Roaring Fork Conservancy District Independence Pass diversion system tour recap

Independence Pass Diversion
Independence Pass Diversion

From The Aspen Daily News (Collin Szewczyk):

The Independence Pass transmountain diversion system shut down for more than a month this year around the June peak runoff due to ample water supplies in the Arkansas River basin, only the fourth such time this has happened for these reasons since the 1930s.

Seeing rivers in this more-natural state has reinvigorated local interest in the health of the Roaring Fork watershed and how it is managed.

Recently, a group of more than two dozen interested locals and tourists met up at the Lost Man trailhead parking lot near Independence Pass to learn more about how water is diverted east from the watershed. The sold-out event was hosted by the Basalt-based Roaring Fork Conservancy, and was led by both its employees and those of the Twin Lakes Reservoir and Canal Co., which manages water flows through the transmountain diversion system…

Medved noted that there are 24 major diversion tunnels in Colorado, and two of the five largest are in the Roaring Fork watershed.

The fifth largest is the 3.85-mile-long Twin Lakes tunnel, which diverts water from the headwaters of the Roaring Fork River to the Arkansas River basin. It is a bit over nine feet wide and boring began in November of 1933, with the workers “holing out” in February 1935.

The Boustead Tunnel is the third-largest diversion tunnel and is located on the headwaters of the Fryingpan River. It stretches 5.5 miles, and empties into Turquoise Reservoir near Leadville.

Scott Campbell, general manager of the nonprofit Twin Lakes Reservoir and Canal Co., which is privately owned and based out of Ordway, has worked with water for about 40 years and explained that the Twin Lakes diversion was originally a supplemental water right in the 1930s. He added that when water from the Arkansas River was coming up short on the eastern side of the Continental Divide, Twin Lakes Reservoir water would help to fill the gap.

Each year, the transmountain diversion system collects water from the Roaring Fork River, as well as the Lost Man, Lincoln, Brooklyn, Tabor, New York and Grizzly creeks, and moves it through the Twin Lakes Tunnel into the Arkansas basin. From there much of it aids agricultural pursuits near Pueblo and Crowley counties…

The Twin Lakes Reservoir is owned and operated by the U.S. Bureau of Reclamation, but the Twin Lakes Reservoir and Canal Co. retains ownership of 54,452 acre-feet of space within to store water…

More storage on East Slope needed

When asked why Eastern Slope reservoirs aren’t being expanded to store more water, Campbell replied, “That’s a very good question.”

Alan Ward, water resources administrator for the Pueblo Board of Water Works, explained that many of the reservoirs on the Front Range are under federal purview, and changes would require an act of Congress.

“As it turns out, we’ve been trying to do that for almost 15 years,” he said. “It’s not easy to get Congress all together and actually passing legislation that would allow us to study the enlargement of that.”

Ward added that while some potential reservoir sites may be good from an engineering point of view, they don’t always make sense environmentally.

“It’s just a challenge to be able to find a spot that you can get permitted, that you can afford to build on, and that you can get permission to build on, if it requires an act of Congress,” he said. “But something I think is very much in the forefront of the minds of water planners on the East Slope, is where and how can we build more storage to be able to better manage the limited supply [of water] we have.”

Into the Styx

Following a bumpy Jeep ride up Lincoln Creek, care of Blazing Adventures, to see the opposite end of the tunnel through Green Mountain, Campbell concluded the tour by leading people on a subterranean descent into the Twin Lakes Tunnel.

The concrete “road” dropped down quickly into the darkness, and constant seepage water dripped from above, creating the feeling of being caught in an underground monsoon.

Campbell noted that the site’s caretakers, Kim and Glenn Schryver, use the underground route in the winter to reach the outside world while Independence Pass is buried under the snowpack.

He explained that the workers boring the tunnel converged on each other from either side and averaged just under 50 feet in progress a day. When they met up, the holes were six inches apart, Campbell said, adding that the route was determined with a line of mirrors shot over Independence Mountain.

Aspen Times Weekly: Could a mine-waste spill happen here?

Smuggler Mine back in the day via GregRulon.com
Smuggler Mine back in the day via GregRulon.com

From The Aspen Times Weekly (Scott Condon):

Pitkin County has between 600 and 800 mine features, including multiple adits into the same mine, according to an estimate by the Colorado state government. And as Cooper’s experience shows, there are Aspen mines that are filled with water — but just because there’s water, that doesn’t mean it’s contaminated water.

Still, that hefty inventory of adits and shafts makes it reasonable to wonder if something similar to the discharge of 3 million gallons of toxic water from the Gold King Mine near Silverton into the Animas River earlier this month could happen in Aspen (see story, page 33).

State and federal officials as well as miners with street credibility will never say never, but a similar disaster in Pitkin County is unlikely, in large part because of geology, they agreed.

Aspen Mountain’s mines tended to be internally drained to the water table, so “there is generally no significant surface drainage discharges associated with the underground workings,” said Bruce Stover, an official with the Colorado Inactive Mine Reclamation Program. That means there is a “very limited possibility” of underground impoundments of water being formed, he said.

Mines in the San Juan Mountains and other parts of the state have water above the surface. Toxic water was intentionally captured inside the Gold King Mine. It breached when the U.S. Environmental Protection Agency undertook a reclamation effort.

Aspen miners tended to encounter water below the level of the water table and Roaring Fork River, said Jay Parker, a partner in the Compromise Mine on Aspen Mountain and a miner and tour guide at the Smuggler Mine.

The water emerging from Aspen’s mines hasn’t been found to be acidic or laced with heavy metals in any testing to date. In one of Aspen’s few hard-rock mine reclamation projects, water in Castle Creek tested similarly above and below where the Hope Mine discharged, according to Forest Service records.

Parker said water draining from the Compromise Mine on Smuggler Mountain feeds ponds where fish thrive and ducks gather.

Local Mine reclamation aimed at safety

Many of Pitkin County’s mines have collapsed, either naturally or by public agencies for safety reasons.

“Our records show we have safeguarded approximately 90 hazardous, non-coal openings in Pitkin County, many of them on Aspen Mountain,” said Stover. Numerous closures have also been completed on coalmines in the Coal Basin and Thompson Creek areas.

The Forest Service typically performs safety closures on three or four mines per year, according to Greg Rosenmerkel, engineering, minerals and fleet staff officer on the White River National Forest. “There are hundreds of mines across the forest.”

The focus of both the Forest Service and the Inactive Mine Reclamation Program is to prevent people from entering an unsafe situation. Old mining timbers have often rotted, making interior travel perilous. Air deep underground can be toxic without proper ventilation.

“It’s almost an attractive nuisance,” Rosenmerkel said of the old mines.

A recent closure was completed earlier this summer at three mines in the high ground beyond Crystal. The typical closure costs $200,000, though no two projects are the same, he said.

Both the Forest Service and Inactive Mine Reclamation Program are focused on finding mines that pose a physical hazard, such as ones located in a ski area or adjacent to a popular hiking trail, and safe-guarding them.

No toxic water impounded

If Forest Service or Bureau of Land Management officials suspect environmental issues, the state Water Quality Control Division is mobilized to test for acidity or metals. If a problem is found, the Inactive Mine Reclamation Program figures out how to solve the problem. If an environmental problem is suspected with a mine on private lands, the Forest Service might be involved if it affects public lands, Rosenmerkel said.

The Hope Mine in Castle Creek Valley warranted remediation while the Ruby Mine in Lincoln Creek Valley has raised concerns but hasn’t been found in need of monitoring (see related stories), according to officials.

Rosenmerkel said there is no situation in the Aspen-Ranger District where water as toxic as that in the Gold King Mine is being impounded.

The Roaring Fork Conservancy, a Basalt-based nonprofit focused on water quality and quantity issues in the valley, doesn’t specifically test to see how water coming from mines affects rivers and streams in the basin.

“Outside of Ruby, I don’t know if we have a big enough problem or big enough source,” said Rick Lofaro, the conservancy’s executive director.

Fountain Creek: “The annual maintenance of the levee [in Pueblo] has been neglected” — Ken Wright

Fountain Creek
Fountain Creek

From The Pueblo Chieftain (Chris Woodka):

It’s like adding insult to injury.

As if flooding on Fountain Creek weren’t bad enough, mountains of sand are stacking up north of Pueblo waiting to descend on the channel through the city.

Dealing with it will take cooperation from the north and decades to correct.

“It’s like a big anaconda eating an animal and moving it down,” said Ian Paton, part of the Wright Engineering team hired by Pueblo County commissioners to analyze the problem. Commissioners heard a status report on what will be an ongoing study on Friday.

The problem may be bigger than previously thought, Paton explained.

The net gain of sediment in Fountain Creek works out to about 370,000 tons a year between Fountain and Pueblo, causing the river to shift its flow in the channel as the increasing amount of material obstructs its path. It keeps piling up year after year as it eats away 20-foot cliffs.

And, it has become worse since 1980, when Colorado Springs started booming in population and major infusions of water from outside sources — Homestake, Blue River and the Fountain Valley Conduit — began putting more water into Fountain Creek.

Southern Delivery System, a 66-inch diameter pipeline from Pueblo Dam to Colorado Springs, could increase Fountain Creek flows 60-100 percent, while depleting the Arkansas River through Pueblo. Water quality will become an increasing concern as more sediment is churned up.

“Population is the driving factor,” said Andrew Earles, Wright’s top water resources engineer. “To have growth, you need water, and since the 1970s, you’ve been putting more and more water into Fountain Creek.”

Additional water has allowed more growth, and increased base flow threefold.

But the growth also has increased impervious surfaces — roofs, parking lots and streets — by 10 percent of the total watershed area upstream of Security, and caused base flows, high flows (the kind seen this spring) and big floods to become more intense at all times.

The Waldo Canyon and Black Forest fires of 2012 and 2013 have caused storms to generate up to 100 times the damage that would have occurred prior to Colorado Springs’ growth surge, Earles explained.

“We can’t turn back the clock. We can’t put it back to the way it was in the 1950s and ’60s,” Earles said. “We can put it in better shape for the future.”

A big part of that will be developing ways to deal with increased flows into Fountain Creek at the source.

That would include detention of floods, bank stabilization and control of tributaries in ways that reduce damage on the main stream.

Wright Engineers evaluated Colorado Springs and El Paso County estimates of 454 flood control projects that could cost $723 million to complete for their benefit to Pueblo County. About two-fifths of the projects totaling $537 million would reduce destruction to Pueblo.

Colorado Springs officials are proposing $19 million annually to bring stormwater control back to the level it was before its City Council abolished the stormwater enterprise in 2009.

“So far we agree with their list,” said engineer Wayne Lorenz.

Lorenz said a dam between Fountain and Pueblo is “worthy of consideration,” but cautioned that such a oneshot solution could fail.

“A dam is more of a treatment for a symptom rather than a cause,” Lorenz said. “We can’t put all our eggs in one basket with a dam because it might not happen.”

Commissioners are also concerned that projects be maintained.

In Pueblo, the Fountain Creek levees are in need of repair in order to provide the same protection they were designed to give 25 years ago.

“The levee is badly silted and vegetated, and it would take $2 (million)-$ 5 million to bring it back to standards,” said Ken Wright, head of the engineering firm.

“The annual maintenance of the levee has been neglected.”

The fear is new projects on Fountain Creek could sink in the same boat.

“We need to make sure we’re not just building projects, but have the money to maintain them,” said Pueblo County Commissioner Terry Hart.

Reclamation to Host Public Meeting for Ruedi Operations #ColoradoRiver #COriver

Ruedi Dam and Reservoir
Ruedi Dam and Reservoir

Here’s the release from the US Bureau of Reclamation (Patience Hurley):

The Bureau of Reclamation has scheduled the annual public meeting for Ruedi Reservoir Water Operations.

August 12: Basalt Town Hall, 101 Midland Avenue, Basalt, Colo., 7 to 8:30 p.m.

The meeting will provide an overview of Ruedi Reservoir’s 2015 spring run-off and deliver projected operations for late summer and early fall, which are key tourist seasons in Basalt. The meeting will include a public question and answer session.

For more information, please contact Tim Miller, Hydrologist, Eastern Colorado Area Office, by phone or e-mail: (970) 962-4394, or tmiller@usbr.gov.

Aurora: “We have more water in our system than we’ve ever had since we’ve been recording” — Joe Stibrich


From The Aurora Sentinel (Rachel Sapin):

“We have more water in our system than we’ve ever had since we’ve been recording,” Aurora Water Resources Management Advisor Joe Stibrich told congressional aides, city council members, city staff and Aurora residents on a tour of the city’s vast water distribution system last week. “We hit 99 percent of our storage capacity about a week ago.”

In total, Aurora Water has more than 156,000 acre-feet of water storage, which could supply the city with years of emergency supply in case of a drought.

The city gets water from three river basins. Half of the city’s water comes from the South Platte River Basin, a quarter comes from the snow melt flows from Colorado River Basin, and a quarter from the Arkansas River Basin.

But Aurora was not always a municipal water powerhouse.

In 2003, Aurora’s water supply level was at 26 percent capacity, the lowest in the city’s history. The idea for the at-the-time innovative Prairie Waters Project came about in the wake of that severe drought.

The $653-million Prairie Waters Project increased Aurora’s water supply by 20 percent when it was completed, and today provides the city with an additional 3.3 billion gallons of water per year.

The entire system pumps water from wells near Brighton, where it’s then piped into a man-made basin and filtered through sand and gravel. From there, the water is then piped 34 miles through three pumping stations to the Binney Water Purification Facility near Aurora Reservoir, where it’s softened and exposed to high-intensity ultraviolet light. The water is then filtered through coal to remove remaining impurities.

“It’s the crown jewel of our system,” said Stibrich during the tour. “Prairie Waters almost creates a fourth basin for us.”

But even before Prairie Waters, the first “crown jewel” project that allowed Aurora to grow and become the state’s third-largest city, was the one that allowed Aurora to cut most of its water ties with Denver.

Throughout the 1900s and into the 1960s, Aurora relied on the Denver Water Board for its supply. But the partnership between the neighboring cities grew contentious when, in the 1950s, Denver Water imposed lawn watering restrictions on a booming metropolitan area. Part of those restrictions included a “blue line” that prevented some Aurora suburbs from getting permits for new tap water fees.

In 1958, Aurora partnered with Colorado Springs to construct the Homestake Project, located in southern Eagle County in the Colorado River basin. The project was designed to use water rights purchased on the Western Slope that could supply the two cities.

For nearly a decade after the project was conceived, it was mired in legal battles with Denver and Western Slope entities. The first phase of the dam wasn’t even completed until 1967. In the 1980s, Aurora and Colorado Springs unsuccessfully attempted to expand the water collection system within the Holy Cross Wilderness area as part of a phase two plan.

The issue to this day is divisive, said Diane Johnson, a spokeswoman with the Eagle River Water and Sanitation District during the city’s tour of the reservoir.

“For people to think we might be having some other dam up here and impacting their access to wilderness is an emotional issue,” she said.

It was a memorandum of understanding created in 1998 between Eagle County and the two Front Range cities that identifies 30,000 acre-feet of water in the Eagle River basin to be divided into thirds between the three entities that helped alleviate tensions and put the project back on track.

Today Homestake Reservoir provides Aurora with 25 percent of its water, and Aurora Water officials are looking at various ways to expand their storage to satisfy the Eagle River MOU.

One idea is a small reservoir in the Homestake Valley near the Blodgett Campground. Aurora Water officials said the issue with that plan is having to relocate the winding Homestake Road to a portion of the Holy Cross wilderness to accommodate it. Another alternative, which Aurora Water officials said they prefer, is to create a holding facility called a forebay, in the same valley, along Whitney Creek, that would hold water pumped back from a former World War II military site known as Camp Hale. From the holding facility, water could be further pumped up the valley to Homestake Reservoir.

Aurora Water officials are still working through the various politics of the alternatives, and repeatedly emphasized during the tour that there is no “silver bullet’ when it comes to water storage.

From Homestake, water travels east through the Continental Divide and tunnel where it’s sent to Turquoise Lake, then to Twin Lakes Reservoir near Leadville.

Aurora only owns the rights to a limited amount of storage in Twin Lakes, and that water has to be continuously lifted 750 feet via the Otero Pump Station to enter a 66-inch pipeline that leads to the Front Range.

The Otero Pump station — located on the Arkansas River about eight miles northwest of Buena Vista — is another impressive facet of Aurora’s vast water system, and the last stop on Aurora’s water journey before it is delivered to the Spinney Mountain Reservoir in South Park. With the ability to pump 118 million gallons per day, Otero provides half of Aurora’s and 70 percent of Colorado Springs’ drinking water, delivered from both the Colorado and Arkansas basins to the South Platte River Basin.

Tom Vidmar, who has served as the caretaker at Homestake for nearly 30 years and lives right next to the pump station, said the biggest issue facing Aurora’s water system is storage.

“We actually spilled water out of Homestake this year and didn’t collect (the) full amount we were eligible to take, simply because the reservoirs are at capacity,” Vidmar said during a tour of the massive pump facility. He said the electricity costs alone for Aurora to pump the water add up to around $450,000 a month.

A project Aurora Water officials hope to see come to fruition in 15 years is turning land the city purchased at Box Creek north of Twin Lakes in Lake County into additional storage space so water can be pumped more efficiently through Otero.

“Box Creek is an important project. It gives us more breathing room,” said Rich Vidmar, who is Tom Vidmar’s son and an engineer with Aurora Water, during the tour. “As we look at storage and where to develop storage, right now we’re looking at spots where we have chokepoints in our system where we’re not able to operate perfectly to get as much water as possible.”

Just as the state anticipates that its population of 5 million will double by 2050, so does Aurora — and storage will be key to providing water for a city that could potentially grow to more than 600,000 residents in the coming decades.

But the mountains aren’t the only place where Aurora hopes to expand its reservoirs. The city also is looking to expand Aurora Reservoir even further east.

At a July study session, Aurora Water Officials described a feasibility study being conducted to determine just how much water Aurora could store at a future reservoir, which would sit on the former Lowry Bombing and Gunnery Range.

More Aurora coverage here.

“The Western Slope in Colorado has no more water to give” –WestSlopeWater.com #COWaterPlan #ColoradoRiver #COriver

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

From The Aspen Daily News (Collin Szewczyk):

That theme of cooperation, including striking a balance between consumption and conservation, quickly rose to the surface Friday, as members of the whitewater, conservation and political communities met at Colorado Mountain College in Glenwood Springs to discuss the future of state water policy.

“To the best of our ability, we don’t want it to be West Slope against East Slope, “ said Heather Lewin, watershed action director for the Roaring Fork Conservancy. “We want to be working together to understand where water comes from, and how to use it most efficiently … so that we can do the best we can for the people who live here and for the environment.”

Members of the environmental group Conservation Colorado hosted the confab, which was set to coincide with Colorado River Day. The discussion largely revolved around local water issues and the recent release of the draft Colorado Water Plan. As water levels dwindle throughout the West, Colorado is formulating its first state water plan…

A benefit of the state effort is that many interest groups have gotten together to discuss the issue, creating new partnerships that before may never have been possible, said Kristin Green, Front Range field manager for Conservation Colorado.

“I think it’s important to recognize the diversity of holders we do have in this state, particularly in this area, that feel very direct effects from how we are managing our rivers,” she said. “Now more than ever we need to make sure all those different voices are being heard.”

More than 24,000 comments have been made concerning the draft water plan, and the public comment period doesn’t end until Sept. 17, Green said.

She noted that the second draft of the water plan begins to delve into potential solutions, and suggests a conservation goal of saving 400,000 acre feet by 2050. It’s the start of establishing the criteria officials may want to discuss, she said.

“There definitely was more meat on the bones,” Green said of the second draft…

Roaring Fork watershed increases 
quality of the Colorado

Lewin said that while the Roaring Fork River may be a small component of the overall Colorado River Basin, it still contributes around 1 million acre feet of water to the larger river each year.

She said the quality and quantity of that water can be very significant farther downstream in both an ecological sense and for its value to industries, municipalities and agriculture. But diversions strain that resource.

“Having high-quality water in the Roaring Fork makes a big difference of the water quality overall in the Colorado,” Lewin said.

She added that the river’s gold medal fishing designation is a huge economic boost to the valley. That lofty standard is met when there are at least 60 pounds of trout per acre of water, including at least 12 fish that are 14 inches or longer.

“That’s a lot of fat fish,” Lewin said. “But [keeping] those fish growing fat, healthy and swimming doesn’t happen in a vacuum.”

These conditions occur when a river or stream consists of clean water, and is home to an abundant insect population and a healthy riparian area. Lewin said surrounding riparian areas provide shade to cool river temperatures; food for aquatic creatures; erosion control; and help to filter pollutants.

“As you increase development, and as we diminish stream flows, riparian vegetation becomes one of the first things to really suffer,” she said. “So it’s hard to regenerate cottonwoods without overbanking flows. Cottonwoods are a key part to that riparian vegetation piece.”

Lewin said the recent wet spring led to the term “miracle May,” a month with a huge amount of precipitation that helped make up for a dry and warm winter. The heavy flows also helped to clear out sediment that built up in areas of the Roaring Fork.

“One of the biggest transmountain diversions out of the basin, the Independence Pass Tunnel, was shut down for nearly two months,” she said (that was because the East Slope had ample water supplies). “It just started operations about a week ago or so. By closing down that tunnel we were able to really see the full effects of the spring flushing flow and the benefits to the river.”

Lewin added that old oxbows in the North Star Nature Preserve east of Aspen were again filled with water this spring, putting the wetland area in a more natural state.

The Roaring Fork Conservancy has also engaged residents in the Crystal River Valley to work on addressing low stream flows. That effort has focused on looking at best practices to manage diversions and return flows, and studying the area’s physical features.

“We’re trying to see if we can use all of those pieces together in cooperation with the people who live on and around the river, and use that water to do the best we can for the Crystal,” Lewin said.

Dean Moffatt, a local architect, inquired about efforts to bestow the federal “Wild and Scenic” designation and its protections on the Crystal River.

“As an organization, we’re certainly supportive of the process,” Lewin replied. “We think that it’s really important and has the potential to be really beneficial.”[…]

‘No more water to give’

Aron Diaz, a Silt town trustee, said there’s a lot of interest among local leaders in the Colorado Water Plan.

“We’re really in a unique position and have the opportunity to craft Colorado’s water policy at the larger state level,” he said. “But we need to keep in mind how that affects the Western Slope.”

Diaz said the biggest point of concern is that Front Range basins are still adding placeholders, indicating that they may need more West Slope water to meet demands.

“We’re pretty tapped out for the amount of water that we have available to us,” he said. “Both with our obligations to stakeholders along the Colorado and those environmental, recreational, agricultural, industrial, municipal needs … as well as our downstream obligations with the compact, we’re really at the limit.”

There’s a need to set “achievable, but very aggressive conservation goals” to assure every avenue is studied before looking at new diversions, Diaz said. He urged the public to visit westslopewater.com to sign a petition that will be delivered to Gov. Hickenlooper and Colorado Water Conservation Board director James Eklund. It requests that no new diversions of water be made to the Front Range…

“The Western Slope in Colorado has no more water to give. We, the undersigned western Colorado residents, strongly urge you to oppose any new trans-mountain diversion that will take more water from the Western Slope of Colorado, as you develop Colorado’s Water Plan,” the petition states. “We cannot solve our state’s future water needs by simply sending more water east.”

No flouride dosing for Snowmass

Calcium fluoride
Calcium fluoride

From The Aspen Times (Jill Beathard):

With no members of the public present other than two dental professionals and a journalist, the Snowmass Water and Sanitation District board of directors voted Friday to stop fluoridating its drinking water.

The board began reconsidering its practice in May after the federal government revised its recommendations regarding public-water fluoridation. Snowmass already followed the new standards, but the announcement sparked a debate that continued for three board meetings.

Friday’s meeting began with public comment from Ward Johnson, a Snowmass Village resident who practices dentistry in Aspen.

“Being a dentist in Aspen since 1992, of course I am in favor of continuing the fluoridation in the water,” Johnson said, citing a reduction in the rate of cavities in areas of the valley that have fluoridated drinking water. “In my opinion, the only thing that has changed is we have toothpaste with fluoride now. Without systemically ingesting that fluoride, … you do not get the lifetime of benefit that you get when fluoride is in your enamel.”

A report prepared by Glenwood Springs-based engineering company SGM agreed with Johnson’s statement on the dental-health benefits of fluoridation but noted that ingesting too much has proven to have negative health consequences and that research is limited on other potential impacts.

“Only recently have the studies been done on the effects of fluoride beyond your teeth,” board member Dave Dawson said Friday. “People can fluoridate if they wish. I don’t see it as our business to medicate the public.”

Board members Michael Shore and Willard Humphrey said they agreed with Dawson’s position, but board President Joe Farrell, who said he has many dentists in his family, did not.

More water treatment coverage here.