Update includes a project overview, the alternatives selected and analyzed, project operations, and more …
This year, California faces a big decision as the long-awaited environmental documents for the Delta Conveyance Project are expected to be released mid-year.
The Delta Conveyance Project is the latest iteration of a controversial project to construct intakes in the North Delta and a tunnel to convey the water to the existing export facilities in the South Delta. Proponents of the project say it is necessary to modernize the State Water Project and protect the reliability of project deliveries and that by having more operational flexibility, conditions for aquatic species could be improved. However, Delta advocates say that the northern intakes would divert water away from the Delta, worsening water quality in the Delta and threatening the already fragile and ailing ecosystem.
The Delta Independent Science Board is preparing to review the environmental documents for the project when they become available later this year. At the January meeting of the Delta Independent Science Board, Carrie Buckman from the Department of Water Resources provided an overview and an overview update on the project.
Ms. Buckman began by noting that the previous presentations had discussed the changes in precipitation and climate that the Central Valley Project and the State Water Project operate within.
“As DWR is the owner and the operator of the State Water Project, we understand that this new normal and these changes will persist, and it does reinforce the need to modernize the Delta conveyance system,” she said. “We do expect less snow and more rain over a shorter and less predictable duration, and we expect more frequent drought and flood cycles. So the goal that we’re considering through the Delta Conveyance Project is to try to capture water when it’s available to store for later use in droughts. So we’re hoping that by adding points of diversion and creating flexibility, it will promote a more resilient and flexible State Water Project in the face of these unstable future conditions.”
The last few years provide an example of how this could work, she said. The last few years have been dry, and last year, the State Water Project diverted almost no water from the Delta except for health and safety purposes. The deliveries that the State Water Project was able to make were associated with diversions that occurred in prior years in 2019. So the ability to capture water when it’s available becomes even more important moving into the future as climate conditions continue to change.
The stated purpose of the Delta Conveyance Project is to modernize the aging State Water Project (SWP) infrastructure in the Delta to restore and protect the reliability of SWP water deliveries cost-effectively, consistent with the state’s water resilience portfolio. The project objectives are to address sea level rise and climate change, minimize water supply disruption due to seismic risk, protect water supply reliability, and provide operational flexibility to improve aquatic conditions.
Environmental Impact Report (EIR)
The purposes of an environmental impact report (or EIR) include:
- To present information based on the best available science to demonstrate an effort to inform the public and decision-makers about a project’s potential significant environmental impacts and ways to avoid, minimize, reduce, or compensate for them.
- To demonstrate that the environment is being considered before approving the project, and that the agency has considered the environmental implications of this action.
- To ensure the prevention of environmental damage where possible by requiring the implementation of alternatives or mitigation measures.
The slide provides an overview of the CEQA process. The process started with Notice of Preparation in January of 2020; scoping meetings were conducted, and reports were prepared that summarized the process and included all the comments received, both oral and written. An agency outreach plan was developed.
The project then moved to a definition phase, where alternatives were identified and defined. This work was done in collaboration with the Delta Conveyance Design and Construction Authority, which formed a stakeholder engagement committee to help identify ways to avoid effects to local communities through the design and construction process. Reports were then prepared to understand the technical aspects of the potential effects of those alternatives.
The Department is currently analyzing the impacts of the alternatives based on all of that information and, where appropriate, including mitigation. They will next develop the EIR for release in mid-2022. It will then be circulated for public comment, and public meetings will be held to collect comments. The Department will then respond to those comments, make changes in the draft EIR, select a preferred alternative, release a final EIR, make a decision, and issue a notice of determination.
Alternatives
All of the alternatives went through a screening process. The alternatives were collected from various sources, including the scoping comments, alternatives from past documents, and ideas that technical experts had. All of the alternatives were screened using CEQA criteria to identify if they had the potential to meet most of the project objectives and potentially reduce the significant environmental impacts of the proposed project.
Based on the screening, alternatives were identified to be analyzed in detail in the EIR. Those include:
- A central alignment, shown in orange, which is similar to the alignment for the California Water Fix. They are considering multiple capacities of 3000 CFS, 4500 CFS, 6000 CFS, and 7500 CFS.
- An eastern alignment closer to I-5, shown in blue. They are considering multiple capacities of 3000 CFS, 4500 CFS, 6000 CFS, and 7500 CFS.
- The Bethany Alternative, which follows the eastern alignment partway down and then shifts south to connect directly to Bethany Reservoir; it would have a capacity of 6000 CFS.
One thing that was said in the public comments was that, rather than only looking at the Delta Conveyance Project, the Department should consider alternate supplies within the water agency service areas.
“The idea is that if the State Water Project didn’t provide that water, then water agencies could take other actions to provide alternate supplies,” said Ms. Buckman. “That does not meet our fundamental objective for this project, which is to continue having a reliable water supply from the State Water Project. But we recognize those are likely efforts that water agencies would take if the Delta Conveyance Project were not to move forward. So as a result, we are including other potential actions as part of our no project alternative and analyzing the potential impacts and benefits there.”
Central alignment
The number of intakes on the Sacramento River varies depending upon capacity. The figure on the slide shows a 6000 CFS facility with two intakes, intakes 3 and 5. The 7500 CFS alternative would have three intakes; the 3000 CFS only one.
A tunnel 42.9 miles long would connect the intakes from the North Delta to the South Delta. The tunnel would include three launch shafts, three maintenance shafts, and three reception shafts.
The green arrows on the map show where the tunnel boring machines would launch. There would be a double launch shaft in the north at Twin Cities; one tunnel boring machine would launch north and come out at the northernmost intake, and another would launch south to be removed at Bouldin Island. Bouldin Island would also be a launch shaft where a tunnel boring machine would be launched south where it would meet the tunnel boring machine coming north from the southern forebay at Bacon Island.
At the southern end of the tunnel, a pump station would pump the water from the tunnel up to a southern forebay that would help reregulate the flows; it would then connect to the Banks Pumping Plant to pump the water again up into the California Aqueduct. She noted that because there would be two pump stations, the forebay is needed for reregulating the water. There are a set of tunnels 1.7 miles long to connect the southern forebay to the Banks Pumping Plant.
The 7500 CFS option includes a connection to the Central Valley Project and requires an additional tunnel to connect to the Jones Pumping Plant approach channel.
Eastern alignment
The eastern alignment had the same facilities as the central alignment at the northern and southern ends; the tunnel’s alignment is what’s different. From Twin Cities launch shaft north, it would be the same facilities. But from Twin Cities moving south, instead of going through the Central Delta, this alignment stays closer to I-5. The idea is that it might simplify logistics so that the construction traffic doesn’t need to go into the Delta, and there are higher ground elevations and better shallow ground conditions for tunneling.
This tunnel would be 45.6 miles, and there would be three launch shafts, four maintenance shafts, and three reception shafts. The launch shaft at Twin Cities would again be a double launch shaft; another launch shaft at Lower Roberts Island would launch north, meeting the tunnel boring machine from Twin Cities for removal at Terminus Tract. The tunnel boring machine in the south would go north towards Lower Roberts Island, a reception shaft.
Bethany Alternative
The Bethany alternative has not been considered in past efforts. This alternative uses the same northern facilities as the central and eastern alignments; from Twin Cities to Lower Roberts Island, it is the same as the Eastern alignment. But from Lower Roberts Island south, there are some pretty substantial differences.
So instead of going to a new set of southern facilities, the Bethany alternative would have a tunnel that connects to Bethany Reservoir, a regulating facility, and a ‘wide spot’ on the California Aqueduct. This alternative would have a pump station from the tunnel into Bethany Reservoir. Since only one pump station pumps the water from the tunnel to the aqueduct, the southern forebay, a large facility in the South Delta, would not be needed.
This alternative includes 44.6 miles of tunnel, two launch shafts, a double launch shaft at Twin Cities, and a double launch shaft at Lower Roberts Island. There are five maintenance shafts, three reception shafts, and about 3 miles of four pipelines going from the pump station to the Bethany Reservoir.
The Bethany alternative is the proposed project
When the Notice of Preparation was released in January of 2020, the proposed project was identified as having either a central or an eastern alignment. However, now they are identifying the Bethany alternative as the proposed project in the draft EIR, so the Department recently sent a letter to the Corps of Engineers to amend their 404 permit application to include the Bethany alternative.
“The idea of alternatives analysis under CEQA is to consider a range of alternatives that has the potential to reduce significant environmental effects,” said Ms. Buckman. “We found that the Bethany alternative does reduce effects for wetlands and waters, which are important, not just for CEQA, but also for Section 404 permitting with the Corps of Engineers.”
Ms. Buckman did have a few caveats. “We’re changing the proposed project, but that doesn’t mean that we’ve made a decision. CEQA case law requires that we include a proposed project in our draft EIR, and so it just represents our current thinking. Right now, we think the Bethany alternative would reduce effects compared to central or eastern alignment, but we recognize that the public comment period could bring new issues to bear. So we’re not making any decisions on which alternative to implement, or to implement the project at all, until after the public comment period is complete, and we’ve responded to and addressed those comments.”
Project operations
The new North Delta diversion intakes would operate in a dual conveyance system, where the northern intakes would be operated jointly with the existing South Delta intakes and the Banks Pumping Plant. The new diversions would give the flexibility to use either the southern or northern facilities. So in analyzing the project, they need to put together a set of assumptions about how the North Delta intakes would be operated with the South Delta facilities.
“With the California WaterFix, there was an assumption that the two facilities would be operated pretty equally,” said Ms. Buckman. “But as we have gotten into this in more detail and talked to our operators, that’s not how they think they really would operate the facilities. They think that they would first operate from the South Delta. So during the winter and spring, they would use the South Delta to operate to the permit diversion capacity. And then the North Delta would augment excess diversions during really high flow periods. So it would just be used to augment diversions when there are high flows in the Sacramento River.”
“During the summer and fall, there may be some shifting from south to north to help manage salinity and realize potential carriage water savings, but those are fairly small,” she continued. “We think that these assumptions will help maximize benefits while also minimizing impacts.”
The Department is developing a set of new operational criteria for the intakes while also making sure that existing Delta operational criteria are met. The criteria are primarily based on the 2020 Incidental Take Permit for long-term operation of the State Water Project that DWR holds with the Department of Fish and Wildlife.
The D-1641 requirements from the State Water Board include the export inflow ratio, and the new project would account for the North Delta diversion as part of the exports in that calculation. It also includes meeting Old and Middle River flow requirements and export limits from the Incidental Take Permit.
“Our operational criteria are a starting point for the analysis,” said Ms. Buckman. “What we’re planning to do is take these criteria, analyze operations, and if we have effects, then we may consider either mitigation or changes to these operational criteria to try to help reduce those effects.”
The criteria are to avoid effects to fish; they are based on the conceptual model that there are periods throughout the wet season where juveniles are outmigrating, and pulse flows based on cues for the fish.
“We’re developing a set of criteria that will have a set of bypass flow requirements that are always in place,” said Ms. Buckman. “The idea is that when the river flow is very low, there will be no diversion. Then generally, there will be a low flow diversion. Then, when the river level reaches a certain point, we can gradually increase diversions from the North Delta facility until flows are very high when we would meet the 6000 CFS.”
“I think that there’s a perception that if this project were built, it would be operated at 6000 CFS year-round, and that that’s not the case,” she continued. “We would only be able to operate that under pretty high flow conditions in the Sacramento River. In addition, we would layer on a set of pulse protection requirements, so during times that there are pulses of fish, we would further reduce those flows to protect the fish pulses.”
There will also be a set of approach and sweeping velocity requirements for the reach of the intakes that must be constantly met. The approach velocity is how fast the water moves into the fish screen and through the fish screen; the sweeping velocity is how fast the water moves past the fish screen. The fisheries agencies set those requirements to ensure the water helps the fish move past the intakes and reduces near-field impacts of the fish screen.
Community benefits program
In 2021, the Department focused on developing a community benefits program to incorporate into the proposed project. Given that this is a program for the community, the Department has been working to gather input from the community.
“A community benefits program is a defined set of commitments made by the project proponent, in coordination with the local community, to create tangible and potentially significant economic and social benefits for residents, businesses, and organizations facing project impacts,” said Ms. Buckman. “We understand that CEQA is a pretty prescriptive process. And so the things that are analyzed under CEQA and mitigated under CEQA may not consider the full suite of effects felt by the local communities during construction of this project.”
“We wanted to consider ways that we can provide benefits to the local community above and beyond what is required under CEQA,” she continued. “We started with a concept paper at the beginning of 2021. We then spent time interviewing community members and produced an interview summary report. We then held public and tribal community benefits program workshops to collect additional information and talk through some ideas. And we had a case study workshop where three participants in other community benefits programs came and talked about lessons learned and how they organize their programs. And we’re working towards having a framework for the community benefits program included as part of the draft EIR.”
The 2021 year in review
Most of the work in 2021 focused on CEQA and NEPA. They have continued to develop the EIR and EIS to identify potential impacts and mitigation measures to reduce impacts. The Department has also been consulting with tribes and will continue to identify potential effects on tribal cultural resources and consider impacts and mitigation. The Department has also worked with the tribes to conduct surveys on accessible parcels.
The Department has continued consultation with the resource agencies on developing the initial set of operational criteria to meet the requirements under the Endangered Species Act and California Endangered Species Act. They have also been working with the resource agencies to identify tools to assess potential effects.
Regarding the water rights process, the Department plans on submitting a petition for a change in the point of diversion in late 2022. The State Water Board will be a CEQA responsible agency, so the Department has been coordinating with the State Water Board about what is needed as part of the EIR to utilize that in their process. Additionally, the Department is coordinating with the Delta Stewardship Council through the early consultation process to prepare for certifying consistency with the Delta Plan.
They also hosted a series of informational webinars last fall to provide background information in preparation for the release of the draft EIR.
“We’ve heard from several sources that it can be somewhat impenetrable for a public audience, so we wanted to provide some background information that would help people review it when they get the document this year.”
The relationship between the Environmental Impact Report (EIR) and the Environmental Impact Statement (EIS)
The environmental impact report (or EIR) is a document prepared under the California Environmental Quality Act, and the environmental impact statement is prepared under the National Environmental Policy Act.
For the Delta Conveyance Project, the Army Corps of Engineers must consider whether to permit the project under two permitting requirements:
- Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act regulate the discharge of dredge or fill in Waters of the US.
- Section 408 considers alterations of federal levee projects.
The Army Corps of Engineers is functioning as the NEPA lead and is developing an EIS to support their permitting decisions.
“I want to be really clear that they’re not a project proponent, but a regulatory agency,” said Ms. Buckman. “Often, the NEPA lead would be an agency that is also helping to fund or implement a project. But that’s not the case here; the Corps is permitting the project potentially, and so they’re doing this as a regulating agency.”
The EIS will have similar information to the EIR, but there are a few key differences:
- The Corps has requirements for brevity, so the document will be shorter and will refer to the EIR in some areas.
- NEPA does not require significant findings in an EIS, but the CEQA does.
- The baseline for impact analysis is different. Under CEQA, the potential impacts of alternatives are compared to existing conditions, which are the conditions that existed at the time of the publishing of the Notice of Preparation, which was January of 2020. For NEPA, the Corps will compare the alternatives to a future no-action alternative, or what would happen in the future absent the project.
Ms. Buckman acknowledged these aren’t all of the differences, just a few of the key ones. There will be two separate documents for review.
Project schedule
The Department is currently preparing the draft EIR. The Army Corps is preparing the draft EIS; public review of these documents is expected later this year, currently anticipated to be May or June of 2022. Although the Department is anticipating a 90-day review, the Corps is contemplating a shorter period. Still, they are trying to align most of the public review period so those reviewing the documents will be able to look at both simultaneously.
After the public review period, the agencies will respond to comments and finalize the documents with a decision expected in late 2023. Most of the work on the permitting processes is expected to occur in 2023 and 2024.
Standard of adequacy for EIRs
Ms. Buckman then turned to discuss the standard of the adequacy of an EIR. A lot of the public comments are focused on whether the EIR is good enough. CEQA does have some guidelines:
- The EIR should provide decision-makers with a sufficient degree of analysis to provide information to make a decision that intelligently takes account of environmental consequences as evidenced by substantial evidence in the agency’s administrative record.
- The evaluation doesn’t need to be exhaustive. Information should be reviewed in light of what is reasonably foreseeable.
- Disagreement among experts does not make an EIR inadequate, but it does need to disclose and summarize their disagreement.
- Perfection is not the standard. So the EIR is reviewed for adequacy, completeness, and a good faith effort at full disclosure.
Key content issues for comment
Ms. Buckman also noted the types of content issues provided in public comments:
- Project description: is the project adequately described to understand the potential environmental effects?
- Environmental setting: Is the physical environment at the time of the Notice of Preparation adequately described based on existing and available information?
- Impacts: Are the impacts evaluated in light of what’s reasonably foreseeable? The impacts need to include direct and indirect, growth inducing, and cumulative effects.
- Alternatives: Are feasible alternatives evaluated that meet the project objectives and would avoid or reduce potential significant impacts of the proposed project?
- Mitigation and monitoring: Are mitigation measures included to address the potentially significant impacts, and are monitoring requirements incorporated?
Upcoming outreach
In anticipation of the release of the draft environmental documents, the staff is focused on three areas:
- Information and resources to help the public be able to review the documents, including videos, website information, factsheets, graphics, and other materials.
- Outreach and engagements through emails, meetings, briefings, and presentations.
- Opportunities for review and provide formal comments through workshops, fliers, publicity, putting information in libraries, and translating materials. They will be continuing their tribal consultation and environmental justice outreach processes.
QUESTIONS AND ANSWERS
QUESTION: What’s the diameter of the tunnel? And how deep is it buried?
Ms. Buckman: “The tunnel diameter varies based on the capacity; it’s about 40 feet diameter on the inside diameter, but that it’s smaller for some and larger for others. And the depth to the top of the tunnel is about 100 feet, but that also varies depending on where the tunnel is. So there is about 100 feet on the top and about 150 on the bottom.”
QUESTION: Is the scope of the EIR going to be principally on the impact of the construction of the tunnel? Or will it also be ‘equally weighted’ on the operation or resulting changes in flow that the tunnel will cause and environmental impacts related to that?
Ms. Buckman: “We’re working on trying to capture the full suite of environmental impacts, which can include impacts from construction operations and maintenance. I wouldn’t necessarily talk about weighting; we’re not saying that one set of potential effects is more important than another, but we are trying to consider and disclose all of them.”
QUESTION: How many pages long will the EIR be? The last one was something like 30,000 pages …
Ms. Buckman: “It’s not written yet. We just are starting to draft it, so I don’t think I can answer that. But I will say that you are not the first person to mention that the California WaterFix document was too long to read for most people. And so, we are trying to make a concerted effort to make this shorter, more concise, and easier to get through. How successful we will be, I don’t know yet. But, hopefully, in our next discussion, I’ll be able to give you more details.”
QUESTION: What will happen to all the excavated material for the tunnel?
Ms. Buckman: “We are seeking to try to reuse it as part of project construction where that’s possible. So for the central and eastern alignments with a southern forebay facility, there is the reuse of material to construct the embankments around that facility. For all of the alternatives, there is some reuse at the shaft site because those shafts need to be built up to above-ground a bit to maintain flood protection. So there will be some reuse there as well.”
“The material that can’t be reused is going to be stockpiled at the launch site at Twin Cities and somewhat at Lower Roberts Island as well. That material, we do allow to be reused in the future for other projects, potentially levee projects in the Delta, other projects in the Greater Sacramento or Stockton areas. But we don’t know where those projects could be, and to make assumptions about that would be speculative. So we’re analyzing leaving it there so that we can look at the potential impacts of having those stockpiles and make sure that we disclose those in the EIR.”
QUESTION: I don’t understand why this project needs to take place. Could you summarize for me just quickly why this project is even being proposed?
Ms. Buckman: “The main issues are related to the future and continued degradation of State Water Project diversion [capability] in the Delta. As we look forward, because of climate change, primarily sea level rise, potential earthquake risk, and changing regulations in the Delta, we anticipate future supplies for the state water project are going to decrease pretty substantially.”
“With climate change, we do expect future conditions to be different. Right now, the snowpack provides essentially another kind of storage, and we anticipate substantially less snow in the future. So we will have flashier winter storms with more rain and less snow, and that alone will change the ability of the State Water Project to capture that water. So, having a program like Delta Conveyance Project where you can take those high flows and divert them will help provide a more sustainable future water supply.”
QUESTION: How much consideration was given to the fact that rivers need high flows to maintain their ecological vitality? Without those high flows, they just become canals. And it seems to me that, looking in from the outside, is why can’t the river continue to be the primary form of conveyance during the period of high flows?
Ms. Buckman: “We are definitely considering the potential effects to fish and other conditions within the river associated with the diversion. One of the things that we were talking about is that this would be during high flow conditions where diverting the potential up to 6000 CFS wouldn’t change the flows … these are really high flow periods. And so this would still be a very wet period on the river; it wouldn’t be taking all of the water and resulting in a dry condition in the Delta, if that makes sense.”
“So, while we are diverting water, it is during high flow conditions where the difference is a smaller percentage of the flow. The other thing is, we’re looking at the conditions and how that could affect fish, water quality, and other resources in the Delta. The way we’re looking at this project is, it doesn’t really have the potential to affect the situation upstream from the river or upstream from the Delta in the river system. We’re not looking at changing operations of the reservoirs upstream or the river systems; those will be operated the same way that they are absent the Delta Conveyance Project.”
QUESTION: Will the public or the ISB have an opportunity to comment on how the EIR or EIS will be structured? I ask this because I’ve been involved in these in the past, and the bar for both the EIRs and EISs I’ve reviewed has been shockingly low from an ecological perspective. So will we have an opportunity to comment on how these documents might be structured?
Ms. Buckman: “That was the point of the comments in the Notice of Preparation … The ISB provided comments on the Notice of Preparation for CEQA, some to that effect, and we are considering those during the development of the EIR. I don’t know if the ISB provided comments on the environmental impact statement to the Corps, but the Corps conducted scoping in August 2020. And at this point, we’re further down the road. But that was the time to provide those comments.“
DISB Chair Dr. Steve Brandt added that based on our previous EIR review, they submitted a number of comments on how to present the material.
QUESTION: I understood that you said that you have not decided upon the Bethany alternative, but is the EIR going to be based on the Bethany alternative? And what happens if you decide on the central alignment, which is quite some distance from the Bethany alternative?
Ms. Buckman: “Most EIRs focus on a proposed project and analyze the alternatives in much less detail. And that’s what CEQA directs. But because we’re partnering with an environmental impact statement that has to consider all alternatives at a similar level of detail, we are looking at all alternatives at the same level of detail. So while we are identifying the Bethany alternative as the proposed project, we are fully evaluating central and eastern and the variety of different capacities. So because we would have all of that impact analysis in the EIR, we would still have the flexibility later to say, we understand that there are these other factors and so, therefore, we are looking at considering this different proposed project.”
QUESTION: I had a question about the community benefits program. Could you give more detail as to the types of benefits that would be considered or might be being discussed? How does that program factor into the decision-making process, if at all?
Ms. Buckman: “I gave a very broad overview because I can easily talk for a half-hour about the community benefits program alone. Right now, we’re looking at two key pieces associated with the community benefits program. One of them is the Delta community fund. The idea is that it would fund potential efforts of the community in support of maintaining the Delta’s ecological, economic, recreation, cultural values, as they’re trying to fundamentally help Delta as a place. It would be funded with the construction costs. And that’s not funded by DWR; it would be paid for by the water agencies that receive the water.”
“The other piece of the effort is implementation commitments. The idea is that there are some pieces of project implementation that may provide benefits to the community. Examples of those are things like, we’re building park and rides, and the communities may want those to stay after the project construction is done. Another one is the internet; we’re bringing high-speed internet to the intake facilities, and we could very easily provide a way for local communities to connect to that. So those are the key things that we’re talking about. We asked for project ideas and got a lot of them.
“We’re putting together a framework based on what we’ve heard and what we’ve discussed with community members. That will be part of our EIR, and it will be in all of the alternatives, so it’s not specific to an alternative. This is something we think matters for all of the alternatives, and so it’s included across the board.”
QUESTION: Is Reclamation involved in any consequential way in its operation?
Ms. Buckman: “No, at this point, they haven’t indicated an interest in participating as a lead agency, so they are not. This is a State Water Project-only facility, although we do have some alternatives that include the potential for them to be involved. And that’s partially because we have a record that they had been involved in WaterFix. So because people want to see how the impacts and benefits would change, we did include them in alternatives, but the Bureau of Reclamation has not indicated an interest in being part of the project.”
QUESTION: Is May a realistic timeframe, so we should start setting aside three months of our lives starting in May?
Ms. Buckman: I’m saying May or June. I don’t have a date yet. But I do think that that’s that at the moment. We’re looking pretty solid on releasing them in May or June.
