[env-trinity] Two Rivers Tribune article -- PCFFA response to Tom Schlosser

[FISH1IFR at aol.com]

Dear Colleagues.....
 
My good friend and colleague Tom Schlosser, naturally enough as an Attorney 
 for the Hoopa Valley Tribe which opposes the Settlement, has a different 
-- and  far more optimistic -- view of the potential success of an all-FERC 
and State  401 Certification fight than I do.  On these issues, reasonable 
people do  disagree, mostly because we are trying to predict future outcomes 
of uncertain  agency administrative Commissions, Boards and court cases.  
 
But as the great Yogi Berra once said, "It is dangerous to make  
predictions, especially about the future."  It is also unwise for any  Attorney to 
have total faith in their theory of a case succeeding in  litigation.... 
sometimes it fails, and it is wise to have a backup  plan.
 
Tom Schlosser simply has far more confidence in those Commissions/Boards  
and Courts all making the decisions we want than I do.  I and the  other 
Parties to the Klamath Hydropower Settlement Agreement (KHSA), many of  whom are 
also experienced litigation and administrative agency Attorney's  
themselves (as am I), simply have far less confidence in the backbone of the  
California Water Resources Control Board, and even less confidence in the  Oregon 
Environmental Quality Commission (EQC), to "just say no" and to then  fight 
through years of litigation to make it stick in courts through all the  
state, and then federal, rounds of appeals, than do advocates of scrapping the  
KHSA and going it alone through the FERC process.   
 
Each factual determination and each condition imposed by  either of these 
two state Commissions/Boards in any 401 Certification (or  denied as 
PacifiCorp proposed alternatives in decertification) will be  subject to litigation. 
 
 
No state agency has ever yet succeeded in making a complete 401  
Certification denial stick.  And FERC has never yet, in its entire history,  ordered a 
dam down against the wishes of a license Applicant -- EXCEPT pursuant  to a 
Settlement Agreement such as the KHSA.  And to win in litigation one  would 
have to ultimately prevail on all key issues, every time.  One major  loss 
on any key issue could be fatal.  
 
Since we simply do not know what preconditions might be imposed on a 401  
Certification, or what the result of litigation over those preconditions 
might  be, it is quite premature to say that PacifiCorp simply cannot meet 
them.... and  they have multiple backup plans to face those contingencies if they 
have  to.  What if they can meet them?  What then?  Then they  get a 
50-year FERC licensing and the next time this opportunity comes up will be  at 
least 2062.  This is a risk of that FERC-only route Tom completely  ignores.  
 
And my point about PacifiCorp likely walking away with J.C. Boyle dam in  
any nes FERC license, which produces 55% of the power of the entire system, 
but  has the least water quality impact and sits in the state with the 
weakest water  quality laws, is unfortunately a realistic potential outcome of 
such a  FERC-only route in Oregon.  
 
The PUC approvals for collection of the Klamath Surcharge, was not -- as  
mistakenly portrayed by Tom -- a decision comparing dam removal under  FERC 
to relicensing also under FERC.  It was a decision based on the  KHSA, i.e., 
approving the KHSA (with its $200 million "customer cap" on  ratepayer costs 
of dam removal), to full FERC relicensing.  
 
There is no question that PacifiCorp's ratepayers' responsibilities under  
the KHSA are less than under full FERC relicensing.  However, if one  
compares the full costs of dam removal under FERC alone (i.e. without the  KHSA) 
with dam relicensing under FERC alone, they come much closer to a  wash -- 
and therefore much closer, absent the KHSA and its liability  protections for 
PacifiCorp's customers, to something that PacifiCorp could  realistically 
choose as the best financial option of those two.  Don't  be too certain which 
way this would go.  
 
And two final rebuttal points:
 
(1) Yes, the companion Klamath Basin Restoration Agreement (KBRA) will  
require long-term management and funding, which means an annual Congressional  
funding fight.  But so what?  This is always the case with any  federally 
funded restoration project.  Much of the KBRA, however, does  not need special 
federal legislation to proceed, and is written into the  President's Budget 
already, some of it being funded already.  But of  course, it will always 
be a struggle to get any particular sums of  appropriations through Congress. 
 Is this an excuse for not  trying?  I would say not.
 
Dam removal itself, however, does NOT require any federal funding and,  
after passage of implementing legislation, will occur under the KHSA without 
any  other approvals by Congress. Many people are working to smooth that  
Congressional passage route in many ways.  
 
There is also already more than $20 million in the Klamath Surcharge fund  
now, and this is increasing monthly, on target toward the $200 million in  
funding due by 2020.  But in our view -- and the view of most Klamath  salmon 
biologists -- there is no way to achieve substantial recovery of  salmon in 
the Klamath through dam removal alone.   This is why the  KBRA provides for 
more water -- up to 230,000 acre-feet more water each  year -- to be 
returned back to the river for fish as part of the  deal.
 
(2) Of course there will be litigation over any dam removal decisions.  
There already has been, though none of it has succeeded to date.   This type of 
litigation delay is already built into the KHSA dam  removal schedule and 
why it will likely take nine more years to get these dams  down.  
PacifiCorp's Condit Dam, which comes down this fall, took about 11  years I believe, so 
this timeline is realistic.  
 
(3) Tom is correct that the NMFS Biological Opinion, and the Interim  
Conservation Plan that came out of PacifiCorp's response to that BiOp, provide  
some minimal stand-alone "interim measures," but those are already  
incorporated into the KHSA, at Appendix C.  They are not all that  impressive, 
frankly, and only sufficient to prevent ESA "jeopardy," nothing  more, but his is 
correct that they might survive a KHSA failure.  In  addition, however, as 
part of the negotiations the KHSA at Appendix D  contains many more "interim 
measures" than required under the NMFS  BiOp.  Lose the KHSA and all those 
additional protective measures will  indeed be lost, so my point remains much 
the same.
 
Looking to the NMFS BiOp or Interim Conservation Plan to provide additional 
 protections is redundant.  Those "imterim measures" are already being  
implemented -- as an integral part of the KHSA.
 
SUMMARY:  On the basis of our analysis of all the  above issues, and the 
difficulties inherent in a FERC-only/401 non-Certification  litigation route 
to achieve four-dam removal unilaterally and against  PacifiCorp's wishes, 
the "bird in the hand" of the already signed Klamath  Hydropower Settlement 
Agreement (KHSA) -- with all its  interim protective measures in full play in 
the interim  -- appears far superior, far faster, far less risky, far more  
protective of the river, and far more certain to result in four-dam removal 
by  2020 than the "two birds in the bush" strategy of seeking, hopefully 
getting,  and then valiantly and successfully defending through years of 
litigation  a still hypothetical denial of 401 Certification by both the two  
states, during which PacifiCorp only has to continue business as usual under the 
 current FERC license.
 
Hence those supporting the KHSA see the KHSA as our  first and best option 
to achieve full four-dam removal as soon as feasible with  as much certainty 
as possible, with at least some river protections in place in  the mean 
time.  This is why we are diligently pursuing it now.  
 
Unfortunately, it is the "FERC-only route" which Tom presents, with all its 
 inherent risks and increased uncertainties, no "interim measures" to speak 
of  (except perhaps the barest minimums required by a NMFS BiOp), and the 
real  possibility that it will not actually achieve four-dam removal, or that 
 litigation delays will push that removal well past 2020 anyway, that is  
the "back up plan," if the KHSA should fail -- not our first  option.
 
I respect Tom Schlosser as a friend and colleague.  But those groups  that 
support the KHSA simply come to a different conclusion than he does, given  
the facts, risks and uncertainties above.  
    
 
======================================
Glen H. Spain, Northwest  Regional Director
Pacific Coast Federation of Fishermen's Associations  (PCFFA)
PO Box 11170, Eugene, OR 97440-3370
Office: (541)689-2000 Fax:  (541)689-2500
Web Home Page: _www.pcffa.org_ (http://www.pcffa.org/) 
Email:  fish1ifr at aol.com

 
 
 
 
In a message dated 8/25/2011 9:09:57 A.M. Pacific Daylight Time,  
t.schlosser at msaj.com writes:

It is depressing enough to have a Director of PCFFA defending PacifiCorp’s  
terrible water quality management on the Klamath, but the errors in Mr.  
Spain’s apology below are glaring.  (1) Spain confuses the Section 401  water 
quality certification with PacifiCorp’s application for a  certification.  
It is true that PacifiCorp seeks certification for a new  license like the 
1956 license, which they dream should be without fish  passage.  The State 
Water Resources Control Board CEQA EIR, however, will  consider several 
alternatives, including dam removals, in developing  conditions for a 
certification.  The SWRCB is not limited to granting or  denying exactly what PacifiCorp 
hopes for; instead, the Board can impose  conditions. 

Spain’s purported fear that PacifiCorp could comply with  all the 
conditions without removing the dams is unjustified, in part for the  reasons 
described in the Op-Ed published by PacifiCorp’s Dean Brockbank, which  Spain 
attached.  As Brockbank notes “PacifiCorp has received approval in  both 
California and Oregon to begin collecting surcharges to cover the  company’s share 
of dam removal costs in 2020.”  PacifiCorp achieved that  approval by proving 
to the utility commissions that dam removal is cheaper  than retrofitting 
the dams to provide the full volitional upstream and  downstream fish passage 
which is already mandated by federal licensing  conditions.  Conditions 
that may be imposed by the State Water Resources  Control Board will only 
further tilt the cost savings in favor of dam  removal.  These dams are history.

Spain projects that litigation  will delay dam removal when FERC issues a 
license that will make it cheaper  for PacifiCorp to remove the dams than to 
comply with conditions.  But  there is no guarantee that there will be no 
litigation concerning the KHSA and  KBRA and the flawed NEPA process currently 
under way.  Anyone can  sue.  Plus, Spain neglects to mention the $1 
billion albatross hanging  around the neck of the KHSA--the need for federal 
legislation and  appropriations. We don't think Congress will jump to pass the 
legislation  required by the KHSA, and this could delay that process 
indefinitely.. By  contrast, no new legislation is needed for a FERC license that 
leads to dam  removal.

Finally, Spain claims there is no legal way to gain the  additional 
protections of the interim measures except through the KHSA.   Again, he overlooks 
the Biological Opinion issued by National Marine Fisheries  Service for the 
protection of Coho salmon, and the Interim Conservation Plan  that NMFS 
negotiated with PacifiCorp to avoid liability under the Endangered  Species Act. 
 It is, in fact, those documents not the KHSA that have  produced most of 
the operational changes seen thus far. 

Tom


On 8/23/2011 4:51  PM, _FISH1IFR at aol.com_ (mailto:FISH1IFR at aol.com)  wrote: 
 
Colleagues....
 
The Klamath mainstem water quality issues raised by this  attached Two 
Rivers Tribune article has already been  thoroughly answered by PacifiCorp's 
Dean Brockbank, in an OpEd published  earlier in the Reddling Record 
Searchlight on June 27th.  That  OpEd is attached below for your information.
 
Two observations of my own in addition, however, to bring some much  needed 
perspective to the mis-statements and half truths in the  original Two 
Rivers Tribune article:
 
(1) The 401 Water Quality Certification now pending before the  California 
State Water Resources Control Board is not for dam  removal, it is only for 
a full FERC relicensing of up to 50  years.  So why would anyone want to 
push forward to help  PacifiCorp secure one of the last requirements for a full 
FERC  relicensing?
 
Some opponents of the Klamath Hydropower Settlement Agreement (KHSA)  
(including the Hoopa Valley Tribe, a representative of which is quoted in  the 
article) still strongly believe that if only they can just get the  Water 
Board to flatly deny that 401 Water Quality Certification  permit for the full 
FERC relicensing Application, that this alone will  automatically lead to dam 
removal perhaps faster and easier than under the  already agreed to KHSA.  
Some opposing groups also believe this is  the only way to jettison the 
other half of the Klamath Basin Settlement,  which is the 50-year Klamath Basin 
Restoration Agreement (KBRA) [I will  leave aside why this would be itself a 
bad idea to focus on just dam  removal].  
 
This strategy, unfortunately, is a high risk gamble with the  fate of the 
Klamath that might well not pay off.  
 
Since no state water agency has EVER just flatly said no to a FERC  
relicensing application, in the view of those of us who are KHSA proponents,  it is 
far more likely that what would come out of this FERC-required process  is 
a qualified "yes" but with additional mitigation measures that,  
unfortunately, PacifiCorp just might be able to meet without  removing the dams.  In 
other words, as compared to the already  signed KHSA, which is moving toward a 
final decision in March 2012 on  four-dam removal targeting 2020,  there is 
-- in KHSA proponents' views  -- a much higher risk that moving forward 
with that 401  Certification would simply open up the way for PacifiCorp to 
relicense the  dams instead of taking them down.  
 
And since no dam relicensing 401 Certification has ever been just  flatly 
denied by a state before, proponents of the KHSA dam removal route  
(including PCFFA) estimate that at best such a denial would just open the  process up 
to delays from many more years of litigation, during which  time PacifiCorp 
would be able to simply continue to run the dams as  usual -- without any 
water quality mitigation measures of any sort  -- on routine annual 
extensions while multiple and serial levels of  litigation and all its many appeals 
is all still  pending.  Advising Attorneys with considerable experience in  
such FERC litigation estimate that reliance on this 401  Certification denial 
route could well delay dam removal -- if it happens  at all -- until well 
after the 2020 removal target date under the  already existing KHSA.  
 
And even if California flatly denies the 401 Certification for  its three 
dams, and this ruling survives years of litigation, this  might well not be 
the case in Oregon, which has much weaker water quality  laws, has only the 
one dam (J.C. Boyles) with the smallest negative impact  on water quality, 
but that dam is by far the most valuable to  PacifiCorp of the four in terms 
of total power produced.  
 
In other words, even forcing the FERC issue might still not result in  all 
the dams coming down, even after many years of litigation, but Oregon's  
J.C. Boyle could well remain.  With a new 50-year licensing, this would  mean 
the next opportunity to obtain the equivalent river restoration as  under 
today's KHSA would not occur until after 2062.  To many of  us involved in this 
process, this risky "alternative" FERC route is  simply not an acceptable 
gamble.  
 
In short, those groups who signed on to the KHSA (including  PCFFA) and are 
thus diligently pursuing dam removal through the more  direct KHSA route 
believe the risk of the alternative FERC/401 Certification  route is far 
greater than the risk of the KHSA by comparison.  This is  why we have supported 
the KHSA and why we oppose the Water Board moving the  FERC relicensing 
Application forward through the 401 Certification process  while the KHSA is 
still being implemented and still has a chance of  success.
 
(2) As noted by PacifiCorp's Dean Brockbank in his OpEd below, by  trying 
to sabotage the KHSA and potentially forcing the company back to the  regular 
FERC relicensing route, in addition to reintroducing much  more uncertainty 
about whether four-dam removal will ever finally be  achieved, one also 
loses all the benefits of the KHSA in terms of various  "Interim Protective 
Measures" to help protect water quality  and fish in the lower river that the 
KHSA requires, and which  PacifiCorp is now paying several million dollars 
per year to  fund.   
 
There is no other legal way to gain the additional protections of such  
"Interim Measures" except through the KHSA.  Aggressive efforts by the  Hoopa 
Valley Tribe to impose such "interim measures" via the FERC process  alone 
have already failed before FERC and lost in the US Court of  Appeals for the 
DC Circuit.  Efforts by PCFFA to impose similar water  quality improvement 
conditions on PacifiCorp through state court litigation  under California's 
Porter-Cologne Water Quality Act also failed. 
 
Detailed descriptions of those Interim Measures can be found in  Appendices 
C & D of the KHSA (available at _www.klamathrestoration.gov_ 
(http://www.klamathrestoration.gov/) ).  A copy of  PacifiCorp's June 2011 first Annual 
Report on the KHSA's Implementation is  also attached, and will bring you up 
to date on what the Company has in  fact been doing under these KHSA-required 
measures to improve water  quality in the river and to mitigate the impacts 
of its dams during the  "interim period" until the four dams can be removed 
under the KHSA --  which is still projected for 2020.
 
Reasonable people often disagree, particularly when they try to  estimate 
likely future outcomes of highly uncertain and complex decisional  processes. 
 But those who support the KHSA and its companion KBRA have  very good 
reasons -- only some of them outlined above -- for pushing both  parts of the 
Klamath Settlement Agreement forward instead of relying on a  flawed FERC 
process conducted by an agency (FERC) which has never ordered a  dam removed 
against the wishes of its owner in its entire history.   

A very detailed Draft Environmental Impact Statement (DEIS) on four-dam  
removal in the upper Klamath, with estimates of its total costs  including 
mitigation measures, is all due out in late September, 2011  for public review 
and comments.  To get more information on the DEIS  preparation process, and 
to get on the notice list for this and other  KHSA-related information, 
sign up on the notice list available at: _www.klamathrestoration.gov_ 
(http://www.klamathrestoration.gov/)  .
 
 
======================================
Glen H. Spain,  Northwest Regional Director
Pacific Coast Federation of Fishermen's  Associations (PCFFA)
PO Box 11170, Eugene, OR 97440-3370
Office:  (541)689-2000 Fax: (541)689-2500
Web Home Page: _www.pcffa.org_ (http://www.pcffa.org/) 
Email: _fish1ifr at aol.com_ (mailto:fish1ifr at aol.com) 
 
 
==========================================================
 
 
 
Dean Brockbank: Klamath Deals Already Producing  Results  
Op-Ed 
June 27,  2011 
Redding  Record Searchlight 
The June 13 "Speak Your Piece" "Water quality suffers as  Congress dithers" 
ignores the facts on the ground and in the water to make  several alarming 
claims of governmental malfeasance and corporate  indifference. Fortunately, 
the dire picture painted by the authors does not  exist. In fact, to make 
their points, the authors simply ignored the many  active steps PacifiCorp 
and other stakeholders are taking right now to  implement elements of the 
landmark Klamath agreements, including actions to  improve Klamath River water 
quality, aquatic habitat and the chances that  the fishery will be more 
abundant. 
For  example, to date PacifiCorp has provided more than $1.5 million to a 
coho  enhancement fund administered in cooperation with the National Marine  
Fisheries Service and the _California Department of  Fish and Game_ 
(http://www.redding.com/news/topic/california-department-of-fish-and-game/)  to 
support the  survival and recovery of coho salmon in the Upper Klamath River 
basin. Under  the Klamath Hydroelectric Settlement Agreement (KHSA), PacifiCorp 
will  continue to contribute more than $500,000 annually until the three 
Klamath  dams in California are decommissioned. Measures to enhance tributary 
cold  water flows critical for salmon, keep key coho streams connected to 
larger  tributaries and limit the impact of livestock on river habitat are 
among  many activities directly supported by the  fund. 
In addition to this funding, PacifiCorp is making changes to  operations 
and flow releases to improve conditions for salmon, supporting  research on 
fish disease that will aid in the development of management  strategies to 
combat this problem, and funding improvements to hatchery  operations that will 
benefit coho  salmon. 
Many other activities to improve water quality in the Klamath  watershed 
are well under way and will continue both before and after  Congress acts to 
approve and implement the agreements. These current  water-quality 
improvements include pilot projects and studies of measures to  reduce nutrient levels 
in the river and improve water quality throughout the  watershed, which 
have already begun. If the interior secretary issues an  affirmative decision 
to proceed with dam removal, more than $6 million is  committed to fully fund 
significant water-quality  improvements. 
In coordination with various state and federal agencies and  the Karuk and 
Yurok tribes, parties to the KHSA are now actively monitoring  water quality 
over approximately 250 miles of the Klamath River from the  Link River dam 
in Klamath Falls to the Pacific Ocean. This unique monitoring  effort is 
supported by $500,000 in annual funding from PacifiCorp and will  continue each 
year until the dams are  removed. 
Significant progress is being made on other fronts as well.  PacifiCorp has 
received approval in both California and Oregon to begin  collecting 
surcharges to cover the company's share of dam removal costs in  2020 and has 
already transferred all of its internal engineering and other  operational 
information to the appropriate federal agencies crafting a  detailed plan to 
remove the dams. 
Like everyone else, PacifiCorp is waiting for the interior  secretary's 
decision on whether to proceed with dam removal and a full and  fair debate in 
Congress, but a lot has been accomplished since the  agreements were signed 
last year and that work will continue. It is  important to remember that the 
improvements described above are being  implemented now as a result of the 
KHSA and would not be required in the  absence of the agreements. This is a 
testament to the efforts of the  involved parties to craft solutions to 
these complex resource issues that  avoid the alternative of continued 
litigation and the deferral of water  quality and habitat improvements that are 
happening  now. 
####################################################


 
 
In a message dated 8/23/2011 12:29:00 P.M. Pacific Daylight Time, 
_tstokely at att.net_ (mailto:tstokely at att.net)  writes:

PacifiCorp  Continues to Pollute With Permission
 
_http://www.tworiverstribune.com/2011/08/pacificorp-continues-to-pollute-wit
h-permission/_ 
(http://www.tworiverstribune.com/2011/08/pacificorp-continues-to-pollute-with-permission/)  
Clean  Water Act Deteriorates on Klamath River
By  Allie Hostler, Two Rivers Tribune 


PacifiCorp is on deck to receive yet another abeyance of its  California 
Clean Water section 401 certification today at the State Water  Resources 
Control Board meeting in Sacramento further delaying the power  producer’s 
obligation to reduce its pollution of the Klamath River. 
Prior to the culmination of the Klamath Basin Restoration  Agreement and 
Klamath Hydroelectric Settlement Agreement—two linked deals  that compromise 
permanent water deliveries to agricultural interest for  the removal of four 
hydroelectric dams on the Klamath River in California  and Oregon—the 
Federal Energy Regulatory Commission had nearly finished  its process to 
re-license the antiquated dams. 
The final step, the California Environmental Quality Act (CEQA)  process 
and the Clean Water Act Section 401 certification, was stalled in  2008 
because of a commitment amongst the Interior Secretary, numerous  stakeholders, 
and PacifiCorp to enter into serious negotiations under an  Agreement in 
Principle. 
Those negotiations were completed in February of 2010 when the  Interior 
Secretary, along with then Governor Arnold Schwarzenegger of  California, and 
then Governor Ted Kulongoski of Oregon met in Salem, Ore.  to sign the 
documents. Dozens of stakeholders also signed, including  several Klamath River 
Tribes and environmental groups. Legislation was due  to be enacted by May 
10, 2010, but it was not, and has not. 
Although three tribes signed, three did not; The Hoopa Valley  Tribe, the 
Resighini Rancheria and the Quartz Valley Indian Reservation.  Also, several 
environmental groups were either excluded from the  negotiations or 
voluntarily left the table because of their  disagreement. 
There are rumors that Oregon Senator, Jeff Merkley plans to  circulate a 
draft discussion bill in the near future, however, the rumors  have not yet 
been confirmed. 
The current Water Board resolution proposes to delete all  deadlines for 
enactment of federal legislation. 
“This is simple avoidance of the Board’s duty to protect  California water 
quality,” Hoopa Valley Tribal Council member, Hayley Hutt  said. “Stop 
hoping that the KHSA will do this Board’s work. Instead, they  need to complete 
the CEQA [California Environmental Quality Act] analysis  on PacifiCorp’s 
Section 401 application.” 
The Hoopa Valley Tribal Environmental Protection Agency (TEPA)  regularly 
tests water quality on the portion of the Klamath River that  passes through 
the Hoopa Reservation. According to TEPA Director, Ken  Norton, recent tests 
confirm what the Tribe suspected—levels of total  phosphorous, nitrogen and 
blue-green algae exceed applicable  standards. 
“The Water Board’s resolution says to continue the abeyance until  the 
Secretarial Determination (due in March of 2012), but what they do not  say is 
that the Secretary cannot legally make a determination if dam  removal is in 
the best interest of the public until federal legislation is  introduced,” 
Hutt said. Hutt will testify in front of the Water Board  today in 
Sacramento. 
Although proponents are equally frustrated with the delay in  progress to 
improve Klamath River water quality, they stand by the  Settlements they 
negotiated and signed. 
Craig Tucker, the Klamath Campaign Coordinator for the Karuk Tribe  said 
that the Karuk Tribe continues to believe that a negotiated  settlement is the 
surest way to dam removal. “I’ll stand by that until  proven otherwise,” 
he said. 
Tucker emphasized that the introduction of federal legislation  must occur 
by March, at the latest, and the stall is not due in any part  to the 
parties. 
“It hasn’t been for people’s lack of trying and effort,” he said.  “We 
are now on Congress’ clock. We need to get behind it and move it  forward.” 
Sean Stevens from Oregon Wild, a large non-profit environmental  group 
based out of Portland, Ore. said the group has tried to stop the  Water Board 
from giving PacifiCorp a free pass to continue polluting the  Klamath River. 
“Now that there’s a science report that says it’s unclear if dam  removal 
will reduce pollution in the Klamath River, it’s even more  important for 
the Water Board to address water quality in the Klamath  River with or without 
the Settlements,” Stevens  said.

 
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