text:
State and Federal Contractors Water Agency comments Fourth Draft Delta Plan
1121 L Street, Suite 1045, Sacramento, CA 95814
Chairman Isenberg and Council Members
980 Ninth Street, Suite 1500
Re: State and Federal Contractors Water Agency comments
Fourth Draft Delta Plan
Dear Chairman Isenberg and Council Members:
The State and Federal Contractors Water Agency (SFCWA) appreciates the opportunity to comment on the Fourth Draft Delta Plan (Delta Plan), dated June 13, 2011. We once again commend the Council's staff for its obvious level of effort to produce these drafts on a timely basis. We are pleased that in many respects this draft represents an improvement from the Third Draft Delta Plan and we are gratified that many suggestions for improvements from many stakeholders, including ourselves, were incorporated in this latest version of the Delta Plan. We particularly recognize the new "Appendix A", which attempts to provide some clarity with regard to the Council's view of its relationship to the Bay Delta Conservation Plan (BDCP). However, as we will describe below in our overall comments and then with specific editorial comments and suggested wording changes, the Delta Plan still contains some significant flaws in approach, expectations, acknowledgment and understanding of the State Water Resources Control Board's (SWRCB or Board) processes, and continued overreach with regard to "covered actions" and the asserted regulatory authority of the Council.
Improvement in Water Supply Reliability – Perhaps the biggest (and arguably fatal legal) flaw of the draft Delta Plan is that the water supply reliability coequal goal is characterized in the context of a zero-sum approach. The Council manifests this viewpoint unnecessarily and without substantiation through statements that more water should be reallocated to environmental/flow purposes, which are fundamentally contrary to the improve water supply reliability coequal goal. The position seems to be that investment in local resources is the only method of "improving statewide water supply reliability" while simultaneously (and certainly counter-intuitively) advocating reducing exports from a present-day baseline. Water supply reliability to meet the standard set forth in section 85302(d) of the Act cannot be defined as the export contractors receiving less water than currently available to meet present demands. This would result in disinvestment in the Delta. The discussion of water supply reliability in the Delta Plan needs to be recalibrated to reflect an effort to increase the availability of supplies transferred through the Delta at times and in manners which are more environmentally benign, which , in turn allows relatively less to be diverted during dry periods. This involves more than promoting local resource development via insertion of the Council's "covered action" consistency authority into local resource development matters. Instead, the Plan needs to express the need to improve reliability and the long-term average amount of exports available from the Delta system compared to today's levels; while recognizing that all project operations will be regulated by the Board to meet appropriate public trust, Constitutional, and coequal goal requirements. Concurrent with investment in better conveyance and addressing all ecosystem stressors, both parts of the coequal goal can thus be met.
We encourage and request a specific statement in the Delta Plan with regard to how the Council views improvements in water supply and water supply reliability intended to be achieved through the implementation of the Bay Delta Conservation Plan (BDCP). The Act is quite clear that the BDCP, and its water management benefits – for both the environment and water supply – was considered by the Legislature to be an important and integral component of an effective Delta Plan, should it satisfy the requirements for incorporation in section 85320. It would be illogical for the Act to include such direction if the Legislature also believed the BDCP somehow be inconsistent with the Delta Plan, the coequal goals, or the policy enumerated in section 85021 to "reduce reliance on the Delta in meeting California's future water supply needs." To ensure no ambiguity, we provide the following suggested language and request the Council include it in the Delta Plan as part of its discussion of baselines related to "performance measures" in Chapter 4. At page 75, after line 17, add:
Consistent with legislative direction to incorporate the Bay Delta Conservation Plan (BDCP) into the Delta Plan pursuant to section 85320 of the Act, the Council has determined that the baseline for measuring progress toward reducing reliance on the Delta to meet California's future water supply needs relative to SWP and CVP export levels will be established by their operations and modeled long-term average deliveries in compliance with state and federal regulatory standards and requirements applicable upon initiation of operation of new Delta conveyance facilities included as part of the BDCP.
The draft Delta Plan's discussion of water demand seems to champion the view that future statewide water demands will be reduced from present levels. While fine as an aspirational goal, no analytical foundation is provided to assess whether it is realistic. As one example, Figure 4-5 on page 61 shows aggregate water use declining. This reflects a reduction in agricultural water use, not urban use which is still trending slightly upward, and also likely reflects drought conditions and fallowing of acreage. . Though agricultural acreage may be trending downward, climate change is expected to necessitate additional water applications to crops to compensate for loss of soil moisture, reduced precipitation, ambient temperature increases, etc. In addition, urban demands will increase in the future, though those increased demands will largely be met through increased water use efficiency measures, conservation and local resource development and thus total use is unlikely to change significantly.
Role of the SWRCB with regard to flows – Another area where we have concerns is the Delta Plan's repeated misuse of terminology related to the SWRCB's processes, as well as the unrealistic timeline expectations for the Board to complete some of its activities. The Delta Plan inappropriately conflates "flow" with "objectives" and "criteria" on numerous occasions when describing what the Board will be "developing" or "adopting" or "implementing". The Board will be reviewing and potentially updating its Water Quality Control Plan for the Bay-Delta, and at the end of that process will consider whether and how to issue revised water quality objectives and related flow requirements. Developing operating criteria applicable to diversions within the watershed is an implementation strategy for achievement of water quality objectives, and this particular tool implicates "flow" management. We strongly encourage the Delta Plan to be reworked so the correct terminology and description of the Board's processes is accurate throughout the document. This also applies to the timeline expectations. It should be clear that the Board will be reviewing its WQCP in the near term to reflect the initial implementation of the BDCP, and will need to revise it prior to issuing operational permits for new conveyance that is not expected to be operational for a decade or more. This two-step approach needs to be reflected in the Delta Plan and its timeline expectations, which means that the present January 1, 2014 date for "adoption and implementation" of new standards is unlikely to be met and we suggest further consultation with the Board and the BDCP's management committee to ascertain the proper timelines.
BDCP as a Package of Actions – The Council's assertion on page 48 [Lines 19-22] that consistency certifications would be required for actions undertaken pursuant to the BDCP after its incorporation into the Delta Plan could result in "selective" incorporation of BDCP projects and consequently is quite troubling. The first sentence imposes a superfluous requirement not contained in, and inconsistent with, the Act. The second sentence is beyond the Council's authority. If the BDCP is incorporated into the Delta Plan consistent with the Act, then all of its activities are by definition consistent with the Delta Plan. The Council does not have the authority to regulate or reject parts of the BDCP after its incorporation into the Delta Plan. As an NCCP/HCP the BDCP is a comprehensive package of actions, commitments and assurances approved by state and federal fishery agencies that cannot be cannibalized or pulled apart.
Regulatory Approach and Consideration of Covered Actions – We still believe the asserted ability to bootstrap local water management decisions far removed from the Delta into the Council's "covered action" jurisdiction is unfounded and "policy A" on page 62 [L 35-37] should be deleted. This "covered action" "trigger" is rife with problems of vagueness and overreach. Does "export of water" mean any movement of water by the SWP or CVP under current contracts and biological opinions? The same question applies to transfers. Such operations are certainly "routine" and excluded from being subject to "covered action" consistency review by the Act itself. Moreover, regulation of such operations is reserved to the Board exclusively by the Act. Even if such a "policy" were appropriate, what is the definition of "significantly caused by"? As written, an SWP or CVP contractor who is a wholesale agency could be charged with pursuing an "inconsistent" action based upon the deficiencies of one of its (potentially many) member agencies, over which it has no control. In attempting to impose a "forcing mechanism", the Delta Plan here goes too far. This criticism also applies to WR R10 on page 74 related to SWP contracts, which should also be deleted.
The requirement that the proposed new Water Reliability Element "document actual or projected net reduction in reliance on Delta exports" on page 63 [L 25-26] is inappropriate. That is not what the Act requires. Instead, the statute specifies reduced reliance in meeting future water supply needs which is very different than an "actual…net reduction" from current levels. Reduction in reliance on Delta exports will be accomplished through increased local water resource development. If the intent is to require a showing of meeting ordinary existing demands while receiving less imported supplies than under a successfully implemented BDCP, that would be inconsistent with the Act and the coequal goals.
The Council needs to clarify that the "regional water balance" sought on page 64 would include a region's imported water supplies. If that is not the intent, most regions of the state would never succeed in bringing their "region into balance". It must be the demand within the hydrologic region that is the criterion focusing the analysis, but the balance "inputs" cannot be limited to water supply solely available within that hydrologic region. The latter point needs to be clearly stated.
The Council needs to define what it means by a rate structure that "sustainably encourages and supports water conservation" [P 64, L 26-29]. Moreover, are these rate structure recommendations intended to apply to wholesalers? They should not. Wholesalers have different financial requirements than retailers and are at least one step removed from direct interaction with the end-user where price functions apply. The question of applicability also applies with regard to agricultural water districts. How would such a hypothetical rate structure be applied? Volumetrically or based on utilization of WUE technologies or..? This recommendation needs much more thought and clarification. The footnoted description from Utah, though helpful, contains many vague terms and concepts triggering more questions than they answer.
WR R3 on page 65 [L 13-16] is problematic at best. In the first place, a new diversion point does not necessarily result in or reflect new or increased demand for water; it may instead be a response to water management and operational needs to serve a distinct geographic location with existing supplies, or even potentially serve environmental uses. Secondly, from what baseline is "new or increased demand for diversions" measured? If the new point of delivery is receiving water under current contract entitlements and consistent with regulatory requirements, will the Council consider that to be "inconsistent" under this proposed recommendation? If that is the Council's view, it is inconsistent with the Act. More clarity, specificity and examples are needed here to understand the Council's intentions.
Strategic Levee Investment Strategy – The Delta Plan's discussion of flood protection is somewhat lacking. A major deficiency is that the Council has not satisfied the Act's direction under section 85306 for it to include in the Delta Plan its own recommendations for a strategic levee investment strategy. Instead, the Council has punted on this long overdue and critical input to planning for the Delta. In addition, the 4th Delta Plan does not recognize that economically based risk reduction analyses need to be performed on an island- by- island basis and that levee policies for the eventual conversion of some islands to habitat have to be developed before major investments are made in levee improvements. This would, of course, be central to priority setting as part of the development of a strategic levee investment strategy to further the achievement of the coequal goals. The Delta Plan does not recognize that habitat restoration land costs will be higher and there will be significantly higher potential stranded costs if plans and policies coordinating restoration with levees are not developed as an initial step. The Delta Plan has also not recognized the need to evaluate subsidence costs, the existing DWR emergency response efforts nor the "Pathway" program in the Emergency Preparedness chapter. These issues need to be rectified in the next draft.
In addition to the overarching comments we have provided above, we also have reviewed the text in order to provide specific detailed edits, and we are providing those in Attachment 1. We strongly encourage that the council or its staff consider reviewing each of these sets of comments with us in order to assure that their intent is fully understood and that they are not unintentionally or arbitrarily rejected.
We appreciate the opportunity to comment and look forward to continued participation in Plan development.
Byron M. Buck
Attachment A
Specific Editorial Comments:
P iv L15: "Creating a More Natural Flow Regime" should be replaced with something like "Creating a More Variable Flow Regime to Improve Ecosystem Performance" or "Increase Variability in Flow Management to Improve Ecosystem Function". This should be a substitution made throughout the document. It is not as elegant perhaps, but it more accurately captures the intent of the activity, focuses on the key criterion (i.e. variability), and doesn't imply an effort to return to an unattainable, hypothesized condition that would preclude achievement of the coequal goals. The intent is to focus on trying to manage flows in a manner to more closely mimic pre-development peaks and valleys of the hydrograph (though their amplitude will generally not be the same), taking into account the numerous other factors involved in optimizing the benefits of such management choices.
P 3 L 8: delete "seeming". These were, and still are, comparatively areas of water abundance. It is understood Area of Origin protections are not affected by the Delta Reform Act.
P 3 L 10: delete "during dry times". Though it is a true statement, it implies such supplies were only needed during "dry" times, when in fact those supplies are necessary all the time and in some places represent essentially the only water supplies available.
P 3 L 17: delete "—and abused". This is gratuitous, untrue, and has no place in this document.
P 3 L 22: add at the end of the sentence "…society, while maintaining its central role in ensuring water supply reliability for the State."
P 4 L 1: As commented on before, the Delta Plan, in itself, will not "achieve" the coequal goals. Generally, the terminology should be "further the achievement of the coequal goals." This should be a change reflected throughout the document.
P 4 L 6-7: delete "ignored" and change sentence to read "…in decline cannot be left unresolved much longer without significant consequence to the interests of all Californians." The word "ignored" itself ignores the significant and costly efforts that have been expended on addressing Delta issues over the last decades.
P 4 L 10: delete or replace the inaccurate language "to achieve those goals". The statutory language requires a Delta Plan "that furthers the co-equal goals (Section 85300(a)). As noted above, the Delta Plan itself will not, and the Legislature did not expect it to, "achieve" the coequal goals and hence the wording should be changed. In this instance, the problem is also that the sentence reads as if the goals are required to actually be achieved by January 1, 2012, rather than simply the completion and adoption of the Delta Plan by that date.
P 4 L 18: it should be "an historical" not "a historical".
P 4 L 43-44: once again, the Delta is not the source of export water supplies. In addition, because the bullet only references dependence on "Delta water exports", it seemingly excludes the diversions from the watershed itself that bypass the Delta altogether, i.e. SFPUC and EBMUD. This should be corrected. We suggest the following construct instead: "The Delta watershed provides water for millions of Californians. it is not California's dominant water supply. Though some water users are entirely dependent on water conveyed through and exported from the Delta or diverted from the watershed upstream, or exported from, but most use…."
P 5 L 1-2: "only for a portion" implies imported supplies are of minimal consequence. This is false and misleading. We suggest the following language instead: "…supplies and depend on Delta imported water for only a portion as an important component of their overall water supply portfolio." Delete "Therefore," add "to further diversify".
P 5 L 6: add at end of sentence, "…the Delta to meet future water supply needs."
P 5 L 10: add "…improved reliability of Delta water, to recover lost export capability through enhanced operational flexibility and to make historic investments in the Delta ecosystem…." The BDCP is not just about "reliability" but also about increasing export capability consistent with regulatory prescriptions and the coequal goal.
P 5 L 14-20: The SWRCB reviews and updates its "Water Quality Control Plan" which includes "water quality objectives" and "flow requirements". "Flow" is a tool the Board can use in developing an implementation plan to try to achieve the water quality objectives. However, "flow" alterations implicate water rights and thus entail a "water rights proceeding" to actually implement such a "flow" component. This entire issue is, as the Council has appropriately stated, within the purview of the Board. Consequently, in addition to getting the wording correct in the first sentence, we suggest deleting the 2nd and 3rd sentences altogether. In addition, the statute does not call on the Board to do anything with regard to "high-priority tributaries" other than undertake "studies"; there is no call or deadline for producing new "objectives" or other regulatory action in relation to those streams, consequently the Delta Plan should not imply otherwise.
P 5 L 21: delete "suffered from" and replace with "been transformed by".
P 5 L 28: replace "the natural flow regime" with "more variable flow management" or newly developed language per discussion provided at the beginning of these comments above.
P 5 L 45-46: revise "…includes strategies to preserve the Delta's current rural and agricultural base, consistent with the coequal goals."
P 9 L 5: delete "implement" add "commence implementation", which is the wording of the Act.
P 10 L: add "…water supply system." The Delta is not the source of the water.
P 10 L 25: revise "Reduced Altered freshwater flows into the Delta, water pumping facilities in the southern Delta exporting water from the Delta,…." The flows are not "reduced" at all times, the water exported is not "Delta" water.
P 11 L 4: add "…consumptive use and upstream and in-Delta diversions of water…" — to provide more comprehensive specificity.
P 11 L 38-39: revise "…water supplies from conveyed through the Delta has grown at the same time the reliability of water those supplies from the Delta has been deteriorating begun to deteriorate." The water is not "from" the Delta and reliability has been deteriorating for awhile now.
P 11 L 45-47: Replace the first two sentences with the following "Assessing statewide water supply reliability is hindered by the fact that California has an unwieldy data and information gathering system that may not be asking for the right data and after receiving responses does not aggregate them in a manner useful to water managers and policy makers. For example, since 1914…." The current language wrongly implies (1) that there is some fixed end-point that rings the bell on "achieving" statewide water supply reliability, when it is a year-to-year measure in reality that is highly dependent on the variable and uncontrollable weather; and (2) some statistic related to "annual statewide water use" would "inform" statewide decisions on water supply management made by "California's water managers" – this doesn't reflect the reality of California's decentralized water system nor, as with (1), the variability of the weather which precludes "decisions" with sufficient certainty well into the water year.
P 13 L 1-2: SWRCB terminology should be modified, as noted above, "flow criteria" and "flow objectives" are not appropriate.
P 15 L 6: Repeat of comment on previous draft. What is rationale of "50 percent" reduction in "urban per capita water use"? This sentence should be deleted. The first sentence is more than adequate to make the point without pulling a number out of thin air which has no substantiation. If necessary, include something along the lines of "urban per capita water use statewide has continued to trend downward from the 20×2020 baseline."
P 15 L 18: replace "sufficient" with "appropriate" and replace "natural" with "variable". Use of "hydrograph" rather than "flow regime" is an improvement.
P 19 L 18: replace "requires" with "recommends" as the Council does not have the authority to "require" in this context.
P 33 L 14: add at the end of the sentence, "as outlined below." This is particularly useful with regard to the reference to the State of Washington which seems to come out of nowhere. In addition, perhaps a brief sentence explaining why the criteria developed by the State of Washington are appropriate would be in order.
P 34 L 10-11: The Delta Science Program should also be reviewing current research activities and recommending whether they remain pertinent and worthy of continuation or whether the resources would be better spent elsewhere in service of the coequal goals. This should be listed as an explicit task of the DSP and the ISB.
P 35 L 35: The discussion of the Delta Science Plan here at the end of the chapter makes it come across as a bit of an afterthought when it is central to the success of the Delta Plan. It seems like it should be moved up in the chapter.
P 35 L 36: add "…needed to prioritize, organize and integrate…."
P 35 L 42: add "…is to prioritize and organize Delta science activities…."
P 44 L 8 and note 7: We appreciate that on page 45 one year temporary water transfers are granted an exemption from being a "covered action". However, the correct statutory interpretation is that a project exempt from CEQA also is excluded from the definition of a covered action. In recognition of this fact, and at a minimum, instead of making CEQA exempted projects subject to "covered action" consistency determinations, the Council should review CEQA exemption categories and decide in a public forum which should not be exempted from "covered action" consistency analyses, provide the rationale for not doing so, and exempt all the other activities that are similarly exempt from CEQA. At the very least, perhaps identify such a CEQA exemption review as an early priority of the "adaptive management" approach described at page 45, lines 11-13.
P 45 L 40-41: We find the need for a certification analysis of "an action [ ] taken in conformance with another plan that has been incorporated into the Delta Plan" to be superfluous and wasteful of time, labor and financial resources of project proponents, as well as an unnecessary burden on the limited administrative capacity of the Council. If an action is part of a plan that has become part of the Delta Plan, how could it be "inconsistent" with the Delta Plan, of which it is itself a part?
P 48 L 19-22: Delete this entire paragraph. The first sentence imposes a superfluous requirement that is inconsistent with the statute. The second sentence is beyond the Council's authority. Once again, if the BDCP is incorporated into the Delta Plan consistent with the Act, then all of its activities are by definition consistent with the Delta Plan. The Council does not have the authority to burrow into the BDCP after its incorporation into the Delta Plan and pick and choose actions to "review". As an NCCP/HCP the BDCP is a comprehensive package of actions, commitments and assurances approved by the state and federal fishery agencies that cannot be cannibalized.
P 52: text prior to section 85021 citation, add "…for water supplies to meet future needs is established…."
P 52: It is section 85302(d) not (c) that sets out the Act's criteria for addressing a more reliable water supply for California.
P 53: This is an example of Council documents inappropriately and selectively quoting the Constitution. Any citation to Section 2 of Article X should always include the first sentence of Section 2 too. Add >
"It is hereby declared that because of the conditions prevailing in this State the general welfare requires that the water resources of the State be put to beneficial use to the fullest extent of which they are capable, and that the waste or unreasonable use or unreasonable method of use of water be prevented, and the conservation of such waters is to be exercised with a view to the reasonable and beneficial use thereof in the interest of the people and for the public welfare. The right to water…." The principle of "reasonable use" includes the principle of "use" not just preventing "waste", and as such the opening sentence of the Constitutional provision should be included as well.
P 55 L 33: revise "…watersheds, primarily diverting it at divert it into storage; utilize the rivers to deliver it to the Delta where it flows to pumping facilities in the south Delta…." Project water is diverted far upstream from the Delta.
P 56 Water Supply Reliability box: first line of 5th paragraph: add "decreasing the statewide per capita demand for water…." As written it seems the expectation is that a statewide aggregate water demand reduction from a present-day baseline is "necessary". This is not the case and is not consistent with Section 85302(d).
P 56 Water Supply Reliability box: first line of 7th paragraph: add "…that the amount of water available from the Delta through the delivery capabilities of the SWP and federal CVP must be made more reliable." Because the next sentence relates the first sentence to the BDCP it is appropriate to specify the SWP/CVP capability. Alternatively, the word "watershed" could be inserted after the word "Delta" in the original sentence.
P 56 Water Supply Reliability Box, second to last line: delete "reduce its water needs" and replace with "continuously improve its water use efficiency and conservation efforts, develop…"
P 57 L 9: What are "local imported deliveries"? Is that EBMUD, SFPUC and LA Aqueduct? This should specify.
P 58 L 8: Figure 4 – 2 > the pie chart showing water supplies obfuscates the role of Delta and Delta watershed supplies. These should be shown as a single slice. If shown, it would be clear that this is the single largest water supply for California.
P 59 L 4: add "…reliability of California's…."
P 60 Figure 4-4: This graphic is misleading and should be deleted. Although it is from the 2009 Water Plan, the data reflected by the individual bars on the chart were not gathered utilizing the same assumptions as to level of effort informing the "high" and "low" estimates.
P 61 L 12: The reference to $1 billion of State bond fund investment should also reference how much in local (and possibly federal) resource dollars were leveraged by those bond funds to provide a more robust picture of the level of investment that has occurred.
P 61 L 14: Delete "reduce demand" replace with "increase water use efficiency". While aggregate water use shows a decline on the chart, which reflects a reduction in agricultural water use, not urban, which is still trending slightly upward and also likely reflects drought conditions, crop shifting and fallowing of acreage. Absent an analytical basis to support it, there should be no assumption that California's future is a place where aggregate water demands will be less than today. Today's data and trends simply do not support this notion. Though agricultural acreage may be trending downward, climate change is expected to necessitate additional water applications to crops to compensate for loss of soil moisture, reduced precipitation, ambient temperature increases, etc.
P 62 L 2: add the following sentence to the end of the paragraph; "However, as in other areas that rely upon imported water, this ability to meet future demands assumes the continued delivery of those imported supplies, which are foundational to their water supply portfolios and support the ability in particular, to recycle water for additional use and store surplus water in groundwater basins for future use."
P 62 L 16: add "…reduced reliance on the Delta to meet California's future water supply needs."
P 62 L 27-30: delete "demonstrate reasonable use of existing water supplies and"; this verbiage is loaded, a term of art, and adds nothing other than controversy. This language implies support for a top-down, intrusive approach for second-guessing local decision makers and the investments they make or don't make and a one-size-fits-all mentality.
P 62 L 35-40: delete paragraphs "A" and "B". These "covered action" triggers are rife with problems of vagueness, overreach and consistency. Does "export of water" mean any movement of water by the SWP or CVP under current contracts and biological opinions? The same question applies to transfers. Such operations are certainly "routine" and excluded from "covered action" consistency review by the Delta Reform Act itself, let alone such activities are within the purview of the SWRCB and thus regulation of them is reserved to the Board exclusively by the Act. Even if such a "policy" were appropriate, what is the definition of "significantly caused by"? As written, an SWP or CVP contractor who is a wholesale agency could be charged with pursuing an "inconsistent" action based upon the deficiencies of one of its potential many member agencies, over which it has no control. These covered actions are also inconsistent and discriminatory in that they apply only to a subset of diversions (17% on average) from the watershed.
P 63 L 24: add "…dependence on the Delta to meet future water supply needs through…."
P 63 L 25-26: phrase "document actual or projected net reduction in reliance on Delta exports" is troublesome. The Council should provide an example of how they think this recommendation would be satisfied and from what baseline it would be measured. If the intent is to require a showing of meeting ordinary demands while receiving less imported supplies than under a successfully implemented BDCP, that would be inconsistent with the Act and the coequal goals.
P 63 L 28: delete "a minimum periods of".
P 64 L 5: add "…Delta to meet future water supply needs, including, but not limited…."
P 64 L 15: This discussion of "regional water balance" should explicitly clarify that a region's imported water supplies are included in the analysis. If not, most regions of the state would never succeed in bringing "the region into balance". It is the demand within the hydrologic region that is the criterion focusing the analysis, but the balance inputs are not limited to water supply solely available within that hydrologic region. The latter point needs to be clearly stated.
P 64 L 25 and 28: What does a "conservation-oriented rate structure" that "sustainably encourages and supports water conservation" mean? Moreover, are these rate structure recommendations intended to apply to wholesalers? They should not. If they are, the Council needs to provide a rationale why they should apply to wholesalers who have different financial requirements than retailers and that are at least one step removed from direct interaction with the end-user. The question of applicability also applies with regard to agricultural water districts. How would such a hypothetical rate structure be applied? Volumetrically or based on utilization of WUE technologies or…? This recommendation needs much more work. The footnoted description from Utah though helpful contains many vague terms and concepts.
P 65 L 13-16: What does WR R3 mean? From what baseline is "new or increased demand for diversions" measured? If the new point of delivery is receiving water under current contract entitlements and consistent with regulatory requirements, would that be "inconsistent" under this proposed recommendation? More clarity, specificity and examples are needed here to understand the Council's intentions.
P 65 L 19-20 and 29-30 and 35 and 37 and 42 and note 16: See previous comment about use of words such as "water flow criteria", "flow objectives and criteria", and "flow standards", etc., as inappropriate and incorrect with regard to the SWRCB's processes related to updating and implementing a Water Quality Control Plan.
P 65 L 41: revise "…flows needed to protect the Delta and its ecological resources necessary to protect public trust resources and does not include other public trust considerations." This is the statutory language, which should be the default generally rather than rewriting the language in the Act.
P 65 L 42: revise "While informing only the starting point for the broader flow-standard-setting process…." The language mischaracterizes the document. It is not a starting point; it is one assessment among a very large volume of existing reference materials. Moreover, it is caveated in both the legislation and the SWRCB's report as having no regulatory effect. As the Council acknowledges elsewhere, the report does not reflect any of the necessary balancing required of SWRCB actions, nor is it consistent with the coequal goals.
P 66 L 9 and 13: Proper SWRCB wording as opposed to "flow objectives". What is contemplated are a potentially updated WQCP for the Delta and "studies" for the tributaries.
P 66 L 9-14: Replace this entire "Problem Statement" with the following – "Until the SWRCB completes its review and potential update of the Water Quality Control Plan for the Bay-Delta, and carries out studies of high-priority tributaries called for by the Delta Reform Act, a high level of uncertainty will continue to stymie efforts to improve the reliability of the State's Delta watershed dependent water supplies." The current language misstates the activities of the SWRCB and implies a legal Armageddon based upon a misunderstanding of water rights and water rights law. In fact, as recent history has shown, everything is already subject to potential litigation. Whether it matters or not, or is valid or not, are different questions and questions of no real concern to the Delta Plan.
P 66 L 16: This is very un-reader-friendly. There is no reason not to simply put the text of ER P1 here too, even though it technically is "from" Chapter 5.
P 66 L 18: delete "network of".
P 66 L 26: add "…Delta's native fisheries…."
P 66 L 32-35: Here the council asserts it has the authority to "approve proposed conveyance improvements." That is patently untrue. The Council must include the BDCP in the Delta Plan if DFG makes the determinations required in Section 85320(e). The Council does have the authority on appeal to review DFG's decision, but it may not substitute its judgment in place of DFG's; so long as DFG's decision is supported by a preponderance of evidence the Council must uphold that decision and include the BDCP in the Plan. Even if the Council can legitimately determine that DFG's decision is not supported by the evidence, its authority is limited to not including the BDCP in the Plan. While a Council decision that BDCP will not be included in the Plan will have significant implications for the BDCP, that is the limit of the Council's authority and it specifically has no regulatory authority to "approve" conveyance improvements.
P 66 L 39-40: add "…greater water supply reliability, recover export capability through…." BDCP is not just about reliability, it is also intended to recover, pursuant to an NCCP/HCP, export capability lost to previous and current regulatory constraints.
P 67 L 6-7: revise "…export at times of surplus when this water can could otherwise be diverted."
P 67 L 8: add "…through local water supplies and previously delivered export supplies, and storage…." As written, the text implies local supplies met all demands, which is obviously not the case.
P 67 L 9: revise "…delivery of the available surplus water."
P 67 L 14: revise "…water storage from now provided by the Sierra snowpack."
P 67 L 33: add "…additional surface storage has been…."
P 68 L 7: revise "…so that more stormwater water runoff could be captured…."
P 69 L 9: revise "…that can be accomplished most quickly within the next 5 to 10 years." 5-10 years is pretty optimistic for most storage projects, even local ones.
P 70 L 2: add "…provides for roughly…."
P 70 L 20: revise "…problems have forced resulted in the adjudication of some groundwater basins…."
P 70 L 32: delete "voluntary"
P 71 L 3: add "…number of adopted plans…."
P 72 L 18: revise "…caused by droughts or and will be critical in the event of a catastrophic failure…."
P 73 L 10-12: Delete second clause of first sentence because it is wrong and inconsistent with rest of section, including lines 32-34. Revise to read "…improving water supply reliability, California has limited information on which to base sound water management decisions. The the State's information infrastructure…." This still makes the valid point.
P 73 L 15-17: Delete sentence starting with "For example". This is a red herring and "information" that is not worth pursuing generally. In addition, water can't be "over-allocated" because the water rights system prevents that from occurring among legal diverters of water. The better statement might be something along the lines of real-time diversion data would be beneficial to get a better handle on what's actually happening at any given time pursuant to all those permits the Board issued.
P 73 L 19-23: Delete this sentence as it only adds to the document if one misinterprets the results of the satellite study. The study did not show "overdraft", it showed changes in gravity which was translated to the removal of water from groundwater basins, which is here equated with "overdraft." The chain of argument does not hold. This "study" was based on only 3 data points in the Central Valley. USGS data regarding subsidence is much more probative. If anything, this satellite data illustrates the critical importance of groundwater to sustain water supplies in the Central Valley. If it must stay, at least make it a separate paragraph so it doesn't contaminate the prior discussion regarding data gaps.
P 73 L 30: revise "…investigate and enforce terminate illegal diversions…."
P 74 L 38-41: delete WR R10. This has the same problems as "policy A" on page 62.
P 75 L 17.5: add "Consistent with legislative direction to incorporate the Bay Delta Conservation Plan (BDCP) into the Delta Plan pursuant to section 85320 of the Act, the Council has determined that the baseline for measuring progress toward reducing reliance on the Delta to meet California's future water supply needs relative to SWP and CVP export levels will be established by their operations and long-term average deliveries in compliance with state and federal regulatory standards and requirements applicable upon initiation of operation of new Delta conveyance facilities included as part of the BDCP."
P 75 L 18: add "Improved water supply reliability baselines should be…."
P 75 L 28: revise "Water Supply Reliability Elements" This language is consistent with the language on page 63.
P 75 L 35: This repeats the misstatement of SWRCB activity. The Board will not be able to "implement" an updated WQCP at the same time it "adopts" the potentially revised plan. The term "flow objectives" is incorrect. Moreover, the Act does not require "adoption" of "flow objectives" for the major tributary streams, it directs that "studies" be completed by then.
P 76 L 16-17: delete this bullet. The "policy" it is "measuring" is flawed, as commented upon above.
P 76 L 19: add "…reduction in statewide urban…."
P 76 L 24-25: As on page 63, L 25, the language regarding reporting of "actual or projected reduced reliance" is opaque and needs additional clarification.
P 83 L 23: delete "naturally"
P 83 L 25-26: add "…adapt to them in a manner that does not impair the achievement of the coequal goals." As written it seems like reduction of stressor impacts is not a focus and adaptation could occur but to the detriment of native species – as is much the case today.
P 84 L 10: revise "the natural a more variable flow regime" per comments above.
P 84 L 34: revise "…crop production, and altering their hydrology by diverting water above and within the Delta for use within and outside the watershed to the southern parts of the state." It is inappropriate to only cite southern California as the beneficiary of diversions in or from the watershed.
P 86 L 42: revise "a more natural variable flow regime" per previous comments about inappropriateness of this terminology.
P 87 L 2: revise "Creating a More Natural Variable Flow Regime" ditto.
P 87 L 3-4: revise "…reflecting historical flow patterns and variability conditions are best for…."
P 87 L 16: revise "…for setting flow criteria determining desirable flows at critical times for improving ecosystem function."
P 87 L 17: revise "More flow variability during specific periods is natural flows are important to migratory cues of many fish species."
P 87 L 20: revise "…a more variable natural flow regime in the Delta…."
P 88 L 8-18: revise this language to get what the Board is actually doing and its appropriate terminology, which is not "flow criteria and objectives".
P 88 L 16-22: delete both of these examples as they represent significant overreach of the Council's actual authority, as well as being facially inconsistent with the Act's reservation of all regulatory authority related to water rights to the SWRCB.
P 89 L 3: delete "…Plan objectives and establish flows as follows:"
P 89 L 4-7: revise this language to reflect the proper terminology. The Board cannot "implement" a revised WQCP by the date included here. With regard to tributaries, the Act only directs that "studies" be completed, not that standards be adopted. The bullets should be identified as "(a)" and "(b)" to be consistent with reference to them on Page 88, L 12.
P 93 L 9: revise "…how more natural variable flows…."
P 93 L 22-25: ER R4 is the same as ER P4?
P 95 L 38: revise "BDCP is expected to contribute significantly to furthering the achievement of affect the Delta Reform Act's coequal goals."
P 97 L 4: delete "…Act and no later…."
P 98 L 13: The Board cannot "implement" on this timeline. Also, "flow objectives" is wrong terminology. The WQCP includes "water quality objectives".
P 98 L 33: revise "…more variable natural net flow patterns to support…."
P 106 L 1-4: revise "…establish water quality objectives that will be partially for which implementation is best achieved through assigning responsibilities to water-right holders and water users. This is because the water quality parameters to be controlled are significantly affected by flows and diversions; these current responsibilities were established in Water Rights Decision 1641."
P 106 L 6: add to end of paragraph "However, consistent with judicial interpretations of Article X, Section 2 of the California Constitution, dilution cannot be the solution to pollution."
P 107 L 9-10: revise "…encourages the completion timely implementation of the elements of the California Water Board's 2010…." These reports are completed already. Also, aren't these reports of the SWRCB and not of the RWQCBs – so why are they included in line 12?
P 108 L 21: add "…in the watershed and the tidal cycle."
P 108 L 29: revise "…and presently serves as a water quality standard regulating to regulate Delta outflow at certain times." The X2 standard is under review at this time and may not be carried forward, and it does not regulate outflow year-round.
P 108 L 33-34: delete this final sentence. This conclusion is controversial in that there has not been a determination that there is a "population level" correlation to the position of X2. Furthermore, during the SWRCB hearings during the development of its public trust resources flow criteria, the Board's science panel indicated there was a question as to whether the location of X2 in relation to the distance to the Golden Gate was significant or whether what really mattered was where was the preferable habitat for smelt (geomorphological, turbidity, vegetation, food supply, etc.) and its correlation with X2 rather than simply moving it west.
P 109 L 4-6: revise "…freshwater environment year-round primarily for in-Delta water supply and export for beneficial uses purposes under current water project operations. It has been hypothesized that allowing more seasonal and interannual salinity variability more in keeping with natural flows will benefit native species."
P 109 L 8-9: revise "…and introduced aquatic plants, and introduced fish and other species such as Asian claim, largemouth bass…."
P 109 L 10: revise "…also hypothesized to be important a controlling factor for populations…."
P 109 L 17: revise "…particularly in from the San…."
P 109 L 21: add "…higher salt concentration than the original supply water."
P 110 L 22: add "…and municipal uses without new conveyance infrastructure investments."
P 110 L 29: revise "Water conveyed through the The Delta is used…Californians. It The Delta is also…."
P 112 L 19: add "…all recipient regions within the Central Valley that are…." As written agencies outside the Delta watershed would be required to participate in CV-SALTS. Was that the intent?
P 113 L 15-18: delete the sentence beginning "This conclusion" as it is over the top and there are similarly strong "challenges" to material regarding "X2" for example. Add "However" at beginning of sentence beginning "Food web effects".
P 120 L 18: The Board will not "implement" on this timeline and "flow objectives" is the wrong terminology.
P 120 L 30: insert space between "5" and "years".
P 120 L 33: delete "interannual".
P 133 L 7: replace "a historically" with "an historically".
P 136 L 23: add "…provided they mitigate any, or do not, decrease…."
P 140 L 32-33: The Act directs that the Council "shall recommend in the Delta Plan priorities for state investments" in levees. This is a deficiency that needs work by the Council, "in consultation with" the CVFPB, rather than deferring the subject. The general framework is a start, but it does not represent a "strategic levee investment plan" which is supposed to be part of the Delta Plan.
P 140 L 34: The $250M figure seems too small considering the present draft of the DPC's ESP shows a table referencing $238M in levee spending since 1989. Certainly more than $12M was spent between the "early 1970s" and 1989.
P 143 L 38: replace "system" with "capability".
P 145 L 2: replace "the" with "that".
P 146 L 10: delete "…relating to levees conditions…."
P 146 L 12: revise "…on a local basis to better serve for Delta and state interests."
P 146 L 36: add "…for the regional and state benefit of all beneficiaries…."
P 147 L 2: add "…levees to help protect water quality."
P 147 L 35: replace "support" with "counteract".
P 147 L 37.5: There should be a "Policies" heading and "no policies" language added for consistency.
P 150 L 10: add "after review for consistency with the coequal goals and Delta Plan by the Council" to the end of the sentence.
P 155 L 21: insert a space between "above" and "ground".
P 157 L 37: replace "removes" with "remove".
P 163 L 2: Why include a performance measure that is to occur 6 months prior to adoption of the Delta Plan? This should be deleted.
P 163 L 3: Although legislation has been introduced, is the January 1, 2012 date realistic?
P 163 L 13-14: add "…will be maintained at sustainable levels in the future." It is inappropriate to have a performance measure that contemplates no impact to agricultural receipts.
P 163 L 21-22: delete this bullet as it is repetitive to the first and also includes a commitment to maintaining a status quo condition rather than working to make the Delta's evolution a net positive.
P 163 L 24-25: Does this measure envision habitat creation as a "conversion" from "open space"? If not, this bullet should be rewritten to clearly say so. If so, the second sentence of the bullet should be deleted.
P 169 L 15-16: The editorial assumption regarding the "likelihood of getting voter approval" should be deleted.
P 170 L 5: add "…into the Delta Plan pursuant to the requirements of the Act."
P 170 L 12: replace "by this date" with "by January 1, 2014".
P 170 L 18: replace "flood risks" with "levee failure".
P 170 L 19: the funding is not needed so much for mitigation commitments, which are paid for by the project contractors, but for ecosystem investments and habitat creation that are not related to specific mitigation requirements but which are targeted at restoration as a state interest benefit?
P 170 L 26: What is the basis of the $27 million per year figure? That should be explained, at least in a footnote.
P 170 L 32-35: What is the basis of the $50 million per year figure? In addition to the Science Program and ISB ($27M) and the Conservancy ($10M – which is assumed to include land purchase costs), what is the basis of the $13M in administrative costs for the Council and the Commission? These figures seem high and should be explained, at least in the footnote.
P 170 L 44-45: add "…funding once the BDCP funding plan is completed."
P 172 L 30: What is the basis of the $10M for development of a plan? Seems quite high.
P 173 L 12-26: delete this entire "User Fees" section. Any user fee development will require significant stakeholder involvement, hashing out of numerous details, etc. Simply dropping such a proposal into the Delta Plan is a disservice and a distraction that is not necessary at this time.
P 174 L 2-9: delete this entire "Public Goods Charge" section. Energy and water do no equate in this context. This also seems to be on top of the fee authority the Council seeks to generate an additional $50M/year, which is already overkill. As with the "user fees" proposal, the proposal of a "public goods charge" is a disservice and distraction to the pursuit of the Delta Plan.
P 174 L 11: The prioritization of state investments in levees is something that the Council is charged to include in the Delta Plan itself after "consulting" with the Central Valley Flood Protection Board (see Delta Reform Act § 85306). At the very least the "due date" is far too remote and should be moved to January 2013 if the Council is not going to fulfill its obligation under the Act.
Appendix A –
General: Appendix A presents an exceedingly convoluted rationale to support an apparent assertion that the Council has the authority:
• "to approve proposed conveyance improvements"
• "to dictate" the terms of the BDCP
• "to regulate conveyance improvements"; and
• "to include regulatory Policies regarding conveyance"
Each of these assertions is patently untrue. There is nothing in the statute that could be read to allow the Council to "dictate," "approve," or "regulate" conveyance or any portion of the BDCP. The Council must include the BDCP in the Delta Plan if DFG makes the determinations required in Section 85320(e). The Council does have the authority on appeal to review DFG's decision, but it may not substitute its judgment in place of DFG's; so long as DFG's decision is supported by a preponderance of the evidence the Council must uphold that decision and include the BDCP in the Plan. Even if the Council can legitimately determine that DFG's decision is not supported by the evidence, its authority is limited to not including the BDCP in the Plan. While a Council decision that BDCP will not be included in the Plan will have significant implications for the BDCP, that is the limit of the Council's authority. More specifically, the Council's apparent assertion of authority to dictate or regulate the outcome of the BDCP has no basis in law.
The "Regulatory Authority over Conveyance" section of the Appendix must be deleted in its entirety, or completely rewritten to correctly describe the authority the Council does have with respect to the BDCP and actions included within it. That is, the authority to entertain an appeal of DFG's decisions under Section 85320(e) in a manner that does not affect DFG's existing authority (Sections 85032(a) & 85322) or substitute the Council's judgment for that of DFG. If, within those statutory constraints, the Council legitimately can support a finding that DFG has not met the requirements of Section 85320(e) it shall decline to incorporate the BDCP into the Plan. Its role and authority with respect to the BDCP ends there.
P 3 L 21: replace "dictate" with "recommend".
P 3 Note 4: delete "…if and when it was"
P 4 L 14-18: formatting of font seems off by a size or two too big.
P 4 L 31: delete the last sentence as it doesn't add anything and is actually confusing since there's no identified "policy" that is "following".
Appendix B –
P 7 Paragraph 23: We reiterate our objection to the standard of review included in this paragraph.


Stay up-to-date with family law and divorce news, tips and guides by Cindy Best.
Brad and Angelina and Jackie O.
How To Get A Divorce? What Is Your Road Map?
Why Shouldn't My Spouse Pay Me Forever?
Family Law Mediation Instead Of Litigation And Why It Works.


We have been visiting the Carillon cellars in Puligny for many, many years, and this is Undeniably one of the very best domaines in the village. These are classic, 'grown-up' burgundies, exhibiting all that is best about Puligny. Not a great deal of wine here in 2015, so early action recommended!
Bucking the trend of the vintage, Jacques's Puligny needs time in bottle to blossom fully - tasting at this stage it is quite restrained, but the underlying poise and class is evident. Typically weightier and more intense than many other from the village, Carillon's village is quickly becoming the yardstick by which others are measured. Very good indeed.


text:
This is "General Perspectives on Illegality", section 12.1 from the book Legal Basics for Entrepreneurs (v. 1.0). For details on it (including licensing), click here.
12.1 General Perspectives on Illegality
Understand why courts refuse to enforce illegal agreements.
Recognize the rationale behind exceptions to the rule.
We have discussed the requirements of mutual assent, real assent, and consideration. We now turn to the fourth of the five requirements for a valid contract: the legality of the underlying bargain. The basic rule is that courts will not enforce an illegal bargain. (The term illegal bargain is better than illegal contract because a contract is by definition a legal agreement, but the latter terminology prevails in common usage.) Why should this be? Why should the courts refuse to honor contracts made privately by people who presumably know what they are doing—for example, a wager on the World Series or a championship fight? Two reasons are usually given. One is that refusal to enforce helps discourage unlawful behavior; the other is that honoring such contracts would demean the judiciary. Are these reasons valid? Yes and no, in the opinion of one contracts scholar:
[D]enying relief to parties who have engaged in an illegal transaction…helps to effectuate the public policy involved by discouraging the conduct that is disapproved. Mere denial of contractual and quasi-contractual remedy [however] rarely has a substantial effect in discouraging illegal conduct. A man who is hired to perform a murder is not in the least deterred by the fact that the courts are not open to him to collect his fee. Such a man has other methods of enforcement, and they are in fact more effective than legal process. The same is true in varying degrees where less heinous forms of illegal conduct are involved. Even in the matter of usury it was found that mere denial of enforcement was of little value in the effort to eliminate the loan shark. And restraints of trade were not curbed to an appreciable extent until contracts in restraint of trade were made criminal.
In most instances, then, the protection of the good name of the judicial institution must provide the principal reason for the denial of a remedy to one who has trafficked in the forbidden. This is, moreover, a very good reason. The first duty of an institution is to preserve itself, and if the courts to any appreciable extent busied themselves with "justice among thieves," the community…would be shocked and the courts would be brought into disrepute.Harold C. Havighurst, review of Corbin on Contracts, by Arthur L. Corbin, Yale Law Journal 61 (1952): 1143, 1144–45.
Strictly enforced, the rule prohibiting courts from ordering the parties to honor illegal contracts is harsh. It means that a promisee who has already performed under the contract can neither obtain performance of the act for which he bargained nor recover the money he paid or the value of the performance he made. The court will simply leave the parties where it finds them, meaning that one of the parties will have received an uncompensated benefit.
Not surprisingly, the severity of the rule against enforcement has led courts to seek ways to moderate its impact, chiefly by modifying it according to the principle of restitutionThe return or restoration of some specific thing to its rightful owner or status.. In general, restitution requires that one who has conferred a benefit or suffered a loss should not unfairly be denied compensation.
Pursuing this notion, the courts have created several exceptions to the general rule. Thus a party who is excusably ignorant that his promise violates public policy and a party who is not equally in the wrong may recover. Likewise, when a party "would otherwise suffer a forfeiture that is disproportionate in relation to the contravention of public policy involved," restitution will be allowed.Restatement (Second) of Contracts, Section 197(b). Other exceptions exist when the party seeking restitution withdraws from the transaction contemplated in the contract before the illegal purpose has been carried out and when "allowing the claim would put an end to a continuing situation that is contrary to the public interest."Restatement (Second) of Contracts, Section 197(b). An example of the latter situation occurs when two bettors place money in the hands of a stakeholder. If the wager is unlawful, the loser of the bet has the right to recover his money from the stakeholder before it is paid out to the winner.
Though by and large courts enforce contracts without considering the worth or merits of the bargain they incorporate, freedom of contract can conflict with other public policies. Tensions arise between the desire to let people pursue their own ends and the belief that certain kinds of conduct should not be encouraged. Thus a patient may agree to be treated by an herbalist, but state laws prohibit medical care except by licensed physicians. Law and public policies against usury, gambling, obstructing justice, bribery, corrupt influence, perjury, restraint of trade, impairment of domestic relations, and fraud all significantly affect the authority and willingness of courts to enforce contracts.
In this chapter, we will consider two types of illegality: (1) that which results from a bargain that violates a statute and (2) that which the courts deem contrary to public policy, even though not expressly set forth in statutes.
Courts refuse to enforce illegal bargains notwithstanding the basic concept of freedom to contract because they do not wish to reward illegal behavior or sully themselves with adjudication of that which is forbidden to undertake. However, fairness sometimes compels courts to make exceptions.
Why is illegal contract a contradiction in terms?
Why do courts refuse to enforce contracts (or bargains) made by competent adults if the contracts harm no third party but are illegal?

redpajama_set_name: RedPajamaCommonCrawl


text:
Paklobutrazol är en triazol fungicid som främst används som tillväxtreglerande substans för krukväxter i växthusodling. Paklobutrazol fungerar som antagonist till växthormonet gibberellin, genom att hindra dess biosyntes. Genom att hindra krukväxtens tillväxt, så får man kortare och kraftigare plantor, som också blommar och sätter frukt tidigare.

Paklobutrazol kan appliceras på växter, men störst effekt får man om växten tar upp den via rötterna. I Sverige rekommenderar kemikalieinspektionen att jord som behandlats med Paklobutrazol inte skall komposteras, eftersom det bryts ned långsamt och kan ha negativa effekter på andra växter, t.ex. på grönsaker. Paklobutrazol anses inte vara farligt för miljö och hälsa .

Referenser

Externa länkar
http://sverigesradio.se/sida/artikel.aspx?programid=406&artikel=6702836
Fungicider
Triazoler

redpajama_set_name: RedPajamaWikipedia


Why should you take great care in building a website?
A business website is like the reception wing of a luxurious hotel; it automatically shapes the opinion of guests about the quality of services they should expect. Of course, there might be a disconnection between their assumptions and what is actually obtainable, but it is common knowledge that first impressions matter a lot and in business, the first impression has to be excellent to guarantee a second impression.
An organization's website is its main gateway to reach its target audience and so the construct of your business website goes a long way in determining business patronage which is a critical factor for every business.
Simply put, a tacky and poorly designed website would not inspire confidence in prospective clients and would likely deter people from pursuing further business ties with a business outfit.
With this in mind, it is imperative that in creating a business website, adequate care should be taken by the entrepreneur to ensure that the end result is standard and would have the potentials to project the business outfit as both professional and capable of delivering excellent products and services to its customers.
Not every entrepreneur possesses the technological acumen to create a website. Even where there is an availability of the technical know-how, scarcity of funds might be a limiting factor to small business owners who desire to build websites for their businesses.
These online tools come with basic designs and you can add your own domain name for extra fees. So, don't expect too much in terms of customizations and professional optimization. On the other hand, you can choose a professional and premium service like InMotion Hosting that offers more options, tools, and of course a customer support by phone and more.
The company offers an installer software for popular open source applications like WordPress and even eCommerce tools like PrestaShop and others.
The following tips if adhered to would lead to the creation of an excellent website.
In creating a website for any company, it has to be done with the overriding goal in mind.
If you want the website as a portal for your customers to acquire your products, then you have to build the website with this objective in mind.
Also, if you wish to provide information that would lure potential clients to you, the goal must be well defined and it's important to keep things simple.
Creating a website without a clearly defined purpose would only lead to a waste of time and resources.
You should decide what you want your website to say about your business before you initiate the process of building it.
Being the owner of the website, the onus lies on you to spearhead the content creation for your website even if you intend hiring someone else to edit or beef it up. This is because as the entrepreneur, you have a superior knowledge of the basic message of your company more than anyone else.
In writing your website content, you must state your purpose clearly and quickly. Website visitors would be disgruntled if they have to spend a lot of time reading through pages of content in search of important points about your business or the products or services you are offering.
Most business websites have at least a few different pages. You might choose to create different pages for the different services you provide with the main page that gives a general overview.
You might also consider going with the simple format of having a Homepage, About page and Contact page. It is imperative to decide on this before you start building your website.
If you are undecided about how you want your website to look, you could take a look at websites you really like. Do not copy them though; but by studying them, you could gain new ideas about what you would want for your new site.
As a matter of expediency, all businesses should purchase an actual domain name. Some providers offer free ones that come with the likelihood of extensions. But owning your domain makes your website look more professional and makes it easier for people to remember your web address. Take a look at these professional and biggest domain name registrars.
Several hosting platforms are available today. You should study the existing hosting platforms and select the one that best suits the needs of your particular website. It's a great idea to choose a hosting that offers fast servers, free domain and a high level of security and support.
If you plan on hiring someone to create a website for your business, and then choose a designer whose works fit the style of your business, the best way to go about doing this is to look at one of the websites you admire and hire the person responsible for designing it. We found Afarek the best options for building professional and premium quality websites for small businesses.
Using free themes for your website is not advisable because often times they are not as secure as the purchased ones. An inexpensive investment in a good theme would keep your business website secure. Instead, use of these trusted theme marketplaces with professional designs and clean code.
Your business website should include your business contact information. This can either be phone numbers, address, email address, social media accounts or all of the above. If you provide people with adequate means of contacting you, then it is more likely that they are going to feel more comfortable reaching out to you.
Whether you are just choosing a template or working with a designer, you have to keep your design elements simple. Do not be too adventurous with different design elements. Abide with a few colors or textures and avoid adding too many fonts or type sizes.
Images go a long way in adding interest to your business website. You could include relevant images like team pictures, examples of your products or services etc.
Regardless of what type of content you decide to include in your business website, ensure that the site is mobile friendly. Operating a website that is not mobile optimized can drive away your customers, hurt your search engine optimization and make your website look unprofessional.
Conclusively, it is important to keep things simple and ensure you don't get stuck trying to achieve that perfect outlook for your website. Most businesses make upgrades as it becomes required and kick starting the process of getting your first business website should be your objective, so start today!


1 YRS Guangzhou Chuangyuan Plastic Products Co., Ltd.
Our adhesive has better performance in initial tack, holding tack, anti-aging. Our adhesive has better performance in initial tack, holding tack, anti-aging. There will be more paper ash during the printing with poor coating material on face paper, which will lead to bad printing effect.
For ADHESIVE STICKER prices depend on the customer requirement, so please kindly provide detailed information, such as size, material, printed logo,order quantity detail to us so that I can quote you accurately. Product Detail -Silver Adhesive Sticker Item: China supplies transparent pvc vinyl sticker/clear pvc sticker label Technics: Hot transfer printing, Screen printing, Product Type: Transparent Adhesive Label Stickers Material: Adhesive paper, Adhesive glossy paper, PVC,PET,BOPP,Silver polyester etc Size/Designs: Customized size and design & as your require Color: Pantone color, CMYK/ We can print anything as your require Artwork Format: Adobe lllustrator/PDF/Coredraw/high dpi JPG(over 300dpi) Feature: Eco-friendly, waterproof, Oil-proof, Heat-resistant,etc Useage: Widely used on Garment, Bags, Shoes, hat, etc . Barcode & UPC for Hangtag, print to export carton all of products Logo/Design: Customer Logo / OEM & ODM is welcome Keyworkds: Sticker,Plastic Sticker, Transparent Label, Barcode sticker, UPC label, Hangtag sticker, PVC Pet, etc Order process: Inquiry&quote-> Proforma Invoice-> Payment confirmation-> Layout for approval->Printing-> Pay the balance-> Shipment Sample: Free (Based on your order quantity) MOQ: Small orders are accepted Payment Terms: T/T, Paypal, Western UNION, Alipay Lead Time: Fast delivery (3-5 days after the layout cfmed) Ship way: By DHL,FedEX, UPS,TNT or as your demand Package: On roll, Folded package,sheet or individual sheet(According to your request) Quality control: We take great care 100%inspection in the quality of our products.
2 YRS Shishi City Zhaotai Plastic Products Co., Ltd.
item name silicone rubber label material silicone, pet, pvc, silicone, ops ,vinyl ect. and we have been in this field for over five years.
etc How to order: 1) Email or send your artwork to us,we have to get the size, colors,quantity. 2) We give you the unit price; 3) you side pay the down payment,we start to produce. 5) After getting the payment,we will send out the goods as soon as possible.
Backing Plain backing, iron on backing, self adhesive tape backing Cut cold cut/ heat cut /laser cut/ ultrasonic cut Used widely used for garments,shoes,hats,crafts,toys,scarf,towel,bed blankets and Jeans Loom Type Needle Loom,Shuttle Loom,Broad Loom Label Quality White Taffeta,Black Taffeta,Red Taffeta,Full. Dull White Taffeta,White Satin,Black etc MOQ 1000pcs More Woven Label Products Details Show Products Useges More Products we specialized in Garment accessories: woven label, hang tags, stickers, webbing, plastic tag, woven patch, badges and so on as well as 15 years. It is a hightech enterprise which integrates R&D, manufacturing ,sales and marketing with its own professional team,w hich is a decade of experience, we specialize in producing all kinds of woven label,hang tag,webbing,packing box, silk screen printed label,embroidery badge,woven patch,shopping bag,plastic tag,leather patch,zipper puller,ribbon,PVC label,sticker,rubber etc.
2 YRS Chengdu Up Digital Label Technology Co., Ltd.
Alibaba.com offers 14,030 black label transparent products. About 18% of these are bottles, 3% are packaging labels, and 1% are garment labels.
A wide variety of black label transparent options are available to you, such as paper, pet, and metal. You can also choose from waterproof, heat sensitive, and barcode. As well as from custom sticker, shipping labels, and bottled beverage. And whether black label transparent is ce / eu, fda, or gmp.
There are 14,030 black label transparent suppliers, mainly located in Asia. The top supplying country is China (Mainland), which supply 100% of black label transparent respectively.
Black label transparent products are most popular in North America, Western Europe, and South America.
You can ensure product safety by selecting from certified suppliers, including 1,565 with Other, 1,284 with ISO9001, and 239 with GMP certification.


text:
By Denis Pombriant
January 3, 2013 5:00 AM PT
A lot happened while you weren't looking. A stream of articles in December, especially, the week between the holidays, seemed to tie up some of 2012's loose ends and some point to significant changes in the years ahead. They also highlight the difference between hardware and software.
In software, we've been lulled into the belief that things change pretty much instantly. Although change can be rapid in the world of people and things, it still takes some modicum of time. So here are some of the things I saw that might end up rocking our world in the year ahead.
Toyota reached a deal in federal court in the inadvertent acceleration case. You might recall that later model Toyota cars got a black eye when a spate of inexplicable accidents caused by acceleration from unknown causes hit the news. People died when some cars ran off at high speeds with drivers unable to control them. People wanted answers and a big effort went into isolating the problem. Even NASA was involved in working through the source code governing onboard computers.
Nothing was found, and finally a decidedly low-tech answer came into focus. The floor mats in some cars got wedged up against the gas pedals, causing cars to take off. It was an answer and a solution to the problem that many people had a hard time believing, but apparently was true.
A Dec. 29 story in The New York Times reported a preliminary approval by a federal judge of a US$1 billion-plus settlement. I give kudos to Toyota for keeping its calm during the crisis, working to get to root causes and in doing so putting the customer first despite the public anger. Call it customer experience 101.
Apple Impact
There were two stories about Apple that put new spin on some old issues. The first involves treatment of Apple and other assembly line workers in China. Early in 2012, reports of tough working conditions at Apple's primary assembly partner, Foxconn, tarnished Apple's reputation.
In a company as big as Apple, or any successful tech manufacturer for that matter, this is not a problem with an easy fix. There are many factories, thousands of workers and many, many processes — though some basic issues like work hours, conditions, pay and the like seem pretty systemic.
Apple put together a commission of executives and brought in outside help to identify the problems and suggest and implement solutions. The result has been better conditions, reduced hours and soon elimination of mandatory overtime beyond a certain point. Importantly, the solutions also result in significant pay increases so that people deprived of overtime can still make a week's pay.
Start of a Trend?
This is still a moving target, and everything is not settled, but Apple is such a big player in the industry that experts are already talking about how the rest of the industry will have to follow suit. Some are even comparing this to Henry Ford's decision to pay his factory workers a dollar an hour.
At the time, it was a princely sum to be paid, but it enabled workers to afford the products they made. It had a ripple effect on the whole economy and was a key driver that ultimately resulted in the expanding American middle class.
What's the CRM takeaway? Try this: Handheld devices and tablets have become the global standard computing devices, and they are the last link in a chain that starts with cloud computing, social media and analytics that is driving global uptake of computing and every benefit it delivers. The impact on all of us can be speculated over but in the end, the results will dwarf our imaginations.
Finally, the other Apple story also involves HP and many other hardware makers that have globalized production by sending it to the Far East. In another story, we're seeing indications that some manufacturing is coming back to the U.S. and other countries not necessarily known for low wages.
Good News and Otherwise
I see this as both good and not-so-good news. Yes, jobs are coming back to the U.S. but the production is for older PCs and laptops, which according to the research we started seeing in 2011, are beginning to sunset. The demand for these devices is still in the hundreds of millions but demand is not growing fast if at all, and that's the point. The production coming back to these shores is for other reasons like shipping and proximity to customers.
Shipping is becoming more costly with the rise of fuel prices, so the less you do, the better. In addition, devices have fewer options right now, so it's easier to make a commodity device overseas and as long as the supply lines are full, shipping is not a big issue. Configuring more complex PCs for special customer needs has lead time associated with it, so taking shipping time out of the equation gives more time to be more customer-centric.
So if you're scoring this at home, call it a draw. Some manufacturing is coming back and what's staying put is probably not the kind of manufacturing that would interest many Americans. This might be another sign of the maturation of the whole tech sector.
As a CRM topic, more devices in more people's hands makes us all more social, networked, connected and in the moment. That's how we're starting the year.
Denis Pombriant is the managing principal of the Beagle Research Group, a CRM market research firm and consultancy. Pombriant's research concentrates on evolving product ideas and emerging companies in the sales, marketing and call center disciplines. His research is freely distributed through a blog and website. He is the author of Hello, Ladies! Dispatches from the Social CRM Frontier and can be reached at [email protected].
More by Denis Pombriant
LG Ships a Big, Bright OLED That Makes Flat-Screens Look Fat
Thieves Knock Off Apple Store in Paris
Tech Real Estate Grab Headed to a Small Town Near You
More Platform Tools
The Great Re…tirement
Dreamforce NYC Was Un-CRM-Like and That's Okay
This Year in CRM
The Great Sales Methodology Debate, Solved
The Dilithium Crystals Might Be Melting
Zoho's Surround Strategy
Fixing Customer Service Will Require Better Tech


A country loves a secret. Whether it's a recipe handed down for generations or a production method that has stood the test of time, its origin country will be proud to say that they can firmly stamp their name alongside that brand. One such name is Davna. A Polish vodka that created from old-time recipes and causing a stir with rival brands, especially a certain bison grass vodka. So what is Davna, and more importantly, how can I say such a thing to rival established names?
Interesting, especially to a man who loves the traditionalism of spirits and drinks. But how does it re-create these 'traditional' recipes?
The bizon grass is the favoured food of Poland's bison which roam the last primeval forest in Europe. Picked in early summer, the bison grass, or Hierochloe Odorata grass, is harvested in early summer within the Bialowieza forest in Eastern Poland. The grass is harvested in full bloom then dried naturally. The dried grass is spread on screens and then gently heated and washed over with high strength alcohol for several days to 'draw' out the aromatic essence. It's Czeri (cherry) flavour, the other in its portfolio, uses freshly hand-picked cherries from a Polish orchard in East and South Poland and then macerated for two weeks in top quality vodka. It is then rested for a full year in oak barrels before blending with natural extracts from cinnamon, almonds, cloves and vanilla. After this, it's rested for a further seven days then filtered and bottled.
Soft herbs and light almonds on the nose, with the herbs coming through more dominant on the palate. A little sharp near the finish with a fresh 'grassy' flavour that lingers on a dry end.
Soft cherry on the nose with a slight cinnamon aroma. A slight spice hit on the palate to begin with the cherry just overpowering it as it develops. Rather short but warming.
Not bad on its own, and ones that can go simply with apple juice (Bizon) and coca cola (Czeri). Worth asking for if you ever came across it within your favourite bar, or indeed your own drinks cabinet.
Check out the rest of the photos, taken at Epernay, via my Facebook page.


Designed by Tomá Brousil in 2011. Published by Suitcase as part of the Tabac Super Family.
Tabac Mono supports up to 81 different languages such as Spanish, English, Portuguese, German, French, Turkish, Italian, Polish, Kurdish (Latin), Romanian, Dutch, Hungarian, Czech, Serbian (Latin), Kazakh (Latin), Swedish, Belarusian (Latin), Croatian, Finnish, Slovak, Danish, Lithuanian, Latvian, Slovenian, Irish, Estonian, Basque, Luxembourgian, and Icelandic in Latin and other scripts.


This system contains the following elements: PIC18F4620 microcontroller, GSM modem , Ethernet controller, RTC board, digital thermometer and a LCD.
It has several built-in options for establishing a connection to the remote data center such as: Ethernet , cellular modem ( GSM /GPRS and CDMA), and analog dial-up .
• Use the simple communication wizard for hassle free working with modems , Ethernet , GSM , etc.
Multitech employs a universal socket into which conventional, GSM wireless or Ethernet modems can be connected without changes to surrounding hardware.
Radio controllers exist, as to cell / GSM modems , wireless Ethernet and plenty of other technologies.
RJ45( Ethernet ) GSM /GPRS Modem Pool .


Download Elektrik Mistress MP3 via new freeware audio player - Ginoplayer. To Download Elektrik Mistress MP3, it is necessary to download small and free player.
They have over 40 million songs! It's totally free! No spyware or malware. Download Elektrik Mistress and enjoy by listening it!
If suddenly you haven't found Elektrik Mistress MP3, write to us, we shall try to get it for you.


text:
The Manila Times College progresses as it becomes an International Baccalaureate Candidate School
by Barbara Celis | Apr 23, 2021 | General Announcements
International Baccalaureate, Baccalauréat International, Bachillerato Internacional
and IB logos are registered trademarks of the International Baccalaureate Organization.
Published October 2018
Update December 2018
Published on behalf of the International Baccalaureate Organization, a not-for-profit
educational foundation of 15 Route des Morillons, 1218 Le Grand-Saconnex, Geneva,
Switzerland by the
International Baccalaureate Organization (UK) Ltd
Peterson House, Malthouse Avenue, Cardiff Gate
Cardiff, Wales CF23 8GL
Website: ibo.org
© International Baccalaureate Organization 2018
The International Baccalaureate Organization (known as the IB) offers four high-quality and challenging educational programmes for a worldwide community of schools, aiming to create a better, more peaceful world. This publication is one of a range of materials produced to support these programmes.
The IB may use a variety of sources in its work and checks information to verify accuracy and authenticity, particularly when using community-based knowledge sources such as Wikipedia. The IB respects the principles of intellectual property and makes strenuous efforts to identify and obtain permission before publication from rights holders of all copyright material used. The IB is grateful for permissions received for material used in this publication and will be pleased to correct any errors or omissions at the earliest opportunity.
All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted, in any form or by any means, without the IB's prior written permission, or as expressly permitted by the Rules for use of IB Intellectual Property.
IB merchandise and publications can be purchased through the IB Store (email: sales@ibo.org). Any commercial use of IB publications (whether fee-covered or commercial) by third parties acting in the IB's ecosystem without a formal relationship with the IB (including but not limited to tutoring organizations, professional development providers, educational publishers and operators of curriculum mapping or teacher resource digital platforms etc) is prohibited and requires a subsequent written license from the IB. License requests should be sent to copyright@ibo.org. More information can be obtained on the IB public website.


For more than 85 years, the YMCA of Southwest Michigan has been working hard to tackle important needs in our community to benefit thousands of people.
The YMCA of Southwest Michigan is a volunteer-led public charity 501(c)(3) that works collaboratively with community partners to improve the lives of children, adults, families, and the entire community. Our purpose is to strengthen and enrich the development of individuals and families through quality programs and services that build a healthy spirit, mind, and body for all.
Your membership fee supports the daily operation of our facilities.
Program fees, individual and corporate donations, foundations, and grants support our programs and events.
Annual Campaign donations are used toward financial assistance for Y memberships and programs, and also help fund specific initiatives such as Y-Club after school care, outreach water safety programs, summer day camps, YMCA's Diabetes Prevention Program, Enhance® Fitness for seniors, and more.
Capital Campaigns fund facility expansions and renovations, contributing to the health and well-being of residents throughout the surrounding area.
Thanks to your contributions, we are able to support our communities and help them grow!


The Speers: Family Pictures for the sake of a decent Christmas... I mean New Years Card!
Family Pictures for the sake of a decent Christmas... I mean New Years Card!
A friend of mine in my playgroup who has her own photography business took these shots on the beach... when it was freezing cold and super foggy out.... go figure. But we did get a few good pictures of the family just a few weeks after Rowyn was born.
Which one will appear on the now "New Year's" card? You can guess. The cards should be arriving any day! Which means they will be sent out the first week of January (my goal). Thanks for being patient.
How on earth did you decide?! These are all amazing!! What a beautiful family -- and I'm jealous of the tank tops in December!
You look great, Meliss... not like the mom of 3 babies, and only a month out from a c-section! A-maz-ing!


text:
Become Public Policy Expert at IIMs with Mahatma Gandhi National Fellowship
The Mahatma Gandhi National Fellowship (MGNF) is an opportunity for young, dynamic individuals to contribute to enhancing skill development and promote rural employment in the country. MGNF is an initiative of the Ministry of Skill Development and Entrepreneurship (MSDE), Government of India (GoI) that is designed and implemented by 9 IIMs without even the Common Admission Test (CAT) Scores.
The fellowship is being offered by IIMs in Bangalore, Jammu, Kozhikode, Lucknow, Nagpur, Ranchi, Udaipur, Visakhapatnam and Bangalore. The programme will prepare policy leaders and policy professionals with skills, wisdom and ethics to imagine, design and implement relevant solutions to India's policy and governance challenges. The institutes will focus on designing and management of public policy has initiated new debates, discoveries and developments that have further offered the scope to explore their capabilities to make meaningful impact.
Should be a citizen of India
Age between 21-30 years at the time of application
At least a graduate in any discipline (Engineering, Law, Medicine, Social Sciences, etc.) from a recognized university or a post-graduate from a recognized university
Three years of work experience after secondary schooling in the social/non-profit sector with an interest in working in rural areas is preferred. However, individuals with no work experience and a strong motivation to work in this area may apply.
Ability to express proficiency in the official language used in the state government
Mahatma Gandhi National Fellowship
The programme will not only serve as an in-depth understanding of what public policy is, but will also equip fellows with design and management precepts, with the objective to develop better systems thinkers and policy executives. Fellows will learn not only about public policy analysis, the development of policy, but also the integration of practical concerns of finance, capabilities and ethics, as well as best practices of implementation, management and assessment, across the domains of public administration and public policy.
While working with the District Skill Committees (DSCs), the fellows will also write a position paper on the district's eventual growth trajectory and long-term skilling strategy. At the end of the two-year programme the fellows will be absorbed by various ministries and government departments.
The Fellowship is a commitment to serve with District Skill Committee (DSC) in a full-time capacity. Fellows are expected to work within the framework of the activities of the DSC and engage on activities required by respective IIMs (for example, collect details on schemes, understand district requirements, write cases in consultation with State Resource Associate, and the Faculty Panel, etc.)
Mahatma Gandhi National Fellowship Entrance Exam
The application window for 2021-23 admissions is now open. Application window open till March 27, 2021.
MGNF Exam will be held on the 3rd week of April 2021. Selected Candidates will be then called for personal interview.
There will be 100 multiple choice-type questions consisting of four sections and no negative marking:
General Awareness (GA)
Quantitative Ability (QA
Data Interpretation and Logical Reasoning (DILR)
Verbal Ability and Reading Comprehension (VARC)
Admit cards will be available from 1st week of April, 2021.
Around 660 fellows will be recruited for the 2021-23 session. The candidate will receive a monthly stipend of Rs 50,000 during the first year and Rs 60, 000 during the second year:
Number of Fellows(2021-23)
IIM Ahmedabad
IIM Lucknow
IIM Jammu
IIM Ranchi
IIM Nagpur
IIM Bangalore
IIM Udaipur
IIM Visakhapatnam
IIM Kozhikode
Certificate of Completion: MGNF is a Certificate Program in Public Policy and Management offered by host IIMs. It has been designed at the initiative of the Ministry of Skill Development and Entrepreneurship (MSDE), Government of India (GoI).
Moreover it is expected that on successful completion of MGNF, the graduating Fellows will have a comprehensive understanding of the functioning of rural economies, the ability to identify skill gaps, and design ways to address them in a way that the government can take action. The ability to understand what promotes livelihoods, and constrains economic development will be key assets for the graduating Fellow. We anticipate that the graduating Fellows will be successful in finding consulting jobs with state and national government departments across all domains, in private consulting jobs, and with CSR based organizations, non-profit foundations. For those interested in start-ups, this program provides valuable insights and connects that can help them understand the entrepreneurship ecosystem that exists and how to leverage that in their districts as well.
Are you ready to be the future public policy leader?
Stay informed, Stay ahead and stay inspired with MBA Rendezvous.


Art E Studio is located on the beautiful island of Maui, in Lahaina. It is a dedicated art school focusing on teaching children and adults the fine art of oil and acrylic painting. The instructor, Darice Machel McGuire, has over 40 years experience in fine arts. She leads her students through the basic process of creating a painting, helping each student achieve their goals and encouraging them to expand their skills by trying new techniques.
One day painting workshops are available for visitors to Maui. Take a look at the Class schedule and Workshops located in the navigation bar to the left. You can view some of the students work in the "Workshop Gallery".


Sellers and agents know that pre-qualified buyers are serious and more likely to complete a sale. This is important leverage.
Higher scores often mean better programs and rates. Learn what lenders consider that improves your chances of saving money.
Fixed-rate, adjustable, jumbo — here's a comprehensive list of common and not so common mortgage purchase rates.
Home appraisal process includes inspection, researching comparable homes, and gathering data to present a final report.
Learn about current rates and how to lower your monthly payment with tips and guides on mortgage rates.
What you can afford often comes down to simple math. Understanding key terms and documents can help save time and money.
Buying a home is a significant investment and research and education is essential.
Some consumers feel that mortgage companies want to steer you toward a mortgage option that is best for the company and not the customer. At Lenderful, we want to empower you to make decisions that help you get the mortgage you need. It is because of this that we believe education is essential. The more you understand, the better decisions you will make, and the more comfortable and in control you will feel. In our Learning Center we'll help you understand all the variables and nuances of the mortgage process so you can become the expert.
If you have a question the Learning Center doesn't answer, ask a Lenderful Expert! They're standing by to help with whatever you need.


Check out the motorcycles. This is the view from in front of Hobo Junction and Carlton Bike Rental. We like the activity. This is not your typical sleepy little town.
A few weeks ago, Joelene Steffens, visionary proprietor of Carlton Bike Rental, said, "We're definitely trying to make Carlton happen. This weekend we happen to have a gun show in town and it's just phenomenal the traffic that's going through that parking lot. It's been non-stop all day long. We had a chicken swap in our town a couple weeks ago. We're just looking for those opportunities to generate community and we want people to bring their families here. So we've got Jay Cooke State Park right down the road. It's a beautiful bike ride from here to Jay Cooke and you can, while you're there, check out a GPS unit and go on a scavenger hunt. Kids think it's fantastic. It covers all different age groups and while you're there you will see many adults doing the same thing. The great thing about it is it's free."
Stay tuned because just as summer follows spring, the best is yet to come. Minnesota starts here!
This article help me. Thank your for sharing .


Ladies, if you are looking to make an impression, or gentleman, if you want to give your woman a tangible gift that encapsulates her radiance than this is the necklace for you. Miraculous and stunning, this crystallized, Brilliant Blossom Necklace is absolutely astonishing for the eye to behold. Even though this necklace has a reputation for being inescapably eye-catching, this modern, gorgeous piece is also comfortable and light to wear. The elegance and softness of the style is delightfully counteracted by the impressive azure jewel that inhabits the centerpiece, making it a remarkable addition to any wardrobe.


Limited edition digibook pressing includes one bonus track: 'Mt. Fuji' (2006 Version). 2007 release from the Italian Hard Rock band, the final chapter of their epic saga that began with Gate of Hell. The band's masterpiece to end an unbelievable legend was recorded and mixed by Tommy Hansen (Helloween) at Jailhouse Studios. Mastered by George Marino at Sterling Sound. Cover artwork by Luis Royo. Underground Symphony. 11 tracks.