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  • Workboat: Lockdown - Inside America’s decaying waterways infrastructure

    LaGrange-lock-damBy Pamela Glass on January 19, 2017

    More than half of the nation’s 242 inland waterway locks and dams are nearing or have surpassed their 50-year life spans. About a third are more than 70 years old. By 2020, it’s estimated that 78% of these locks and dams will exceed their design life.

    Those built in the 1930s are the oldest and in the worst shape. Many of them have concrete that’s crumbling, failing gates, and are plagued by emergency shutdowns that cause operational and financial headaches for barge operators. But even the newest ones, built in the 1970s and ‘80s and already old by construction standards, are too small for modern-day tows and are showing their age.

    Many of the oldest locks and dams along the 12,000-mile commercially navigable inland waterways system were built for steam-powered vessels that pushed small tows. Today, tows are bigger — with up to 15 barges carrying large loads of high-value cargo — and are part of a sophisticated, multimodal transportation network that moves commodities like coal, soybeans, cement and energy products for domestic consumption and international trade.

    A recent visit to the oldest and newest locks along the Upper Mississippi and Illinois rivers, among the nation’s busiest for barge traffic, provided visible evidence of the serious decline of inland infrastructure, and the challenge to maintain an efficient, reliable and globally competitive waterways system.

    Barge companies and the Army Corps of Engineers consider the LaGrange Lock and Dam at Versailles, Ill., one of the worst. Built in 1939, it is the southernmost lock on the Illinois River, located 80 miles upstream from where the Illinois and Mississippi meet. The structure accommodates a steady stream of barge traffic, moving mostly agricultural commodities as well as recreational vessels.

    The deterioration of the concrete at the LaGrange lock was evident in August 2016. Waterways Council photo.
    The deterioration of the lock concrete was obvious during an August press tour put together by the Waterways Council. Segments of the vertical lock wall concrete have been removed so it won’t fall into the river.

    But what can’t be seen is even more troubling. Corps officials said the mechanical and electrical systems are obsolete, and that high usage, frequent flooding and freeze-thaw cycles challenge the lock’s operations and reliability. The other issue is the obsolete lock’s size. The LaGrange lock is 600’×110′, while today’s big tows require 1,200-foot-long chambers. As a result, tows must be broken up and locked through in two stages, which can produce long waits of up to four hours.

    The Corps has been able to keep things going with emergency maintenance, but it is getting increasingly hard to find spare parts. Officials expect repairs to take more time, as replacement parts will need to be special ordered.

    “This site is our number one priority for major rehabilitation in the nation,” said Thomas Heinold, deputy chief of operations at the Corps of Engineers, Rock Island (Ill.) District, which is responsible for LaGrange. “It’s as if we bought a car in the 1930s and we’re still going with that original car. We have replaced some components and body parts, but what we really need to do is replace the car.”

    The funding history of LaGrange is an example of how navigation projects are inconsistently handled by Congress. A major rehabilitation evaluation report on LaGrange in 2005 estimated a major rehab cost at $72.6 million. Between 2005-2010, Congress appropriated money to design the new 1,200-foot lock, but work was suspended in 2011 due to lack of funding. It is hoped that an infusion of funds into the Inland Waterways Trust Fund from an increase in the barge fuel tax will soon help put the project back on track.

    For shippers, modernizing the locks at LaGrange is essential to their business, especially this year when the corn harvest has been one of the biggest on record. “We’re 70 cents below on profit on corn, so pennies matter. This is why we need an efficient waterways system that is competitive to rail. We need that competition because rail can’t handle our capacity,” said Rodney Weinzieri, executive director of the Illinois Corn Marketing Board. “Reliability is everything. It will bring our transportation costs down.”
    OLD VS. NEW

    The Melvin Price Locks and Dam has two lock chambers — 600′ and a 1,200’x110′ main chamber. Pamela Glass photo.
    The Melvin Price Locks and Dam on the Mississippi River in Alton, Ill, is one of the newest facilities in the inland system. Located 20 miles above St. Louis, it opened in 1989. It has two lock chambers — a 600-foot lock used for recreational and smaller craft, and a 1,200’×110′ main chamber used for large commercial tows. About 74 million tons of commodities move through the locks annually.

    Barge operators who traverse LaGrange and Mel Price say locking through Mel Price is a highlight of their trip, as it usually means a quick and efficient lock-through of only 45 minutes, compared to several hours at LaGrange.

    “We get through in less than half the time,” said Jeff Stoneking, captain of the Christopher Myskowski, a 6,140-hp Marquette Transportation Co. towboat that was docked near the Melvin Price locks and welcomed journalists on board. He said towboats must pay close attention when navigating through the smaller chambers. “Those locks are designed for two, four, six barges pushed by steamboat, and we’re now pushing 15. You only get one shot at it.”

    At the Melvin Price locks, tows lock through in less than half the time it takes to pass through the LaGrange Lock and Dam. Pamela Glass photo.
    Even this newer facility has had its share of breakdowns. Cables for one of Mel Price’s chamber gates failed in 2014, causing an eight-month shutdown of that chamber because materials needed for the repair were not available immediately. Luckily the facility has two chambers, thus avoiding a complete system closure. The incident is an example of another nagging problem for waterways: deferred maintenance. The Corps of Engineers had to defer work on other navigation projects in order to pay the $4 million emergency repairs at Mel Price.

    Part of the problem in securing funds for inland infrastructure is that projects are costly and not as visible to the public as other transportation modes, such as road and rail. As a result, Congress has paid scant attention to adequately funding the system. But after years of efforts to educate state and federal lawmakers about the importance of waterways investment, industry officials say prospects for funding have brightened and that many inland locks and dams are finally receiving money for modernization and operations.

    Changes are underway in both politics and policy. Corps of Engineers budgets for inland navigation have been the highest ever in recent memory; a much-needed increase in the barge fuel tax is bringing an influx of money to the trust fund that shares the costs of navigation improvements with the federal treasury; Congress has put the Water Resources Development Act (WRDA), which authorizes water projects and sets water policy, back on a two-year authorization cycle; the cost-share arrangement for the over-budget and expensive Olmsted Locks and Dam project in Illinois was changed to allow more Trust Fund money to be used for other projects; and there’s been a growing acknowledgement, and budget support, from states that rivers are important for commercial, not just recreational uses.

    Most recently, a commitment from president-elect Donald Trump to boost the nation’s sagging infrastructure, from highways and bridges to waterways, has given the industry hope that this progress has staying power, and that a flurry of nationwide construction projects will bring new business to the waterways.

    About the author:    •    
    Pamela Glass is the Washington, D.C., correspondent for WorkBoat. She reports on the decisions and deliberations of congressional committees and federal agencies that affect the maritime industry, including the Coast Guard, U.S. Maritime Administration and U.S. Army Corps of Engineers. Prior to coming to WorkBoat, she covered coastal, oceans and maritime industry news for 15 years for newspapers in coastal areas of Massachusetts and Michigan for Ottaway News Service, a division of the Dow Jones Company. She began her newspaper career at the New Bedford (Mass.) Standard-Times. A native of Massachusetts, she is a 1978 graduate of Wesleyan University (Conn.). She currently resides in Potomac, Md.

    https://www.workboat.com/news/coastal-inland-waterways/lockdown-decaying-inland-waterways-infrastructure/

  • WSJ: Declining Salmon Population Threatens Fishing Tourism in Pacific Northwest

    This year regional agencies recorded one of the smallest counts of spring Chinook salmon in a generation in the Snake and Columbia river basin

    neil.recfish1.webBy Sarah Trent
    Aug. 21, 2021

    RIGGINS, Idaho—Beneath the vacancy sign at the Salmon River Motel, a black and white placard reads “Salmon Lives Matter, Give a Dam.” For years the motel has been a profitable business in this canyon town of 400 three hours north of Boise, with a mile-long Main Street that swells each summer with visiting sport fishermen.

    Now the motel and other businesses here are at risk, as the fish that drive the local economy shrink in both number and size.

    This year, regional fish and wildlife agencies recorded one of the smallest counts of adult spring Chinook salmon in a generation in the Snake and Columbia river basin. Last year was worse. A wide body of research connects their decline to rising temperatures and climate change, which have compounded the damage done to fish populations by hydroelectric dams.

    The impact of this decline ripples along this species’ entire migratory route, from the tourist economies and tribal communities of the inland Northwest to the $2 billion commercial fishing industry in ocean waters as far as Alaska, where state fisheries report total harvest weight has dropped by half since the 1960s.

    Across the inland Pacific Northwest, dwindling salmon runs have emptied motel rooms, tackle shops and restaurants. Business in Riggins this summer beat expectations as pandemic fears eased, but the continuing decline of the sought-after Chinook—the largest of all Pacific salmon—threatens to devastate economies and tribes throughout the Pacific Northwest and Alaska.

    If salmon continue to decline, “it will hurt this town,” said Salmon River Motel owner Jerry Walker, whose family of loggers suffered when the town’s sawmill burned down in 1982. Without the fish that helped Riggins rebuild its economy, he said, “there’s nothing else here.”

    Outdoor-resource tourism economies like Riggins “are really fragile things,” said Aaron Lieberman, executive director of the Idaho Outfitters and Guides Association. The decline of one resource can cause a cascading effect, he said. “When you don’t have fish runs, you don’t have people coming, the entire economy is crippled.”

    Reports by the Idaho Department of Fish & Game show that salmon in the connected Columbia and Snake river basins in Idaho, Washington and Oregon first plummeted after the midcentury construction of eight hydroelectric dams that blocked or slowed migration. Fish must swim hundreds of miles downstream as finger-sized juveniles heading to sea, then return upstream again several years later to spawn.

    State, federal and tribal governments developed a national hatchery system to mitigate these losses by releasing tens of millions of juvenile fish each year. By the early 2000s, it seemed those efforts were working: State data showed returning adults peaked around 2001. Riggins locals recall streets lined with RVs and great fishing for weeks on end. A state-commissioned economic analysis showed salmon fishing alone that year brought $10 million to Riggins, accounting for a quarter of the town’s annual revenue.

    Since then, research and fisheries data show spring Chinook runs are getting smaller and individual fish weigh less, too. Lower snowpack, warmer nights, and heat waves like those that have blasted this region all summer have caused lower flows and warmer conditions inhospitable to these cold-water fish.

    This spring, researchers at the Nez Perce Tribe Department of Fisheries Resources Management said 42% of wild Chinook populations in the Snake River Basin had reached “quasi-extinction levels” and predicted 77% of populations would fall to that level by 2025.

    Hatcheries throughout the region still collect enough of their own returning fish to spawn and meet their production mandate, said Ralph Steiner, who manages the Rapid River National Hatchery near Riggins, but there are fewer left in the river for fishing. Because of rising water temperatures and earlier migrations associated with climate change, he said, their operations also face new challenges and increasing costs to replenish the fish vital to commercial, recreational and tribal fisheries.

    This May, facing fewer salmon and tighter state restrictions, Riggins outfitter and guide Roy Akins canceled half his salmon bookings, returning a total of $15,000 to 60 fishermen he said were frustrated and disappointed. “Nobody wants to hear that the day they’ve been looking forward to is going to be taken away from them,” Mr. Akins said.

    As fishermen rethought travel plans, the Salmon River Motel saw normally booked-solid rooms sit empty, said Sharon Walker, referencing records from before she and her husband bought the property in August. John Belton, owner of Seven Devils Steak House at the center of town, said slow spring salmon years can cut their May and June income in half.

    Debbie Swift, who works at liquor and tackle store Hook Line & Sinker, said that tackle sales have decreased over the years, and that slow seasons and cancellations complicate inventory decisions.

    The salmon decline also leaves recreational fishermen and tribal communities, which by law split the available harvest, “fighting over scraps,” Mr. Akins said.

    Tribal communities say it isn’t just their economic health, but their very existence that is at stake. For these traditionally subsistence communities, salmon are a sacred source of food and connection with the Earth, and are at the root of tribes’ cultures, languages and songs, said Aja DeCoteau, interim director of the Intertribal Fish Commission coordinating management efforts of four tribes in the Columbia Basin.

    Ms. DeCoteau, a Yakama Tribe member, said lately there are years when there aren’t enough fish to sell, let alone fill her community’s freezers for the year. “This is just the beginning,” she said. “We have to adapt.”

    Her organization has contributed research, a salmon recovery plan, and invested federal grants totaling $27 million toward watershed restoration. Mr. Akins said that without the tribes’ efforts, he believes salmon here would already be extinct.

    This year, Mr. Akins, Nez Perce leaders and conservation groups backed a proposal by Rep. Mike Simpson (R., Idaho) calling for redeveloping energy infrastructure and breaching the Snake River dams, citing the increasing threat of climate change and the enormous cost of salmon extinction to his state.

    Mr. Akins said he was hopeful, but less so than as a young man advocating for these precious fish. Now, he said, he and his wife, Karen Akins, want to diversify their income. They would like to buy a self-storage facility, Ms. Akins said: It is less risky than fishing.

  • Yakima Herald: Grant boosts effort to dismantle Yakima's Nelson Dam

    Michelle Iracheta, December 2, 2016

    nelson copyFor the better part of a century the Nelson Dam on the Naches River has hampered salmon trying to migrate upstream, while preventing countless tons of sediment from being carried downstream where it’s needed.

    Yakima County is moving closer to getting both fish and sediment to the right places under a plan that creates more wildlife habitat and reduces the danger of floods.

    On Tuesday, a national environmental group announced it is donating money to three dam removal projects in Oregon, California and here for the Nelson Dam.

    The $75,000 donation will account for only a small portion of the estimated $12 million price tag for the dam removal project that been planned for years by Yakima city and county officials and the Yakama Nation.

    But the donations quickly caught the eye of the National Geographic Society’s web page, which noted plans for the Nelson Dam are part of a growing movement to remove aging dams, while benefiting people and wildlife.

    Located near U.S. Highway 12’s twin bridges west of Yakima, the dam was first built in the 1920s, and rebuilt in 1985 in order to divert irrigation water into the city of Yakima.

    However, there are a number of problems with the dam. At a height of 8 feet, it creates a significant backwash and presents a formidable obstacle to fish trying to migrate upstream.

    The dam is also significantly worn, said Joel Freudenthal, Yakima County senior natural resources specialist.

    It’s not at a stage where it’s an immediate danger to the community, but come rushing waters from floods, the dam could pose a threat, he said.

    By slowing the natural speed of the river, the dam also traps sediment upstream, creating conditions that have led to flooding.

    Removing the dam will help with the flood risk, said David Brown, city of Yakima water and irrigation manager. “We want that gravel to roll down the river. Highway 12 is under a flood plain. With the dam gone, it will no longer be in the flood plain.”

    Removal will allow more than half of a million cubic yards of gravel be carried downstream to create more spawning habitat in an area that’s been deprived of natural sediment for decades.

    Meanwhile, removing the dam won’t curtail that diversion of irrigation water, but merely change the way it’s taken from the river.

    The plan is to build a wide, roughened channel that fits into the natural design of the environment and acts like a ramp, Brown said.

    The removal of the dam is scheduled to start by fall 2017 if all permits are in place.

    Tuesday’s small grant was provided by Open Rivers Fund, a philanthropic fund dedicated to dam removal and river restoration.

    The fund also provided money for the removal of the Matilija Dam in California’s Ventura County and the Savage Rapids Dam on Oregon’s Rogue River.

    The group noted the Nelson Dam removal plan is broadly supported by irrigation districts, local, state and federal agencies, the Yakama Nation and various environmental groups.

    “There are more and more communities grappling with these legacy dams. They break, people’s houses get flooded, or people die. Fixing those old dams can be very expensive,” said Michael Scott, acting program manager with the Hewlett Foundation, which operates the Open Rivers Fund.

    “It makes sense for the county,” Brown said. “It’s probably cheaper than putting in a bunch of concrete.”

    •Reach Michelle Iracheta at 509-577-7675 or at miracheta@yakimaherald.com. Follow her on Twitter @cephira.

  • YES! Magazine: Tribes Are Leading the Way to Remove Dams and Restore Ecosystems

    When the Elwha River dams fell, it was the culmination of many decades of successful partnerships to support the Lower Elwha Klallam Tribe in righting historic wrongs.

    redroad2By Lindsay Vansomeren
    July 14, 2021

    Cameron Macias bent down to examine a small pile of sawdust-filled scat on the floor of the former Lake Mills on the Elwha River in the northwest corner of Washington state in 2016. It was a sign that beavers were moving into the area after a 100+ year absence. “There’s very small dam-building activity in some of the side tributaries,” says Macias, who was working at the time as a wildlife technician for the Lower Elwha Klallam Tribe, of which she is a member. “It’s kind of funny and ironic because of the dam removal,” Macias says with a laugh.

    The dams she’s referring to—the Elwha and Glines Canyon dams—were removed in 2011 and 2014 respectively, and together they are considered the world’s largest dam removal project to date. Many other tribes have looked to the success of the Elwha River dam removals in bringing down fish-blocking dams in their lands as well, including along the Snake River and the Columbia River in the Pacific Northwest.

    Together, the country’s 2 million dams block access to more than 600,000 miles of river for fish. And by 2030, the American Society of Civil Engineers estimates that 80% of those dams will be beyond their 50-year lifespans. Given how obsolete and potentially dangerous this infrastructure will be, not to mention its negative effects on declining fish stocks, the best solution for many aging dams is to simply remove them. But bringing down a dam is a big job.

    When the Elwha River dams fell, it was the culmination of many decades of successful partnerships among the Lower Elwha Klallam Tribe, the National Park Service, the U.S. Fish and Wildlife Service, and dozens of other local and national organizations. Today, those partnerships continue to support the tribe in righting historic wrongs.

    Righting Historic Wrongs

    The Elwha Dam was built in 1910 to provide electricity to attract new settlers, in flagrant violation of a Washington state law that said dams must allow for fish passage. At the time, no one consulted the Lower Elwha Klallam people, whose culture rests on the salmon that would be blocked by the dams. “We had a few of the elders that even stood in the areas of the lower dam where they were starting to build to protest,” says Frances Charles, the tribal chairwoman for the Lower Elwha Klallam Tribe.

    But the dam construction proceeded, and afterward, hatcheries were put in as a sort of life support to keep salmon populations afloat. Every year, the fish born in the hatcheries would try to return to the spawning grounds of their ancestors, banging their heads on the dam in a desperate attempt to get upstream.

    “We ourselves felt like we were banging our heads against the concrete wall, no different than the salmon,” Charles says.

    Things changed in January 1986 when the tribe filed a motion to stop the relicensing of the dams, citing that the dam prevented them from exercising their treaty rights because it blocked fish passage.

    “The tribe and [Olympic National] Park and the environmental interests said, ‘You know, if you’re going to license these things, you’re going to provide fish passage,’” says Mike McHenry, the Tribe’s fisheries habitat manager. Studies showed that building fish passages wouldn’t effectively restore the salmon runs, so the decision was made to take down the dams. Still, it took an Act of Congress and $325 million to complete the job.

    Congress laid out a monumental goal in the Elwha Act: nothing less than the “full restoration of the Elwha River ecosystem and native anadromous fisheries.” In other words, reverting everything back to the way it would have been without the dams.

    To do this restoration work, tribal biologists regularly team up with universities and nongovernmental organizations to apply for grants. For example, Macias—on a grant funded by the nongovernmental organization Panthera—is now working on her Ph.D. at the University of Idaho by studying cougars and bobcats in her tribal homeland. And the tribe counts many other state, federal, and environmental groups as partners in monitoring the restoration of the Elwha.

    To Charles, partnering with other groups makes sense in many ways. “[The dams are] not only impacting you as a tribe, it impacts everybody that’s around because they’re a part of that just as much.”

    The Power of Treaties

    Ultimately, one of the most effective tools in taking down the dams was the Treaty of Point No Point. The ancestors of the Lower Elwha Klallam Tribe signed the treaty in 1855, ceding their lands to incoming settlers in return for “the right of taking fish at usual and accustomed grounds.” In a 1974 Federal District Court case, Judge George Boldt ruled that Washington tribes were allowed half of all the harvestable salmon.

    “That really empowered the tribes in Washington to become, essentially, a co-manager with the state,” McHenry says. In essence, the ancestors of the Lower Elwha Klallam Tribe paid for their descendants to have harvestable fish today by ceding lands to settlers. Because the dams prevented that, the Lower Elwha Klallam Tribe had legal standing to bring down the dams.

    There are almost 400 treaties between Indigenous tribes and the United States, each with different terms. This highlights a unique point for Indigenous people as land managers: No two tribes are the same. “I can’t tell you how many times I’ve had a call where somebody wants the ‘Indigenous perspective.’ It’s not this ‘one thing,’” says Julie Thorstenson, the executive director for the Native American Fish and Wildlife Society. “They’re all different, but the number one thing that they have in common is that they’re all underfunded.”

    Indeed, the Lower Elwha Klallam Tribe relies on grants for much of its work, both before the dams went down and afterward for things like protecting fish during the dam removals, revegetating the newly drained landscape, and monitoring for signs of plant, animal, and insect recolonization.

    The National Park Service alone has provided the Lower Elwha Klallam Tribe with nearly $3 million in funding over the past nine years to pay for the restoration work, with funding set to expire in 2022. But full recovery could take far longer, up to 30 years, according to a fish restoration plan developed by NOAA. “It would be really bad if funding just ended in 2023, and we are working to ensure that does not happen,” McHenry wrote in an email.

    Thorstenson says, “We hustle. I’m really always amazed at how innovative tribes are.” At the same time, she says, “Grants don’t promote capacity-building, and they don’t promote self-governance, which is what tribes are really striving for.”

    Dam Removals Coast to Coast

    The Penobscot Nation in what is now the state of Maine faced a similar dilemma starting in the 1880s: Three hydroelectric dams were blocking anadromous fish from getting back up the river.

    “[We] had a little informal kind of contest going as to who is going to get their dams out first,” says John Banks, the director of the Department of Natural Resources for Penobscot Nation. “And Elwha beat our tribe by one year because we had a delay,” Banks says, laughing.

    When the dam’s owners came to Penobscot Nation in 1999 wanting to know what they’d need to get tribal support during the relicensing process, Banks was ready with an answer.

    “Number one, the removal of main stem dams must be on the table for discussion. And number two, we’re gonna bring our friends with us,” he said. “Because we know all about divide and conquer, and it’s not going to happen. We are going to work with these environmental groups.”

    Penobscot Nation formed a trust with other NGO partners to bought the dams. They took out two of the dams and preserved a third, around which they were able to build fish passage. The original dam’s owners were able to ramp up production at other sites, and thus it was a win-win: the tribe got the fish back, and the hydroelectric production was maintained.

    The Penobscot River Restoration Trust is considered extraordinarily successful, but Banks is also quick to highlight a frustration that many tribes share: Non-Tribal groups often don’t understand issues of Tribal sovereignty, Federal Indian law, or overall tribal interests. “That was challenging from time to time, but we just kept looking for commonalities and not our differences,” Banks says.

    The Work of Restoration Continues

    In the case of the Elwha, the tribe always had legal standing to challenge the dams. But it wasn’t until the tribe won over the public through outreach and education—such as the annual ceremony of traveling in traditional canoes to visit different Nations around Puget Sound—that they received enough public support to remove the dams and form fruitful new partnerships. “I really feel that a lot of the outreach with Canoe Journeys has been real good medicine to draw in the outside to really witness the cultural values of each Nation,” Charles says.

    Despite setbacks, the restoration has made great progress. Macias describes one of the first big changes she noticed on the drained landscape back in 2016: “The entire lake bed at Lake Mills was just covered in lupine, and lupine is so good for so many reasons. It’s just beautiful. And it’s native,” she says. “Now, [in 2021, the landscape] is so incredibly dense with willows and alders. At this point, there are a bunch of conifers growing up among those different trees as well. And so we’re seeing plant succession,” she says, referring to the healthy process of how plant communities change over time after a disturbance.

    That recovery applies to the salmon too: According to McHenry, the chinook, steelhead, and bull trout are all recolonizing well. Coho have been a bit slower, and the tribe is still waiting for chum and pink salmon to come back in good numbers. The tribe continues to work to improve the habitat for newly returning fish, such as by placing logs and boulders into the river to create pools where young fish can thrive. Kim Sager-Fradkin, the tribe’s wildlife biologist, has measured how nutrients from the ocean are making their way into birds and river otters further upstream via the migration of salmon, in addition to measuring how wildlife are using the newly available habitat.

    Even though full recovery will take decades, Chairwoman Charles of the Lower Elwha Klallam Tribe isn’t worried. Her biggest piece of advice to the other tribes working on dam removal and restoration is simple: “Don’t give up.” Administrations, political whims, and partnerships may change, but the people (and hopefully the salmon now, too) will always be there.

    “It took 100 years for these dams to be taken out. And we’ve lost so many of our elders through the process,” Charles says. “But we know that they’re looking down upon us and really grinnin’ for the pride that we could feel with everybody that was there from all ethics and all regions and all areas.”

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