Species Act at the state level, we have our own Porter Cologne Act at the state for water quality, so I think writing your GSPs based on the assumption someone is going to overturn environmental regulations would probably be uncertain. That’s not going to do it.”
Groundwater recharge: a promising action
The most promising action is groundwater recharge, said Dr. Mount. There is a lot of interesting work going on researching the possibilities of groundwater recharge. “Since irrigation is already the primary source of groundwater recharge in this basin, the idea is to use irrigation, whether it’s flood irrigation or inefficient irrigation, to basically take advantage of wetter periods and improve recharge in the basin.”
Dr. Mount referenced the recent PPIC study, Replenishing Groundwater in the San Joaquin Valley, that studied recharge in 2017, an extraordinarily wet year. “It turns out, people were recharging all over place which was really good news,” he said. “It was substantial through active recharge, as well as passive recharge, and using all different approaches. This is the portfolio approach to recharge. This is very promising.”
In the San Joaquin Valley, there are some areas that are perfect for recharging groundwater, particularly alluvial fans which can really push a lot of water into the ground, and there are a lot of these areas in the Tulare Basin, which also happens to be the area with the highest overdraft, he said.
“This is very optimistic, right? But I have a bucket of cold water to pour on that. The problem that you have in that basin (and here’s the policy intersection that I think is important) is all the water is on the San Joaquin side and all the needs and the greatest demands for recharge are in the Tulare Basin and there is no way to get it there, other than the Friant Kern Canal.”
Conveyance is a constraint
The Friant-Kern Canal has been significantly impacted by subsidence, and cannot carry nearly as much water as it was designed for. “So you have this major problem with the ability to convey the water from the area where you have it in abundance to those areas where you could use it for recharge. It has tremendous potential, but we have some bottlenecks.”
There are hydrologic limitations, especially on the San Joaquin system; it isn’t wet very often, and when it is, it’s very wet. That’s different than the Sacramento Basin; they are distinctly different basins. In the San Joaquin Basin, if you can only take water once in a while, that’s a challenge, particularly if infrastructure is involved, Dr. Mount said.
“Most of the water that’s available in high flows is unfortunately occurring when all your canals are already full,” he said. “We saw this in 2017 when a tremendous amount of water is coming down the system, you would love to have your canals to move it around and put it into recharge areas but those canals were already full because it was the beginning of the irrigation season, and they already moving around for irrigation, so it really leads to you to this January-February-March, so it’s a narrow time constraint.”
However, the big bottleneck is conveyance capacity. Ellen Hanak and the PPIC took a look at this to see what the role of conveyance capacity in the system and how does it constrain the ability to do recharge. “It is a tremendous constraint on recharge,” he said. “Of course, the big problem is the Friant-Kern Canal which due to subsidence associated with groundwater withdrawal, has now lost slope within it; it’s actually falling apart in a number of places and can only carry 1700 cfs in it when it was basically designed to take 4000 cfs. As in the ultimate case of the tragedy of the commons, these are the kinds of things you are facing.”
Dr. Mount said conveyance improvements is the number one policy issue where others can step in. “In the interviews that PPIC did with the farmers and the irrigators in the basin, time and again, capacity was the number one constraint, which is really a surprise because usually regulatory is considered to be the number one constraint, but in this case, it was capacity,” he said. “So where I think a variety of actors can step in is in conveyance improvements. I would love to see the state of California, directed by DWR, to talk about a master conveyance plan for the San Joaquin Basin, which would basically optimize the use of available water through conveyance. That then is the water that drives the water markets that we know are absolutely essential.”
On-farm recharge needs to be promoted through incentives; there are also farmers who are very skeptical about doing recharge on their land. The State Board has to clarify the rules on the water that is available for recharge and speed along regulatory reforms to get these recharge projects going, he said. He also acknowledged that better accounting systems for groundwater use and availability are important.
The consequences of demand management
“If you do everything well, you can probably reduce your structural deficit by about 25%; that’s just the hydrologic limitation of the basin,” Dr. Mount said. “That said, the bad news is that it’s down to demand management, so demand management is going to be incredibly important. … Whereas with augmentation, the principal limiting factor is cost, for demand management, it’s going to be social and economic costs, which are going to be incredibly important, including SGMA’s requirement that some of those be mitigated.”
Dr. Mount gave some examples. He said an estimated 700-750,000 acres of land would need to be fallowed to manage the rest (three-quarters) of the structural deficit. “Most of this in the Tulare Basin which is your most productive land,” he said. “There would be job losses in the farm economy with the greatest impact to disadvantaged communities, which is the tough social aspect of this that SGMA does not care about or address.”
And during the recent drought, there were almost $3 billion in economic costs associated with each year of the drought in both additional pumping and 17,000 jobs lost. “These are not insignificant numbers. These are issues that SGMA didn’t think about or didn’t think it was going to have to address, but they are important issues.”
Another issue SGMA does not consider are the other impacts of fallowing land, he pointed out. “If you just start fallowing 700,000 acres of land in the San Joaquin Basin and the Tulare Basin, you have some major health issues associated with the dust,” he said. “Those of you who live and work in that basin know you get regular dust storms and they are very unhealthy; they are going to get worse under that. Soil quality issues – I have had a number of soil scientists tell me we have to be careful about how we do this. Of course there’s the upland habitat and weed management; the horror stories I’ve heard on weed management alone of 700,000 acres of additional fallowed land is a major problem. … And the groundwater dependent ecosystems; there are a lot of them in the San Joaquin Valley, but they are likely to be important in other places as well as you test this.”
The other factor that Groundwater Sustainability Agencies are going to have to deal with is drinking water, not just water quality, but what is happening to local domestic and small community wells.
Dr. Mount noted a colleague at the PPIC modeled the number of wells that would go dry with a 30 foot drop in the groundwater table in the basin and found that 2500 domestic wells and more than 500 irrigation wells would be affected. “The reason I’m pointing that out is because I think it’s really going to depend on how you get to sustainability. That seems like a reasonable number to plan for, but it’s this mitigation of these wells that I think is going to be hugely important in this system. This is a major policy question as well as a challenge for the Groundwater Sustainability Agencies.”
“I think a major policy question is the impact of fallowing land on rural communities, particularly the disadvantaged communities, and of course the environmental and health impacts associated with that,” he said. “Another great unknown are the water quality impacts of trying to achieve sustainability and the intersection of water quality with all of that. These are places that I think are going to be extremely important on a policy basis, and we should be teeing these things up now.”
The path chosen to get to sustainability will make a difference
The way you get there will really make a huge difference, Dr. Mount said. “I’ve given you a snarky cartoon view of the three directions you might go. One is rip the bandage off; go to sustainability as quickly as possible, which has huge economic effects on landowners as well as local communities. The other is the eat dessert first attitude, which is simply to just treat groundwater like a non-renewable resource, pump as much you can until 2040 and then close shop, and there are some sound economic reasons to do that, by the way. Then the glide path or the Goldilocks approach of ‘just right’.”
“That’s a huge differences in the amount of changing groundwater storage, so now if you’ve got 121 GSAs trying to manage 15 basins in here, and you have 121 different plans, that’s going to make a big difference in aggregate to what happens in the basin and sustainability,” he said. “That’s the part that my uncertainty is through the roof about it, and this maybe something that in fact the legislature should think about.”
Reason for optimism
There is reason for optimism, said Dr. Mount. “The PPIC will release a series of reports this fall, which will do some fairly detailed economic analysis on how to create what would be soft landing in the implementation of SGMA,” he said. “It’s not as drastic as you might imagine … we’re talking about a 10% hit to the agricultural economy, which is large and painful for some people but not nearly as dramatic as one would imagine when I start throwing out numbers like 750,000 acres. In fact, with aggressive use of markets, augmentation, deficit irrigation, crop changes, and of course the all important investments in conveyance to support recharge, that can reduce the economic impacts by half.”
This is where SGMA is basically leaving you to work this out, and where the legislature and the counties could step in to organize the changes and get to a better outcome. “The well impacts and the infrastructure costs – $600 million to fix the Friant Kern Canal, that’s a lot of money. If you make the users pay it entirely, it’s going to be very expensive. And then the rural community issues are going to have to be addressed, but this isn’t the end of the world, particularly if you use a portfolio approach to try and deal with it.”
There’s good news for the environmental side, too. “If you can get a coordinated land retirement program going, you can actually achieve some broader good both for terrestrial habitat and reducing the impacts of dust, particularly with rotational fallowing where you have cover crops and you can actually reduce the dust load. All of that requires incentives, some regulatory flexibility, and money.”
“My late mother had a wonderful phrase. We were not wealthy; we were just boring average middle class people, but to give life perspective, she would always say to me, ‘son, if it can be solved with money, it’s not a problem.’ And that’s true in a lot of instances; if money can solve the problem, it’s a solvable problem. And I think this is where the state can really step in and help out in all of that.”
The second key uncertainty is climate change. There are likely to be at least one if not two substantial droughts between 2020 and 2040, what does this mean for that structural deficit?
“Let’s just imagine for a moment, you do a great job and you’re able to get rid of that structural deficit, this is what sustainability looks like (upper, right). That’s not so bad when you look at it, that’s what sustainability would have looked like between 1988 and 2017. If you had eliminated the structural deficit, that is what it would look like.”
“The most significant thing for those of you who live and work in the San Joaquin Basin is this,” Dr. Mount said. “That drought, worst drought we’ve had in recorded history in California, it was the hottest, and at three consecutive years, it’s was the driest, so what do you do during a drought? When you’re developing your GSPs, the thing to think about is an intense drought like that, under the sustainability model, a sustainable approach is 21 MAF of additional pumping that has to go on to survive a drought like we just had, so as you’re developing your GSPs, you might want to think about it. My argument is, this is not a wipeout for the economy in the basin. You have to manage things very carefully as you do this, manage all the multiple effects, and you still have a strong agricultural economy and the GSPs are basically creating your drought resiliency, and I think that’s going to be the bottom line.”
“So is SGMA good policy? I don’t know. I’ll check back with you after January 2020 when we get to look at the GSPs,” he said. “And the jury is out on this fourth dimension of success. So this is where the community along with people who think about policy needs to start teeing up some major changes and whether this is legislation, this is going to be necessary. You need to start thinking about how you’re going to facilitate this. That has to start now, because as we know, legislation doesn’t happen overnight. That’s extremely important.”
Three final points …
Dr. Mount then had three final points. California is currently considering revitalization of water infrastructure, such as the Prop 1 storage projects and the California Water Fix or Delta tunnels project. “SGMA turns out to be embedded in all of those, and that is lost on most of the public discussions. For example, for the last ten years we have been saying it at the PPIC, if you don’t build the California Water Fix, you’re going to have to start living with less water from the Delta. Reduced reliability, and maybe even in the long run, less available water. That has to figure into your thinking as you go forward with your GSPs, because that’s a major uncertainty. That conveyance is extremely important to the San Joaquin Valley. Sites Reservoir is far less useful if you can’t get the water through the Delta to the users in the south. So it’s worth at least as a group thinking about it.”
The most difficult challenge is cooperation of the local institutions that manage water and land. “I was so struck by the number of GSAs out of that basin. There are 121 individual GSAs for 15 basins. Then here are all the other people who are laying hands on water management in the basin, so one of the biggest challenges is going to be this coordination. In fact, everything I heard in the uncertainty discussions and how to manage all that, is going to involve extraordinary coordination, and that may be one of the places you’re going to have to an unpleasant conversation about consolidation of GSAs. And that may come out, once you’ve submitted those GSPs, but to deal with this is going to be a major challenge because how are you going to augment supply if you can’t start moving water between basins, much less between GSAs? This is going to be a major challenge.”
Lastly, SGMA is the single greatest most important adaptation to climate change, he said. “Nobody even talked about that when they were doing it because 30% of our annual supply typically comes from groundwater, and 60% during drought, and right now, all of the climate models are starting to trend in the same direction with increasing drought intensity and maybe even frequency, and the recent article by Daniel Swain which talked about precipitation whiplash. So with increasing volatility in climate and with increasing intensity of drought, it’s all about groundwater. The volume of surface storage we have is so small relative to groundwater, it’s going to be about groundwater. So as you guys are going through your 5 year updates on GSPs, I just got to tell you, the conversation is eventually going to shift, eventually shift to groundwater as the most important drought reserve and then the most important hedge on climate change. I’ll give a more detailed talk on that in September.”
“To sum up, it’s going to be the same mix you all have been talking about: supply augmentation and demand management. There are places where the legislature and counties can help, and you need to start teeing that up now. We have to think about the legislation and what kind of changes in practice are going to have to happen. It’s not the end of the world in this basin, even though we’re talking about big changes in the management of the water, and economically it may not be a disaster if it is managed reasonably well and reasonably flexibly. Most importantly, what you’re doing now, when you’re developing these GSPs, is your paving the way for larger discussions, big infrastructure questions, big governance structures in the San Joaquin Valley, and climate change adaptation, whether you know it or not.”
“Thank you very much.”
QUESTIONS AND ANSWERS
Question: Your talk focused on the San Joaquin and the Tulare Basin. What about the Sacramento Valley areas? And all acres are not created equal.
Dr. Mount: “Tim has in his area a whole lot of floodplain, which isn’t so great for recharge but is still great overall for water management. The Sacramento Basin is a different kettle of fish. This is why it’s extremely important that we look at these basins individually and how they are managed. I am far more optimistic about the Sacramento system simply because of the reliability and availability of water, and I’m sure the people in the San Joaquin are interested in the reliability and availability of your water, so we look at it in general, we feel like those are very manageable problems.”
Question: You were talking about socioeconomic impacts of water management and potential reductions in water use. What are your thoughts relative to whether these impacts are going to happen in places that were land use decisions made them fundamentally unsustainable to begin with?
Dr. Mount: “You’re right; I avoided that, because it’s such an unpleasant thing to discuss over lunch. In water, like in any business, there are winners and losers and there are some places that are going to lose and there’s no amount of mitigating it. I believe personally, I don’t speak for PPIC, I just speak for myself, we have some social responsibility, particularly for some of these disadvantaged communities. The fact is, when they closed military bases, that policy had a cascade affect. It dislocated families and entire communities, so that happens all the time. So I cannot say we would want to lock in place everything that’s in the valley today as it will evolve, this land fallowing and everything else will evolve, and there will be some towns that dry up and blow away in all of that. But I do feel there is a social responsibility to make it as soft a landing as possible. I’m not sure it’s a satisfactory answer; I don’t know is the better answer.”
Question: GRA had a contemporary groundwater issues meeting and it focused on the changing landscape in California and this issue of fallowing. The conclusion we came to was that we have all these GSAs that have formed and they were formed within the context of these largely geopolitically based subasins, but the solutions need to be regional and statewide, and how do we go about doing that? That’s the tough problem … any suggestions on that?
Dr. Mount: “This is going to be highlighted extensively in the report we are going to do in the fall. there’s no easy path to a soft landing in the San Joaquin as currently organized, meaning with all these individual 120 different GSAs, there’s going to have to be some way, whether it’s consolidation or some governance structure that allows for regional coordination of these activities. The most cost effective approach is to take these regional approaches. It seems to me this is where the legislature could step in and help out, or you’re going to have to self organize as a group of the people who are doing that, bu that’s why I threw that crazy slide up there.”
“I think one of the major stumbling blocks is going to be the governance question, and we should probably start having the very difficult and unpleasant discussions about the tradeoffs between having total control over your resources versus relying on someone else to control those resources, but from an economic perspective, it makes a lot of sense. If you’re going to start doing off-site groundwater banking, and you’re going to be doing it in another basin, you need a way to move that water and move that water around efficiently and fairly. I’m with you Tim, I think this is going to be one of the great challenges, and as we get closer and closer to turning in these GSPs, I think this issue is going to rear its ugly head, and it all depends on how you resolve that. It’s a major challenge, and it usually boils down to governance. Some kind of governance.”