Public Trust Complaint; Upper Napa River part 1

[Troutstalker55B]

For those of you that know my Dad and his environmental work for the last 44 years, I wanted to share his latest formal complaint in regards to the upper Napa River and Steelhead. At 82 years old he continues his relentless battle for the good fight. I'm one proud son!


State of California
Before the San Francisco Bay California Regional Water Quality Control Board
City of Calistoga, Permitee, and et al.
Dunaweal Wastewater Treatment Plant
Napa River, Tributary to San Pablo Bay, thence San Francisco Bay, thence Pacific Ocean

Petition for Request for Information and Investigation by the Regional Water Quality Board by the California Fisheries and Water Unlimited, Petitioner

The State Water Resources Control Board has initiated an investigation and enforcement actions pursuant to public complaints by the California Fisheries and Water Unlimited and other parties to provide daily flows into the headwaters of the Napa River from Kimball Dam in order to protect federally protected threatened Steelhead and other fisheries, the river environment, and the beneficial uses of the headwaters of the Napa River from dewatering and inadequate daily flows from Kimball Dam by the City of Calistoga.

During the past year, Steelhead have been observed in the Napa River below the Washington Street bridge in downtown Calistoga. There is significant historic evidence that Steelhead migrated into the Napa River for spawning and rearing purposes for decades. Thousands of Steelhead migrated and spawned according to the records. The endangered Coho Salmon also spawned in the Napa River but have been exterminated; we cite the records.

Steelhead are protected by the federal Endangered Species Act under the authority and management of the US NOAA Fisheries federal agency. Steelhead are also protected by the State of California Endangered Species Act under the authority and management of the California Department of Fish and Game. The endangered Freshwater Shrimp also exists in the Upper Napa River watershed, and are protected and managed by the US Fish and Wildlife Service.

The State Water Resources Control Board has both a duty and responsibility to protect the state's water quality from contamination. The Regional Water Quality Boards (all-statewide) are an arm of the State Water Board to enforce the Porter-Cologne Water Quality Control Act and other provisions of state and federal law to protect water quality and the beneficial uses of the state's water and to prevent contamination of the state's waters.

Unauthorized 709,000 Gallon Spill into the Napa River from the City of Calistoga Dunaweal Wastewater Treatment Plant

Three miles below Kimball Dam, there exist adverse water quality conditions at the outfall of the City of Calistoga's Dunaweal Wastewater Treatment Plant into the Napa River due to adverse water quality caused by the operation of the Dunaweal Wastewater Treatment Plant. This anti-environmental water quality barrier affects Steelhead, their habitat, and the river environment, with potential and likely adverse effects to downstream water users that divert water from the Napa River, including unknown effects to public health and safety.

The City of Calistoga's Wastewater Treatment Plant may not have the capacity to collect and clean additional wastewater that will be discharged into the Napa River resulting from two newly-approved major resorts within the city limits of Calistoga; namely, the Silver Rose Resort and the Enchanted Resorts projects.
The Silver Rose Resort project will have an 84-room hotel and spa, three swimming pools, three large holding ponds, public restaurant, bar, and delicatessen, banquet room, vineyard, winery, parking, 21 custom homes, plus additional support facilities. The Enchanted Resorts Project will have 110 hotel units, 20 residence club units, spa, swimming pools, detention ponds, public restaurant and bar, ballroom, parking, 13 custom homes, plus additional support facilities.

Last year, on January 23, 2013, an unauthorized spill of approximately 709,000 gallons (others reports are higher) of contaminated and partially-treated water from the Dunaweal Wastewater Treatment Plant contaminated the Napa River. Years prior, in December 2010 and January 2011, Dunaweal wastewater including toxins including antimony and cyanide are known to have contaminated the Napa River. Further, local sources have indicated that on November 19, 2012, the City of Calistoga was pumping the southside outfall pond to the sewer main to keep their ponds from overtopping. The sewage graph shows the spikes (page 2, line 2367, pdf). Dunaweal's three (3) riverside ponds are not able to hold the current wastewater load as they percolate directly into the adjacent Napa River on a daily basis.

Toxic water from the Dunaweal Wastewater Treatment Plant can only be released into the Napa River in increments during wet months pursuant to specific daily flows ordered by the Water Quality Board.

[Troutstalker55B]

Please answer the following questions:

1. Did the Regional Water Quality Board issue enforcement penalties and fines against the City of Calistoga for discharging 709,000 gallons of unauthorized wastewater into the Napa River from the Dunaweal Wastewater Treatment Plant? If not, please explain the specific reasons why enforcement actions were not taken by the Regional Board against the City of Calistoga. If so, what were the specific penalties?

2. Did the Regional Water Quality Board and its staff conduct any water quality and/or aquatic studies to determine the effects to the Napa River environment and the Steelhead and local fisheries resulting from the discharge of 709,000 gallons of unauthorized contaminated wastewater into the Napa River? If not, please explain the reasons why studies and surveys were not conducted by the Regional Water Quality Board and its staff to document and determine the effects to the public trust waters of the Napa River resulting from the unauthorized spill. If studies and surveys were conducted, please forward the conclusions to me.

3. Did the Regional Water Quality Board and its staff require the City of Calistoga to conduct water quality and/or aquatic studies to determine the effects to the river environment, Steelhead and local fisheries, and beneficial uses of the waters of the Napa River resulting from the spill of 709,000 gallons of unauthorized wastewater from the City of Calistoga's Wastewater Plant? If not, please explain the reasons why the City was not required by the Board and its staff to conduct studies to determine the effects from the 709,000 gallon unauthorized spill of contaminated water into the Napa River and the effects to the beneficial uses of the state's water.

4. Did the Regional Water Quality Board and its staff consult with the US NOAA Fisheries regarding the spill of 709,000 gallons of unauthorized waste water into the Napa River that most likely adversely affected Steelhead species and their habitat in the river below the plant discharge outfall point downstream? If not, please explain the reasons why the Regional Water Quality Board and its staff did not advise the US NOAA Fisheries concerning the unauthorized spill. If so, please forward a copy of any consultation letter sent by the Regional Water Quality Board and its staff to the US NOAA Fisheries regarding the unauthorized spill and the potential effects to federally protected threatened Steelhead and their habitat in the Napa River.


5. Did the Regional Water Quality Board and its staff consult with the California Department of Fish and Game (CDFG) regarding the spill of 709,000 gallons of unauthorized wastewater into the Napa River that most likely adversely affected Steelhead species and their habitat as well as other local fisheries and their habitat in the river below the discharge point downstream? If not, please explain the reasons why the Water Quality Board and its staff did not advise the CDFG concerning the unauthorized spill and the effects to the anadromous and local resident fisheries of the Napa River.

6. Did the Regional Water Quality Board and its staff consult with the staff of the State Water Resources Control Board (aka Division of Water Rights) regarding the unauthorized spill of 709,000 gallons of wastewater into the Napa River that most likely adversely affected downstream water users, public health and safety, Steelhead species and their habitat, and other fisheries and their habitat in the river, including all beneficial uses of the Napa River below the discharge plant point downstream? If not, please explain the reasons why the Regional Water Quality Board and its staff did not advise the SWRCB (aka Division of Water Rights) concerning the unauthorized spill and the effects to water users and the beneficial uses of the waters of the Napa River.

7. Did the Regional Water Quality Board and its staff notify and consult with all downstream water users that the river was contaminated by the unauthorized 709,000 wastewater spill from the Dunaweal Wastewater Treatment Plant to protect water rights, water quality, public health and safety, and all beneficial uses of the Napa River? Please forward copies of correspondence to downstream water users that use the surface water of the Napa River. If downstream water users were not notified by the Regional Board, agricultural crops and people (and critical public health and safety) may have been adversely affected by the unauthorized spill of 709,000 gallons of wastewater from the Dunaweal Wastewater Treatment Plant.

8. Did the Regional Water Quality Board and its staff consult with the US Fish and Wildlife Service regarding the spill of 709,000 gallons of unauthorized wastewater into the Napa River that most likely adversely affected federally endangered Freshwater Shrimp in the river below the discharge point downstream? If not, please explain the reasons why the Water Quality Board and its staff did not advise and consult with the US Fish and Wildlife Service concerning the unauthorized spill and the effects to the endangered Freshwater Shrimp and its habitat of the Napa River.

9. What are the specific periods in wet months that discharges are allowed by the Regional Board from the Dunaweal Wastewater Treatment Plant?

10. What is the minimum daily flow in the Napa River that wastewater discharges can be made by the City of Calistoga from the Dunaweal Wastewater Treatment Plant?

11. What are the Permit conditions ordered by the Regional Board that allows the City of Calistoga to discharge wastewater from the Dunaweal Wastewater Treatment Plant into the Napa River during dry water years, very dry water years, and also drought water years when flow drops below the minimum rate?

12. How does the Regional Board and its staff measure the daily flow of the Napa River at or below the outfall of the Dunaweal Wastewater Treatment Plant to determine compliance of the daily flow requirements (i.e. gauges)?

13. Does the Regional Board and Staff measure water quality in the reaches of the Napa River from the outfall point to several miles or more downstream in the Napa River to insure that water quality is not affected and not contaminated by both authorized and unauthorized discharges of wastewater from the City of Calistoga Dunaweal Wastewater Treatment Plant?

14. Has the Regional Water Quality Board found other violations of the City's Water Quality Permit to operate the Dunaweal Wastewater Treatment Plant since the WQ permit was originally issued to the City? If so, what were the specific violations? Were penalties and/or fines imposed by the Regional Board to protect the beneficial uses of the state's water, if any violations occurred?

15. How often does the staff of the Regional Water Quality Board inspect and monitor the Dunaweal Wastewater Treatment Plant for compliance of the City of Calistoga's Water Quality Permit, including authorized and unauthorized spills? Weekly? Monthly? Annually? Nocturnally -- as local sources have claimed to have observed bypassing?

[Troutstalker55B]

Unlined Riverside Ponds

According to one local source, the Dunaweal Wastewater Treatment Plant has three (3) riverside ponds that are not lined to protect groundwater nor river surface and underflow water from being contaminated by illegal and legal wastewater treatment procedures conducted by the City of Calistoga. If this information is accurate, why has the Regional Board allowed the riverside ponds from modifications to protect water quality, the river environment, and the beneficial uses of the state's water of the Napa River? We recommend the riverside ponds are mandated to be lined pursuant to the policy and the requirements of the Porter-Cologne Water Quality Act, as amended, and also the Federal Water Pollution Act Control Act, and suggest that state and/or federal grant money may be sought for this purpose.

Antimony and Cyanide Discharges Napa River

The Dunaweal Wastewater Treatment Plant has discharged toxins including antimony and cyanide into the state's waters of the Napa River. Please answer the following questions:

1. What is the source of antimony from the Dunaweal Wastewater Treatment Plant?

2. What action has the Regional Board and its staff taken to prevent the City of Calistoga from discharging antimony into the state's waters of the Napa River to protect the beneficial use of the state's waters?

3. What is the source of cyanide from the Dunaweal Wastewater Treatment Plant?

4. What action has the Regional Board and its staff taken to prevent the City of Calistoga from discharging cyanide into the state's waters of the Napa River to protect the beneficial use of the state's waters?

5. Did the Regional Board and its staff require studies to determine the effects to public health and safety, and the environment of the Napa River resulting from discharging antimony and cyanide into the Napa River?

6. Are there warning signs posted on the river/roads to prevent the public from contacting the waters of the Napa River below the treatment plant resulting from discharging antimony and cyanide into the Napa River?

7. Have water users been notified by the City of Calistoga and the Regional Board and its staff of antimony and cyanide being discharged into the Napa River to protect public health and safety?

Hot Boron-Laden Surface Water

Hot boron-laden, unmetered water is continuing to be discharged into the Napa River from the area's wastewater streams. Boron is not present in the city's municipal water supply; boron and other toxins are present in Calistoga's geothermal waters (groundwater). Hot boron-laden water enters the waste streams from business spas and private users of geothermal wells. It is illegal to put and/or to discharge hot boron-laden geothermal water into Calistoga's waste stream, thence the Napa River. See Calistoga Municipal Code Section 13.08.345 and Section 13.08.395. See also Porter-Cologne Water Quality Control Act, as amended, the federal Clean Water Act, and Title 40, Code of Federal Regulations under protection of fish life et al. The City of Calistoga has no system to remove hot boron-laden wastewater from the state's waters. Totals for geothermal water use and discharge utilized by city spas remain unpublicized to date. Boron-laden wastewater is very sensitive to many crops including grapes, citrus, walnuts, prunes, and other stone fruit crops which have been grown historically in the area. Boron-laden water cannot be used or sold for agricultural uses, and it can also adversely affect cold water aquatic species and their habitat; yet the City of Calistoga's hot boron-laden water is presently being sprayed on open fields as city practice. Local sources have indicated that the water sprayed in the open field enters the Napa River illegally from runoff because of the City's spraying during periods of rainfall, a practice observed as recently as March 7, 2013 ; photographic record is available.

Please answer the following questions:

1. How does the Regional Water Quality Board insure the public that hot boron-laden surface water will not be discharged into the Napa River to contaminate the river environment pursuant to state and federal statutes? Please explain the Board's actions to protect water quality and the river environment (cold water species) resulting from hot boron-laden surface stream water flowing into the Napa River and its tributaries.

2. Please forward water quality and aquatic studies that were conducted by the Regional Water Quality Board and its staff to determine the effects to the Napa River environment, anadromous and local fisheries, agriculture, water users, and other beneficial uses of the state's water resulting from unauthorized hot boron-laden water being discharged into Napa River and its tributaries from wastewater surface streams. If no studies were conducted, please relate the specific reasons why studies were not conducted by the Board or its staff to study and protect the public trust resources of California and the beneficial uses of the Napa River.

3. Does the Regional Water Quality Board and its staff inspect the unauthorized surface streams where hot boron-laden water is discharged into the Napa River and its tributaries by private businesses and parties? How often are the streams inspected of private facilities (weekly, monthly, annually)? Has the Board and its staff consulted with the local parties discharging boron-laden water into the state's water to prevent the contamination of the state's water? Specifically, what type of progress has been made to date?

4. Has the Regional Water Quality Board issued penalties and fines to parties that discharge boron-laden water into the Napa River and/or its tributaries? If not, please explain the reasons why penalties and fines have not been issued to parties discharging hot boron-laden water into the Napa River and/or its tributaries.

5. Has the Regional Water Quality Board and its staff required the City of Calistoga to enforce their municipal codes to insure the public that hot boron-laden water will not be discharged into the Napa River and its tributaries? Please forward any/all copies of said correspondence requiring compliance of said municipal codes.

6. How will the Regional Water Quality Board prevent hot boron-laden surface water from being discharged into the Napa River pursuant to the Porter-Cologne Water Quality Control Act and other applicable provisions of law?

7. Is the spraying of hot boron-laden water on any open field in the Napa River watershed legal or illegal? Please cite provisions of law.

8. Has the spraying of hot boron-laden water on any open field in the Napa River watershed been authorized, either directly or indirectly, by the Regional Board and its staff? Please cite the situation and condition of law which allows this activity.

9. What is the specific metered amount of hot boron-laden water from wastewater streams being discharged into the Napa River? The Regional Board and its staff should have this information; if not, please explain the reasons why.

10. What is the metered amount of hot boron-laden water being sprayed on open fields in the Napa River watershed? The Regional Board and its staff should have this information; if not, please explain the reasons why.

We strongly recommend halting the additional use of geothermal water without delay and until the time when appropriate studies have been concluded and mitigation measures are in place to prevent further contamination of the Napa River and its tributaries -- and the City of Calistoga has shown to be in full compliance with state and federal statutes.

11. Has any written agreement between the City of Calistoga, spa businesses, and other private parties that allows hot boron-laden waters to be discharged into the state's waters of the Napa River and its tributaries been authorized by the Regional Water Quality Board? Please cite provisions of law.

Silver Rose Resort and Enchanted Resorts Projects - Recent Developments - City of Calistoga Dunaweal Wastewater Treatment Plant

The City of Calistoga has recently approved two (2) major resort projects (the Silver Rose Resort and Enchanted Resorts projects) that will cause additional expansion of sewage and wastewater into the Dunaweal Wastewater Treatment Plant. This tremendous expansion of sewage and wastewater stretches Dunaweal's capacity and creates the even greater potential for unauthorized spills of contaminated wastewater into the Napa River, affecting the beneficial uses (fisheries, river environment, downstream water users, public health, and safety, et al) of the Napa River.

The records show that no mitigation was developed by the City in conjunction with requirements set forth by the Regional Water Quality Board and its staff to insure the public that no spills from overtopping of the treatment ponds will occur in the future years from the proposed and approved developments of the Silver Rose Resort and the Enchanted Resorts projects -- as well as any future development approved by the City of Calistoga. The Regional Board has a duty to mitigate any and all effects to water quality and the beneficial uses of the Napa River that may occur and could be created by the Silver Rose Resort and Enchanted Resorts projects at the City's wastewater plant, including any/all future development because of the expanded use of the Dunaweal Wastewater Treatment Plant facilities.

[Troutstalker55B]

Please answer the following questions:

1. Did the Regional Water Quality Control Board and its staff consult with the City of Calistoga regarding the CEQA process or any other process regarding the effects and expansion to the capacity of the Dunaweal Wastewater Treatment Plant from the Silver Rose Resort and Enchanted Resorts projects? Please forward to me letters of consultation between the City of Calistoga and the Board and its staff regarding the CEQA process for the Silver Rose Project. What are the recommended specific requirements set by the Board and its staff to handle the additional sewage and wastewater into the wastewater treatment plant by the Silver Rose Project to protect the beneficial uses of the Napa River? Beneficial uses means: anadromous fisheries and their habitat, local fisheries and their habitat, invertebrates and their habitat, water quality, downstream water users, public health and safety, et al.

We strongly recommend that the Regional Water Quality Control Board and its staff halt the construction of the Silver Rose Resort project until there are specific requirements ordered by the Regional Board to protect the beneficial uses of the Napa River resulting from the expanded use of the Dunaweal Wastewater Treatment Plant for the Silver Rose Resort project. Consider this recommendation a public complaint.

2. Did the Regional Water Quality Control Board and its staff consult with the City of Calistoga regarding the CEQA process or any other process regarding the effects and expansion use to the capacity of the Dunaweal Wastewater Treatment Plant from the Enchanted Resorts project? Please forward to me letters of consultation between the City of Calistoga and the Board and its staff regarding the CEQA process for the Enchanted Resorts project. What are the recommended specific requirements set by the Board and its staff to handle the additional sewage et al into the wastewater treatment plant for the Enchanted Resorts project to protect the beneficial uses of the Napa River? Beneficial uses means: anadromous fisheries and their habitat, local fisheries and their habitat, invertebrates and their habitat, water quality, downstream water uses, public health and safety, et al.

We also recommend that the Regional Water Quality Control Board and its staff halt the construction of the Enchanted Resorts project until there are specific requirements implemented by the Water Quality Board to protect the beneficial uses of the Napa River resulting from the expanded use of the Dunaweal Wastewater Treatment Plant for the Enchanted Resorts project. Consider this recommendation a public complaint.

3. In developing the specific water quality protection measures for the expanded uses of the City of Calistoga's wastewater treatment plant for the Silver Rose Resort and Enchanted Resorts projects, consult with the State Water Resources Control Board and its staff so that the beneficial uses of the Napa River are protected from the Silver Rose project, Enchanted Resorts project, and/all other future developments that may be approved by the City of Calistoga. Please consult with the SWRCB and its staff to determine the effects to downstream water users and public health from unauthorized spills from the Dunaweal Wastewater Treatment Plant resulting from the present project as operated as well as the expanded project, with cumulative effects from both the Silver Rose Resort and the Enchanted Resorts projects' sewage et al. to protect the downstream water supplies and public health and safety.

4. In developing the specific water quality protection measures for the expansion of the City of Calistoga's wastewater treatment plant for the Silver Rose Resort and Enchanted Resorts projects, consult with the US NOAA Fisheries and the California Department of Fish and Game and their staff so that the beneficial uses of the Napa River are protected from the Silver Rose Resort project, Enchanted Resorts project, and/all other future developments that may be approved by the City of Calistoga.

5. Please forward an analysis that shows that the beneficial uses of the state's water in San Pablo Bay will not be adversely affected by unauthorized and authorized spills from the City of Calistoga's wastewater treatment plant under present conditions as well as under the expanded uses by the Silver Rose Resort and the Enchanted Resorts projects, i.e. cumulative effects.

Management of the Dunaweal Wastewater Treatment Plant

Upon the City of Calistoga former Public Works Director's retirement last month, the City approved, on February 19, 2013, to amend the city's municipal code to eliminate the requirement that the city's Director of Public Works (and manager of the Dunaweal Wastewater Treatment Plant) hold California certification of registration as a civil engineer. Pursuant to the rules and procedures of the Regional Board, can the City of Calistoga appoint a non-certified engineer to run and to operate the Dunaweal Wastewater Treatment Plant pursuant to state and federal statutes and regulations? This matter was highly controversial with the Regional Board's staff because of a formal report submitted to the Regional Board and its staff from the City of Calistoga.



Relief Requested

We expect water quality, endangered and threatened species, the Napa River environment, the authorized water users downstream, as well as public health and safety to be protected -- at all times -- by the Regional Water Quality Control Board and its staff in order to to safeguard the beneficial uses of the Napa River and San Pablo Bay. We formally request you conduct an investigation and take any/all corrective legal action to bring the City of Calistoga and other parties into full compliance within the provisions of the Clean Water Act and the Porter Cologne Water Quality Control Act, as amended; see citations cited.

Please consult with the Executive Officer of the San Francisco Bay Regional Water Quality Control Board and the Chief Enforcement officer regarding a response to this matter. Please consider this correspondence a formal complaint and a request to conduct the appropriate investigations to stop potential contamination and prevent future degradation of the Napa River by the Dunaweal Wastewater Treatment Plant and other parties, and to require the proper management of the City of Calistoga's Dunaweal Wastewater Treatment Plant, including any proposed as well as previously-approved projects as the Silver Rose Resort and Enchanted Resorts projects, by having the wastewater facility modified and in full compliance prior to construction and operation of future development projects. Please answer my questions and please forward to me your answers electronically. Thank you.

Respectfully Submitted
Signed by Bob Baiocchi

Bob Baiocchi
California Fisheries and Water Unlimited
E-Mail Address: bobbaiocchi@yahoo.com
March 17, 2013

cc: Chief Executive Officer, San Francisco Bay Regional Water Quality Control Board; Lila Tang, Chief, NPDES Wastewater Division, c/o Tong Yin, Staff

Mr. Phil Crader, Division of Water Rights, SWRCB, et al

Mr. Taro Murano, Division of Water Rights, et al

Mr. Steve Edmondson, US NOAA Fisheries, et al

Mr. Richard Spitler, City Manager, City of Calistoga

Interested Local and Statewide Parties


Citations Cited

Federal Endangered Species Act (Steelhead, Freshwater Shrimp, all)

State of California Endangered Species Act (Steelhead, all)

Porter-Cologne Water Quality Control Act, as amended (Water Quality) See Section 13160; See Policy et al

Federal Pollution Control Act (Pollution)

Clean Water Act (Water Quality)

Section 25140 of the Health and Safety Code

California Water Code (Water-Beneficial Uses)

Article X, Section 2; California Constitution (Water- Unreasonable and Reasonable uses)

Mono Lake Decision (Public Trust Resources and Protection)

California Health and Safety Codes (Public Health and Safety)

Title 40; Code of Federal Regulations (Water Quality Protection)

Regional Water Board Order No. R2-2006-0066 (evidence)

Regional Water Board Order No. R2-2010-0104 (evidence)

Inspection Report Facility ID 212750; June 26, 2009 (evidence)

Letter to Warren Schenstrom from Regional Board staff; Notice of Violation; Report of Inspection; June 1, 2012

Other reports and photos; Dunaweal Wastewater Treatment Plan; SFBRWQCB; on file at sate office; (evidence)
Council to study problems in water and sewer budgets; May 5, 2012; Weekly Calistogan (local newspaper) (heresy evidence)

State Regulators ask for more details about release of wastewater; June 14, 2012; Weekly Calistogan (local newspaper) (heresy evidence)

Executive Officer's Report; January 2013; San Francisco Bay Regional Water Quality Control Board; Napa River and Napa Valley

others not noted


This petition is dedicated to the memory of fellow San Franciscan, classmate, and outdoorsman, Joseph Bertolas. A rebellious streak didn't permit Joe to finish Balboa High School with the rest of us, but his innate understanding of nature made him comprehend the meaning of sustainability long before there was a word for it and a college degree in it. His memories of fishing the San Francisco Bay, its estuaries, and the many streams north of it, among them, the Napa and Russian rivers, created a lifelong bond which will be missed.

Joseph Bertolas (1931-March 12, 2013)

[WinterrunRon]

Wow. I know the energy it took to read it, can't imagine what it took to research and write. And at 82. You should be proud, indeed.

[Larry S]

I know what you mean, Ron. I'm 7 years behind him and I had to stop twice and take naps while reading it. LOL!
Great document.
Best,
Larry S

[k.hanley]

Jon your Dad is one powerful advocate for our treasured resources. You should be proud.

Please pass along that his energy and efforts are greatly appreciated. I'm certainly thankful for his work.

Cheers, Ken

[Troutstalker55B]

Thanks Ken, I'll pass on your kind note to Dad. He still has that famous "Pit Bull" drive when it come to the fisheries and public trust.