Prospects for detecting the Rossiter-McLaughlin effect of Earth-like planets: the test case of TRAPPIST-1b and c

The Rossiter-McLaughlin effect is the principal method of determining the sky-projected spin--orbit angle ($\beta$) of transiting planets. Taking the example of the recently discovered TRAPPIST-1 system, we explore how ultracool dwarfs facilitate the measurement of the spin--orbit angle for Earth-sized planets by creating an effect that can be an order of magnitude more ample than the Doppler reflex motion caused by the planet if the star is undergoing rapid rotation. In TRAPPIST-1's case we expect the semi-amplitudes of the Rossiter-McLaughlin effect to be $40-50$ m/s for the known transiting planets. Accounting for stellar jitter expected for ultracool dwarfs, instrumental noise, and assuming radial velocity precisions both demonstrated and anticipated for upcoming near-infrared spectrographs, we quantify the observational effort required to measure the planets' masses and spin--orbit angles. We conclude that if the planetary system is well-aligned then $\beta$ can be measured to a precision of $\lesssim 10^{\circ}$ if the spectrograph is stable at the level of 2 m/s. We also investigate the measure of $\Delta \beta$, the mutual inclination, when multiple transiting planets are present in the system. Lastly, we note that the rapid rotation rate of many late M-dwarfs will amplify the Rossiter-McLaughlin signal to the point where variations in the chromatic Rossiter-McLaughlin effect from atmospheric absorbers should be detectable.Comment: 11 pages, 4 figures. Accepted to MNRAS. Comments welcom

Climatology and Trends of Heatwaves in the Southeast United States

There exists broad scientific consensus that heatwaves are increasing in frequency, duration, and intensity in a warming world, and are generally the most strongly linked extreme weather event to anthropogenic climate change. Due to its predominantly maritime climate, few studies have examined heatwaves in Florida. However, Florida’s older-skewed population and increasingly urban land areas make it particularly susceptible to the impacts of heatwaves on human life and health in the twenty-first century. Using a percentile-based heatwave definition applied to station daily maximum, minimum, and average temperature data, trends in the frequency, intensity, and duration of heatwaves were investigated. In order to isolate the effect of Sea Surface Temperature (SST) on heatwaves, four major cities across the southeast were investigated and compared to six major cities on the Florida peninsula from 1950–2016. Initial results show that coastal southeast U.S. heatwave frequency and trends at locations such as New Orleans may be most similar to cities in the Florida peninsula, due in part to the proximity of warming SSTs. The most substantial trends, especially near large bodies of water, are found in minimum temperature heatwaves

Conflicts Of Interest On Regional Fishery Management Councils: Corruption Or Cooperative Management?

When Congress created the Regional Fishery Management Councils under the Magnuson Act, it was felt that user groups with an interest in the resource would act in a manner which would protect that resource and ensure the future health of our fisheries.... Now, rightly or wrongly, many people feel the Councils and their members are acting unfairly. If this perception of unfairness is correct, then Congress definitely must take strong action to rectify this problem ... even if it comes down to only a matter of perception. Congress, in enacting the Magnuson Fishery Conservation and Management Act of 1976 (MFCMA), created a unique system for the regional management and conservation of U.S. fishery resources. Central to this system are eight Regional Fishery Management Councils. Comprised of those most knowledgeable about and interested in the fisheries, the Regional Councils promised to be an innovative solution to the conservation of common fishery resources, potentially incorporating the economies of cooperative management into the U.S. fisheries management scheme. However, upon implementation of the MFCMA, the problems facing U.S. fisheries changed. Competition among U.S. fishermen replaced concern over foreign fishing. The decisions of the Regional Councils increasingly involved economic allocation. In addition, as the MFCMA was amended over time, certain checks on Council power eroded. The original Congressional delegation of authority to manage fisheries, once carefully balanced between the Secretary of Commerce and the Councils, became heavily concentrated in the Councils. The Regional Councils, comprised of individuals making economic decisions about scarce resources which could benefit them personally, with few checks on their authority and little oversight, were viewed in a new light. The public and user groups not represented on the Councils quickly noted the conflicts of interest inherent in the system and denounced them as improper. Many now perceive the Councils as corrupt. The subject has been a matter of great debate, prompting numerous congressional hearings. Legislative solutions are now before Congress. Allegations that the interested Councils were making improper management decisions peaked during the battle between the Alaskan onshore processors and Washingtonian factory trawlers in the early 1990s. When the North Pacific Fishery Management Council decided to allocate a percentage of the catch in certain fisheries to vessels serving the onshore processors, the measure was decried as the Shoreside Preference Amendment by the factory trawlers. Allegations of improper and interested behavior by Council members were made and eventually resulted in an investigation by the Inspector General into Council behavior. In addition, a congressional hearing was held to look into this investigation and to explore solutions to the Council conflict dilemma. This Comment will explore the problem now facing Congress and will evaluate the proposed solutions now being debated in the two Houses. Initially, the concept of cooperative management, one possible theoretical justification for the existing Council system, will be discussed. Next, the original management system put in place by the MFCMA will be examined. This section will be followed by an explanation of how the power structure behind that system has evolved over time. The problems created by the present imbalance in the Council power structure will then be illustrated by a case study of the allegations made regarding the Council in the North Pacific. Finally, possible solutions to the problem, contained in two bills currently before Congress, will be evaluated in light of the potential of the MFCMA to create a system of cooperative management of the nation\u27s fisheries

Vietnamese Fishermen Ass\u27n v. California Department Of Fish And Game: Should Regional Fishery Councils Determine EEZ Preemption Of State Laws?

In 1976, Congress enacted the Magnuson Fishery Management Conservation and Management Act (MFCMA), creating a national program for the conservation and management of U.S. fishery resources. The Act established regional management councils to manage all fisheries located in waters beyond the states\u27 marine boundaries. Under the MFCMA, state authority in federal waters is limited to the regulation of state-registered vessels. Since the passage of the Magnuson Act, several states have attempted to exercise this authority and regulate fishing activity outside of their territorial waters. These attempts have raised fundamental questions concerning the limits of permissible state authority under the Magnuson Act. In its decision in Vietnamese Fishermen Ass\u27n of America v. California Department of Fish & Game, the United States District Court for the Northern District of California joined a line of decisions narrowly interpreting the extent of state authority over fisheries in federal waters. The court held that extra-territorial enforcement of a California ban on gillnetting for rockfish was preempted by federal groundfish regulations allowing such gillnetting in those waters. This casenote will argue that there are two problems with the decision. The first problem lies in the court\u27s reduction of the role of state fisheries management by finding an actual conflict by implication at a time when all management agencies should be working together to protect fish stocks. The second problem arises from the decision of the court to give deference to an unappealable consistency determination by a body containing inherent conflicts of interest. These problems reflect the court\u27s failure to properly balance its analysis under the Supremacy Clause with fundamental concerns stemming from the concepts of federalism and due process. As a result, the court unjustifiably prevented a state from protecting a fishery in which it had a legitimate interest

Vietnamese Fishermen Ass\u27n v. California Department Of Fish And Game: Should Regional Fishery Councils Determine EEZ Preemption Of State Laws?

In 1976, Congress enacted the Magnuson Fishery Management Conservation and Management Act (MFCMA), creating a national program for the conservation and management of U.S. fishery resources. The Act established regional management councils to manage all fisheries located in waters beyond the states\u27 marine boundaries. Under the MFCMA, state authority in federal waters is limited to the regulation of state-registered vessels. Since the passage of the Magnuson Act, several states have attempted to exercise this authority and regulate fishing activity outside of their territorial waters. These attempts have raised fundamental questions concerning the limits of permissible state authority under the Magnuson Act. In its decision in Vietnamese Fishermen Ass\u27n of America v. California Department of Fish & Game, the United States District Court for the Northern District of California joined a line of decisions narrowly interpreting the extent of state authority over fisheries in federal waters. The court held that extra-territorial enforcement of a California ban on gillnetting for rockfish was preempted by federal groundfish regulations allowing such gillnetting in those waters. This casenote will argue that there are two problems with the decision. The first problem lies in the court\u27s reduction of the role of state fisheries management by finding an actual conflict by implication at a time when all management agencies should be working together to protect fish stocks. The second problem arises from the decision of the court to give deference to an unappealable consistency determination by a body containing inherent conflicts of interest. These problems reflect the court\u27s failure to properly balance its analysis under the Supremacy Clause with fundamental concerns stemming from the concepts of federalism and due process. As a result, the court unjustifiably prevented a state from protecting a fishery in which it had a legitimate interest

Conflicts Of Interest On Regional Fishery Management Councils: Corruption Or Cooperative Management?

When Congress created the Regional Fishery Management Councils under the Magnuson Act, it was felt that user groups with an interest in the resource would act in a manner which would protect that resource and ensure the future health of our fisheries.... Now, rightly or wrongly, many people feel the Councils and their members are acting unfairly. If this perception of unfairness is correct, then Congress definitely must take strong action to rectify this problem ... even if it comes down to only a matter of perception. Congress, in enacting the Magnuson Fishery Conservation and Management Act of 1976 (MFCMA), created a unique system for the regional management and conservation of U.S. fishery resources. Central to this system are eight Regional Fishery Management Councils. Comprised of those most knowledgeable about and interested in the fisheries, the Regional Councils promised to be an innovative solution to the conservation of common fishery resources, potentially incorporating the economies of cooperative management into the U.S. fisheries management scheme. However, upon implementation of the MFCMA, the problems facing U.S. fisheries changed. Competition among U.S. fishermen replaced concern over foreign fishing. The decisions of the Regional Councils increasingly involved economic allocation. In addition, as the MFCMA was amended over time, certain checks on Council power eroded. The original Congressional delegation of authority to manage fisheries, once carefully balanced between the Secretary of Commerce and the Councils, became heavily concentrated in the Councils. The Regional Councils, comprised of individuals making economic decisions about scarce resources which could benefit them personally, with few checks on their authority and little oversight, were viewed in a new light. The public and user groups not represented on the Councils quickly noted the conflicts of interest inherent in the system and denounced them as improper. Many now perceive the Councils as corrupt. The subject has been a matter of great debate, prompting numerous congressional hearings. Legislative solutions are now before Congress. Allegations that the interested Councils were making improper management decisions peaked during the battle between the Alaskan onshore processors and Washingtonian factory trawlers in the early 1990s. When the North Pacific Fishery Management Council decided to allocate a percentage of the catch in certain fisheries to vessels serving the onshore processors, the measure was decried as the Shoreside Preference Amendment by the factory trawlers. Allegations of improper and interested behavior by Council members were made and eventually resulted in an investigation by the Inspector General into Council behavior. In addition, a congressional hearing was held to look into this investigation and to explore solutions to the Council conflict dilemma. This Comment will explore the problem now facing Congress and will evaluate the proposed solutions now being debated in the two Houses. Initially, the concept of cooperative management, one possible theoretical justification for the existing Council system, will be discussed. Next, the original management system put in place by the MFCMA will be examined. This section will be followed by an explanation of how the power structure behind that system has evolved over time. The problems created by the present imbalance in the Council power structure will then be illustrated by a case study of the allegations made regarding the Council in the North Pacific. Finally, possible solutions to the problem, contained in two bills currently before Congress, will be evaluated in light of the potential of the MFCMA to create a system of cooperative management of the nation\u27s fisheries

Requirement for Slit-1 and Robo-2 in zonal segregation of olfactory sensory neuron axons in the main olfactory bulb

The formation of precise stereotypic connections in sensory systems is critical for the ability to detect and process signals from the environment. In the olfactory system, olfactory sensory neurons (OSNs) project axons to spatially defined glomeruli within the olfactory bulb (OB). A spatial relationship exists between the location of OSNs within the olfactory epithelium (OE) and their glomerular targets along the dorsoventral axis in the OB. The molecular mechanisms underlying the zonal segregation of OSN axons along the dorsoventral axis of the OB are poorly understood. Using robo-2/ (roundabout) and slit-1/ mice, we examined the role of the Slit family of axon guidance cues in the targeting of OSN axons during development. We show that a subset of OSN axons that normally project to the dorsal region of the OB mistarget and form glomeruli in the ventral region in robo-2/ and slit-1/ mice. In addition, we show that the Slit receptor, Robo-2, is expressed in OSNs in a high dorsomedial to low ventrolateral gradient across the OE and that Slit-1 and Slit-3 are expressed in the ventral region of the OB. These results indicate that the dorsal-to-ventral segregation of OSN axons are not solely defined by the location of OSNs within the OE but also relies on axon guidance cues

Newinsights in the ontogeny and taphonomy of the Devonian acanthodian Triazeugacanthus affinis from the Miguasha Fossil-Lagerstatte, Eastern Canada

Progressive biomineralization of a skeleton occurs during ontogeny in most animals. In fishes, larvae are poorly mineralized, whereas juveniles and adults display a progressively more biomineralized skeleton. Fossil remains primarily consist of adult specimens because the fossilization of poorly-mineralized larvae and juveniles necessitates exceptional conditions. The Miguasha Fossil-Lagerstatte is renowned for its Late Devonian vertebrate fauna, revealing the exceptional preservation of fossilized ontogenies for 14 of the 20 fish species from this locality. The mineralization of anatomical structures of the acanthodian Triazeugacanthus affinis from Miguasha are compared among larval, juvenile and adult specimens using Energy Dispersive X-ray Spectrometry. Chemical composition of anatomical structures of Triazeugacanthus reveals differences between cartilage and bone. Although the histology and anatomy is well-preserved, Fourier transform infrared spectrometry shows that the original chemical composition of bone is altered by diagenesis; the mineral phase of the bone (i.e., hydroxyapatite) is modified chemically to form more stable carbonate-fluorapatite. Fluorination occurring in mineralized skeletal structures of adult Triazeugacanthus is indicative of exchanges between groundwater and skeleton at burial, whereas the preservation of larval soft tissues is likely owing to a rapid burial under anoxic conditions. The exceptional state of preservation of a fossilized ontogeny allowed us to characterize chemically the progressive mineralization of the skeleton in a Devonian early vertebrate

Guidelines for physical weed control research: flame weeding, weed harrowing and intra-row cultivation

A prerequisite for good research is the use of appropriate methodology. In order to aggregate sound research methodology, this paper presents some tentative guidelines for physical weed control research in general, and flame weeding, weed harrowing and intra-row cultivation in particular. Issues include the adjustment and use of mechanical weeders and other equipment, the recording of impact factors that affect weeding performance, methods to assess effectiveness, the layout of treatment plots, and the conceptual models underlying the experimental designs (e.g. factorial comparison, dose response). First of all, the research aims need to be clearly defined, an appropriate experimental design produced and statistical methods chosen accordingly. Suggestions on how to do this are given. For assessments, quantitative measures would be ideal, but as they require more resources, visual classification may in some cases be more feasible. The timing of assessment affects the results and their interpretation. When describing the weeds and crops, one should list the crops and the most abundantly present weed species involved, giving their density and growth stages at the time of treatment. The location of the experimental field, soil type, soil moisture and amount of fertilization should be given, as well as weather conditions at the time of treatment. The researcher should describe the weed control equipment and adjustments accurately, preferably according to the prevailing practice within the discipline. Things to record are e.g. gas pressure, burner properties, burner cover dimensions and LPG consumption in flame weeding; speed, angle of tines, number of passes and direction in weed harrowing. The authors hope this paper will increase comparability among experiments, help less experienced scientists to prevent mistakes and essential omissions, and foster the advance of knowledge on non-chemical weed management

The Trilogy of Personal Jurisdiction and the Importance of \u3cem\u3eFord\u3c/em\u3e

Litigants and judges alike have struggled to understand and resolve the parameters of personal jurisdiction, particularly in product liability cases. This results in significant costs and time which is likely to be of little benefit to anyone. Much of this confusion arises from two problems: (1) most of the early Supreme Court decisions on personal jurisdiction arose from contractual disputes; and (2) when the economy expanded after World War II, and new automobiles, commercial aircraft, appliances, and other complex products appeared, the Court’s attempts to resolve personal jurisdiction issues were unsuccessful. For over three decades, the Supreme Court failed to produce a clear majority opinion, while at the same time, these cases were becoming more common and complex. In the past decade, however, the Court has quietly produced a trilogy of virtually unanimous opinions that offer pathways to resolve personal jurisdiction disputes. These decisions will be particularly useful in product liability cases of all kinds, which often involve suit-related events occurring across multiple jurisdictions. Once lawyers and judges understand this clarified framework, it should become easier for plaintiffs to make better decisions about where to bring their case and enable both plaintiffs and defendants to spend less time and expense litigating personal jurisdiction disputes