#ColoradoRiver: Moffat Collection System Project update #COriver

Denver Water's collection system via the USACE EIS
Denver Water’s collection system via the USACE EIS

From The Wall Street Journal (Jim Carlton):

Next year, the U.S. Army Corps of Engineers is expected to decide whether to issue a permit to triple the capacity of Gross Reservoir in the Rocky Mountain foothills, with additional shipments of about 18,000 acre feet of water a year from the Colorado River watershed. An acre foot is enough water to meet the annual needs of an average family of five.

That is one of the last regulatory barriers for utility Denver Water’s $380 million project, for which district officials say they hope to break ground in 2019 to help ensure local water supplies.

“We have an obligation to supply water,” said Jeff Martin, Denver Water’s manager of the project, as he stood recently atop a 340-foot concrete dam that is to be raised by 131 feet under the plan. “It’s not an option to not have water.”

[…]

The Corps of Engineers is expected to decide next year on a proposed new “Windy Gap” project in Colorado, which would divert up to another 30,000 acre feet a year to the Front Range, the heavily populated area where the Rocky Mountains rise up from the plains.

In addition, more than 200,000 acre feet would be diverted for proposed projects in Utah and Wyoming…

Water officials in California and other lower basin states say they aren’t overly concerned about more diversions upstream, because a 1922 compact requires the upper basin states to deliver them about 7.5 million acre feet a year, or one half the river flow set aside for human use north of the U.S.-Mexico border. Much of that water is stockpiled in Lake Powell on the Arizona-Utah border.

With the Colorado running much lower than when the compact was signed, water experts say there is less water to divert.

“So long as their development doesn’t impinge on their release to us, that is their business,” said Chuck Cullom, a program manager at the Central Arizona Project in Phoenix, which pulls from the river and stands to lose a fifth of its deliveries if a shortage is declared on the Colorado. “If it falls below that, then they would have to figure out how to manage their demand.”

Don Ostler, executive director of the Upper Colorado River Commission, which oversees use of the river in the upper basin states of Colorado, Utah, Wyoming and New Mexico, agreed that new diversions increase the risk of shortages.

“The more you develop, the more a severe drought can affect you,” said Mr. Ostler. “But we are able to live with a certain amount of shortage.”

In Denver, water officials don’t feel they have much choice but to seek more Colorado water.

In 2002, tons of sediment from a forest fire clogged one of Denver Water’s reservoirs during a drought. “We came close to running out of water in the northern end of our system,” said Jim Lochhead, chief executive officer of Denver Water, a utility that serves 1.4 million people.

That crisis helped prompt the district in 2003 to undertake the Gross Reservoir expansion, which would store more water from an existing tunnel that transfers Colorado River water from the west side of the Continental Divide.

Denver officials pledged to only take the water in wet years and release more into streams when it is dry—measures that drew praise from some conservationists…

Gov. John Hickenlooper in July gave the state’s approval, calling the dam’s expansion vital. “The state’s responsibility is to ensure we do the right thing for Colorado’s future,” the Democratic governor said at the time, “and this project is vital infrastructure for our economy and the environment.”

The dam that forms Gross Reservoir, located in the mountains west of Boulder. Photo: Brent Gardner-Smith/Aspen Journalism
The dam that forms Gross Reservoir, located in the mountains west of Boulder. Photo: Brent Gardner-Smith/Aspen Journalism

#ColoradoRiver Economics: “…our new economy is based on water in the rivers in western Colorado” — Jim Pokrandt #COriver

Hayfield message to President Obama 2011 via Protect the Flows
Hayfield message to President Obama 2011 via Protect the Flows

From KRCC (Maeve Conran):

It’s been almost a century since the Colorado River Compact was created, divvying up the resources of this mighty waterway between seven states and Mexico. That means almost 40 million people are dependent on the river in some way. Traditionally, the economic value of the river was based on what the water could be used for when extracted—things like agriculture, mining, and industry. Now, more people are pointing to the economic value of keeping water in the river itself.

The Fraser River in Grand County is a tributary of the Colorado River, which starts in Rocky Mountain National Park. It runs through the heart of the town of Fraser and neighboring Winter Park. These towns attract skiers in winter and fly fishers and outdoor enthusiasts the rest of the year.

“The recreation is all based around the river… it’s the absolute base of the recreational system,” says Dennis Saffell, a real estate broker in the mountain communities of Grand and Summit Counties. Saffell says there’s a direct connection to property values and proximity to the river…

Saffell says a loss of flow in the river would likely decrease the values for all properties in these mountain communities that are dependant on the river for a tourism economy.

That’s something that others in western slope communities are well aware of, including Jim Pokrandt with the Colorado River District, the principal water policy and planning agency for the Colorado River Basin within the state.

“We understand that water left in the river is important to the economy,” says Pokdradt, “and if we have dried up rivers then we’d have degradation to our western slope economy.”

Pokrandt says the fortunes of many western slope towns hinge on understanding that the strength of local economies is beginning to shift from taking water out of the river to leaving it in.

“Rafting, that’s a big deal, skiing that’s a big deal now, hunting, fishing… this is our economy here on the west slope,” says Pokrandt. “Yes, ag is still big, and yes there’s still some mining, but our new economy is based on water in the rivers in western Colorado.”

Historically, most Colorado water rights have involved uses that divert water from the streams, but back in the early 1970s lawmakers began to recognize the need to create rights allowing water to remain in the river, to help protect ecology. But that was just a first step. Now 43 years later, a lot of water is still being taken out of the Colorado River basin and diverted to the east. There are 13 major trans mountain diversions and many other smaller ones.

It’s a concern for advocates like Craig Mackey, co-director of the non-profit Protect the Flows.

“In the 21st century we have an economic reason to have the river itself, the recreation economy, the tourism economy and I think the hardest one to quantify is a quality of life economy,” says Mackey.

Protect the Flows advocates for conservation of the Colorado River Basin, pointing to the connection between a healthy river and healthy economies.

“People want to live here, they want to locate here, they want to grow businesses here, they want to raise their families here,” says Mackey. “And water and our snow in our mountains, which becomes the water in our rivers, is a huge driver in that quality of life economy that we’re so lucky to have here in the state of Colorado.”

Protect the Flows worked with Arizona State University in 2014 on the first study on the economic impact of the Colorado River. It found that the major waterway generates $1.4 trillion in economic benefits annually throughout the entire seven state river basin. In Colorado, the tourism and outdoor recreation economy tied to the river brings in more than $9 billion annually.

The Colorado Water Plan acknowledges the need to keep water in streams, but it also acknowledges the water needs of growing cities.

Realtor Dennis Seffell says even more needs to be done.

“Now it’s time to take a new fresh look as to why it’s important to keep rivers full of water,” Saffell says.

A prolonged drought in the south west, paired with over allocation, has left the Colorado River in a sorry state. Front Range communities, largely dependent on that western water, are having some success with conservation. But with an additional 2 million people expected to move to the Denver metro area over the next 25 years, demand will only increase.

Connecting the Drops is a collaboration between Rocky Mountain Community Radio stations and the Colorado Foundation for Water Education, with support from CoBank.

Arvada: Rate increase in the cards?

arvadareservoir
Arvada Reservoir via the City of Arvada.

From The Wheat Ridge Transcript (Shanna Fortier):

Owners of a typical single family home in Arvada will likely have to pay $1.41 more a month — or $16.90 additional a year — for water and sewer services fees in 2017.

The average single-family home is considered to be 3.2 people and a yard. And the average single family drinking water bill in Arvada runs about $481 annually and $291 annually for sewage.

Jim Sullivan, director of utilities for Arvada, said the average single-family account in Arvada uses 120,000 gallons of water each year for domestic and irrigation purposes and generates 60,000 gallons of sewage. Single-family accounts form the largest customer group in Arvada, using about 60 percent of the water.

Arvada City Council heard the proposed rate increases at the Sept. 26 workshop and will discuss the proposals during council meetings on Oct. 3 and Oct. 17, also the date of a public hearing. The rates have been raised every year over the past decade.

When taken separately, the proposed increases amount to 2 percent for water and 3 percent for wastewater. A 1.45 percent increase for water tap fees is also proposed. Stormwater and sewer tap fees are not projected to increase, city officials said.

The increases are needed because of rising vendor prices, new equipment and materials, and employee salary raises, Sullivan said.

Sullivan added that over the next 10 years, water operation costs will likely slowly increase as the city prepares to contribute payment for the Denver Water Gross Reservoir expansion project.

Sources of water

Arvada has two sources of water. The first is a 1965 contract with Denver Water. The second source is the city’s Clear Creek water right holdings.

But “these two sources will not be sufficient to meet the residents’ needs at buildout of the city,” Sullivan said. “The city has entered into an agreement with Denver Water to financially participate in the Gross Reservoir expansion in exchange for additional water supplies. This project should increase Arvada’s water supplies sufficiently to meet the city’s needs at buildout.”

Gross Reservoir, named for Denver Water former Chief Engineer Dwight D. Gross, was completed in 1954. It serves as a combination storage and regulating facility for water that flows under the Continental Divide through the Moffat Tunnel and supplies water to Denver Water’s North System.

The reservoir was originally designed with the intention of future expansion to provide necessary storage.

With demand expected to increase in coming years, expanding Gross Reservoir will increase sustainability to the water supply as part of Denver Water’s multi-pronged approach that includes conservation, reuse water and developing additional supply to meet customers’ future needs.

“We think we have enough money in the fund to avoid issuing debt for this project,” Sullivan told city council.

The proposed 2017 water fund budget is $29 million, with 75 percent going toward water system operations, 8 percent for debt services and 17 percent for capital improvements. The Gross Reservoir project is the majority of the capital improvements area.

The city’s current debt service is $2.2 million, paid mostly from tap fees, Sullivan said. He added that in 2020 the water bonds issued in January 2001 will be paid off.

The projected increase in the operations budget for water is $656,000 or 3 percent. However, the bond repayment in 2020 will reduce operating costs by $445,000 annually. Because of this, city staff is proposing to increase water rates by 2 percent rather than 3 percent in 2017, smoothing out future rate changes.

The proposed 2 percent rate increases the water fee part of the bill by $8.52 annually or 71 cents per month. The 3 percent increase for wastewater amounts to $8.40 annually or 70 cents per month.

It is expected that by 2023, the 20-year program to rehabilitate the sanitary sewer system in the city will end and the $2 million needed annually will drop to $500,000 for major repairs and maintenance.

The water tap fee increase of 1.45 percent applies to new construction and would increase by $275, bringing the total cost of a single family water tap to $19,275.

Denver Water is seeking approvals from the U.S. Army Corps of Engineers, the U.S. Fish and Wildlife Service, and the state of Colorado to expand Gross Reservoir, which is southwest of Boulder. The 77,000 acre-foot expansion would help forestall shortages in Denver Water’s water system and offer flood and drought protection, according to Denver Water.
Denver Water is seeking approvals from the U.S. Army Corps of Engineers, the U.S. Fish and Wildlife Service, and the state of Colorado to expand Gross Reservoir, which is southwest of Boulder. The 77,000 acre-foot expansion would help forestall shortages in Denver Water’s water system and offer flood and drought protection, according to Denver Water.

#ColoradoRiver: The Plan to Strengthen Denver’s Water Supply — 5280.com #COriver

Gross Dam enlargement concept graphic via Denver Water
Gross Dam enlargement concept graphic via Denver Water

From 5280.cm (Amy Thomson):

Considering the Denver region is growing by an average of 4,500 new residents per month, a large sector of the population likely doesn’t remember the catastrophic 2002 drought. The most severe water shortage since the Dust Bowl, snowpack and soil moisture were at all-time lows, and we remained in a dry period until 2006. Luckily, with water restrictions in place, we never actually ran out of water—we just got really close.

“We realized that we had an immediate need to correct a vulnerability in our system,” Denver Water CEO Jim Lochhead says. That’s when Denver Water started planning the Gross Reservoir Expansion Project, and after more than a decade of negotiations, the project (which was recently endorsed by Gov. John Hickenlooper) is underway.

But will it be enough? The short answer is yes—as long as Denverites work on strengthening their water conservation practices. Lochhead was pleased to note that when a storm comes through the Mile High City, there is a noticeable drop in outdoor water use, because well-informed residents are turning off their sprinkler systems. Denver residents have managed to reduce water consumption by more than 20 percent in the last 15 years, even with a 15 percent increase in population, according to Lochhead.

The decrease is not enough to mitigate the risk of drought, however. As Colorado’s largest water utility, the Denver Water system is made up of two collection systems—the Northern and the South Platte—and they are incredibly imbalanced. About 80 percent of the water comes from the south system, leaving the north very vulnerable to low rainfall or wildfires. During the notable dry years of 2002 and 2013, clients in the north end were lucky their taps continued to flow.

“We were literally only one drought away from a major problem in our system,” Lochhead says, noting that as recently as 2013, the system was virtually out of water in the north-end.

#ColoradoRiver — Tale of Two Basins — Circle of Blue

West portal Moffat Water Tunnel
West portal Moffat Water Tunnel

From Circle of Blue (Brett Walton):

In Colorado, rivers flow not only down mountain slopes but beneath them, across them, and through them.

Nearly four dozen canals, tunnels, and ditches in the state move water out of natural drainages and into neighboring basins. Some snake across high passes. Others pierce bedrock.

All manmade water courses, meant to supply farming, manufacturing, or household use, eventually become so familiar they become part of the landscape. But old infrastructure can come to life in different form. Recently, Gov. John Hickenlooper cast renewed attention on water supply and growth in the West with a decision in a long-running process to expand a Colorado River diversion.

That diversion is the Moffat tunnel which supplies water to Gross reservoir. From its western portal at the base of Winter Park’s ski slopes the 80-year-old conduit, blasted through layers of gneiss, granite, and schist, sends water from west-flowing Colorado River tributaries to Gross reservoir, east of the Continental Divide.

Denver Water, the public utility that owns Gross reservoir, wants to triple its capacity in order to secure water for one of the country’s fastest growing big cities. The $US 380 million project, under state and federal review since 2003, gained Gov. Hickenlooper’s endorsement on the last day of June, a week after it collected a key state water quality permit. The final piece will be a dredging permit from the U.S. Army Corps of Engineers.

The Gross reservoir expansion reflects a fundamental tension for the seven states and two countries that share the Colorado River: how many more diversions can the stressed basin tolerate? The watershed is drying but states in the upper basin still plan to pull more water out of the river. Whether they should — and how much — is a matter of constant debate.

“The challenge becomes reconciling the ability to develop water with the reality that you are assuming a ton of risk,” James Eklund, director of the Colorado Water Conservation Board, told Circle of Blue..

A Game of Risk
Some observers say that the risk threshold has already been crossed. A group of respected academics calling themselves the Colorado River Research Group argued in a 2014 paper that the basin must strive to use less water, not more. “Any conversation about the river that does not explicitly acknowledge this reality is not helpful in shaping sound public policy,” they wrote.

Eklund said he understands the sentiment behind the call for restraint. However, Colorado’s constitution is set up, he said, to protect the right to develop water.

“The state is not going to call balls and strikes and say whether a project is a good investment,” he said. “You take it at your peril. You assume the risk.”

The upper basin is starting to think about those risks. Like the lower basin, it is participating in the pilot conservation program. Most of its projects are located in Colorado and Wyoming. The goal is to prop up Lake Powell with the saved water.

Colorado transmountain diversions via the State Engineer's office
Colorado transmountain diversions via the State Engineer’s office

Denver Water CEO calls for more flexibility in water management — Aspen Journalism

The dam that forms Gross Reservoir, located in the mountains west of Boulder. Photo: Brent Gardner-Smith/Aspen Journalism
The dam that forms Gross Reservoir, located in the mountains west of Boulder. Photo: Brent Gardner-Smith/Aspen Journalism

From Aspen Journalism (Allen Best):

Jim Lochhead, the CEO and manager of Denver Water, said Tuesday that building new dams in the Colorado River basin is not at the top of his to-do list. Nor, for that matter, is drying up farms to provide water for Colorado’s growing cities.

But he says Colorado still needs to have hard conversations about how to flexibly manage its water. In particular, he wants farmers to be able to share water with Denver and other cities without worrying that they may lose their water rights.

Speaking at the annual Western Water Symposium at Colorado State University, Lochhead credited the 2015 Colorado Water Plan as being a useful “compendium of the issues” but said it highlighted relatively easy solutions without fully addressing the harder challenges.

“I don’t think the solution is $20 billion of new water projects for Colorado, but that’s an easy thing to go look for,” said Lochhead, head of the state’s largest water utility that supplies 1.4 million people, and stores nearly 40 percent of its water in Summit County’s Dillon Reservoir.

A coordinated plan is needed, Lochhead said.

“We’re not there yet with the state water plan to develop any kind of coordinated principle vision for the future, much less how to get there,” he said.

Lochhead, who took the helm of Denver Water in 2010, described Colorado’s historical approach to water as a zero-sum game where there had to be a winner and a loser.

That zero-sum game lost its moorings in the second half of 20th century as a result of new federal and state laws, court decisions and political fights, Lochhead said.

He said that two decades have brought more collaboration between diverse interests, including those on both sides of the Continental Divide, and it is reflected in such projects as Wolford Mountain Reservoir near Kremmling.

Both Denver Water and the Colorado River Water Conservation District have an interest in Wolford Reservoir, with Denver Water on track to soon own 40 percent of the water in the reservoir. The water has many benefits, among them providing late-summer water to meet needs of four endangered fish species in the Colorado River near Grand Junction.

Another collaborative effort has been launched in the Winter Park area. There, Denver plans to increase diversions from the Fraser and Williams Fork rivers, but is doing so with the blessing of local authorities, thanks to a collaborative “learning by doing” effort in Grand County that seeks to reduce streamflow impacts from both new and existing diversions.

But Lochhead believes Colorado must still dramatically change its water allocation methods as it faces population growth. Demographers project that Colorado’s 5.4 million population will double within a few decades. If we seek to provide the water for the additional residents the way we provided for the first 5 million, he said, “we won’t like the outcome very well.”

Gore Canyon rafting via Blogspot.com
Gore Canyon rafting via Blogspot.com

The river itself

A second challenge is the Colorado River itself, the fountain that supplies at least part of the water for 40 million people, from corn farms in northeastern Colorado to San Diego. And despite some good snow years, the two big reservoirs on the lower Colorado River, Lake Powell and Lake Mead, are both low enough to keep a ballroom full of water experts up at night.

It could get worse. And, according to projections of climate models, it likely will.

Laurna Kaatz, an in-house climate expert at Denver Water, recently told the Metro basin roundtable it’s still not clear if it will be hotter and drier, or hotter and wetter in Colorado in the future, but there is little doubt it will be hotter.

More major dams on the Colorado River are not the solution, Lochhead said. Evaporative losses would result in more loss than gain, he said, although he did allow for the possibility of relatively small dams.

Denver Water is, however, studying the potential for putting water into aquifers beneath the city, creating underground storage — storage that could, in theory, hold water from the Western Slope.

And Denver Water is looking to store up to an additional 15,000 acre-feet of Western Slope water in an expanded Gross Reservoir, southwest of Boulder. The $360 million project seeks to raise the elevation of the dam by 131 feet, which would increase the capacity of the reservoir by 77,000 acre-feet, bringing it up to 119,000 acre-feet.

Flexibility needed

Lochhead said that Colorado needs more flexible water management options that allow for greater sharing of the resource.

About 85 percent of water in Colorado is used by agriculture and ranchers and farmers tend to have the oldest and most senior water rights.

Water rights are private, said Lochhead, “but you can’t really do anything with that property right except what you are currently doing with it unless you go to water court. And by going to water court you put that entire water right at risk.”

In Colorado’s water courts, objections to changes in uses of water rights are often filed. The process can be lengthy and expensive for those seeking to make changes.

“You need a safe process where you don’t have to put your water right at risk, and you understand that you don’t have to spend years negotiating,” he said.

And Lochhead thinks Colorado also needs another conversation about conservation, where the emphasis is not about sacrifice but about innovation.

Denver Water intends to demonstrate what is possible as it redevelops its 35-acre headquarters campus along Interstate 25 near downtown Denver. There, planners think they can reduce demand for potable water by more than 50 percent.

In water reuse, said Lochhead, Colorado is “way behind the curve” as compared to some world cities, including Amsterdam and Sydney.

Editor’s note: Aspen Journalism and the Aspen Daily News are collaborating on the coverage of water and rivers. The Daily News published this story on Friday, July 29, 2016.

#ColoradoRiver: “..in the Colorado Constitution, the Continental Divide doesn’t exist” — Jim Pokrandt

Denver Water's collection system via the USACE EIS
Denver Water’s collection system via the USACE EIS

From The Grand Junction Daily Sentinel (Dennis Webb):

A proposal to divert Colorado River water to Denver recently has won the endorsement of Gov. John Hickenlooper and the approval of the Colorado Department of Public Health and Environment.

But Denver Water’s Gross Reservoir expansion project may be just as notable for its general lack of opposition west of the Continental Divide. That’s thanks to a wide-ranging agreement, effective in 2013, in which Denver Water obtained concessions including a promise that numerous Western Slope parties to the agreement wouldn’t oppose the expansion project. In return, Denver Water made a number of commitments to the Western Slope.

Now Western Slope interests are working on a similar agreement with Northern Water and others on what’s called the Windy Gap Firming Project, which would store Colorado River water in a proposed Boulder County reservoir.

These approaches represent a far cry from how the Western Slope used to respond to transmountain diversion proposals.

“This is the new paradigm. It’s not the old school. In the old school it was like … we’ll see you in court,” said Jim Pokrandt of the Colorado River District, a party to the 2013 Denver Water deal.

For Denver Water, what’s called the Colorado River Cooperative Agreement provided greater certainty for its customers through means such as resolving longtime disputes regarding West Slope water. For the Western Slope, the deal meant dozens of obligations by Denver Water, such as millions of dollars in monetary payments to various entities, protections of Colorado River flows and water quality, a commitment to further water conservation and reuse efforts by Denver Water customers, and a provision aimed at helping assure maintenance of historic flows in the Colorado River even when the Shoshone Power Plant in Glenwood Canyon is not operating. That hydroelectric plant has a senior right helping control flows in the river.

Another key point in that deal is a promise that Denver Water and its customers won’t try to further develop Colorado River water without agreement from the river district and affected counties.

The cooperative agreement has 18 signatories but more than 40 partners, primarily West Slope governments, water conservation and irrigation districts, and utilities. Among them are the Ute Water Conservancy District and multiple irrigation districts in Mesa County.

Pokrandt said the 2013 deal is a win-win for both sides of the Continental Divide.

“That said, yes, more water would be moving east” if the Gross Reservoir project proceeds, he said.

The project, also sometimes called the Moffat Collection System Project, would nearly triple the capacity of the Boulder County reservoir. Denver Water is targeting water in the Fraser River, a tributary of the Colorado.

“Right now there are some periods of time when Gross Reservoir is full at its current size and their water rights are in priority but they can’t take any more water,” Pokrandt said.

The project has an estimated cost of $380 million, and Denver Water hopes to obtain the remaining major permits by the end of next year. CDPHE in June certified that the project complied with state water quality standards, and Hickenlooper endorsed it last week.

“The state’s responsibility is to ensure we do the right thing for Colorado’s future, and this project is vital infrastructure for our economy and the environment,” Hickenlooper said in a news release. “The partnerships and collaboration between Denver Water, the West Slope and conservation organizations associated with this project are just what the Colorado Water Plan is all about.”

That recently adopted plan in some respects took its lead from the Denver Water/Western Slope deal in seeking to address the state’s future water needs in a cooperative rather than confrontational manner statewide.

Pokrandt conceded that not everyone loves the Gross Reservoir proposal…

Trout Unlimited takes a more positive view of the Gross Reservoir project, pointing to its inclusion of a “Learning by Doing” program requiring monitoring of the health of the Fraser River and adjusting operations as needed. The Gross Reservoir proposal envisions drawing water from the Western Slope in wetter years and seasons, but providing the Colorado River watershed with extra water during low flow periods and investing in restoration projects.

“Moreover, Denver Water has entered into partnerships on the Front Range to ensure that the project alleviates chronic low-flow problems in South Boulder Creek. Both sides of the Divide benefit,” David Nickum, executive director of Colorado Trout Unlimited, said in a news release…

Denver Water Chief Executive Officer Jim Lochhead said in a news release, “The Denver metropolitan area is tied to the economic and environmental health of the rest of the state, and Denver Water is committed to undertake this project in a way that enhances Colorado’s values.”

Pokrandt said Western Slope water interests face the reality that under the state Constitution the right to appropriate water shall not be denied if the water can be put to beneficial use and a party can obtain the necessary financing and permitting.

“There’s not a legal stance to say no, so that’s why the river district was even formed in 1937, was to negotiate these things, because no is not an answer in the legal arena because of the Colorado Constitution,” he said.

When it comes to water rights, Pokrandt said, “in the Colorado Constitution, the Continental Divide doesn’t exist.”