Distribution to Undo Excess: The Ninth Circuit Looks to an Equitable Approach to Apportion the Costs of Environmental Cleanup in \u3cem\u3eAmeriPride Services Inc. v. Texas Eastern Overseas Inc.\u3c/em\u3e

On April 2, 2015, in AmeriPride Services Inc. v. Texas Eastern Overseas Inc., the U.S. Court of Appeals for the Ninth Circuit joined the U.S. Court of Appeals for the First Circuit in holding that district courts are not bound to a single method of distributing response costs in contribution actions under § 9613(f) of the Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”). The First and Ninth Circuits have held that courts may allocate such costs according to the most equitable method as long as it is consistent with the language and the purposes of CERCLA. The U.S. Court of Appeals for the Seventh Circuit, alternatively, has ruled that district courts must allocate response costs using the method prescribed by the Uniform Contribution Among Tortfeasors Act, which accounts for settlements by reducing total liability by the dollar amount of the agreement. This Comment argues that the First and Ninth Circuits’ interpretation of CERCLA is correct because it accounts for the variety and complexity of contribution actions under CERCLA and because it furthers CERCLA’s goals of promoting the prompt cleanup of hazardous waste sites and ensuring that parties responsible for environmental harm bear the cost of cleaning the damage

Climate mediates the effects of disturbance on ant assemblage structure

Many studies have focused on the impacts of climate change on biological assemblages, yet little is known about howclimate interacts with other major anthropogenic influences on biodiversity, such as habitat disturbance. Using a unique global database of 1128 local ant assemblages, we examined whether climate mediates the effects of habitat disturbance on assemblage structure at a global scale. Species richness and evenness were associated positively with temperature, and negatively with disturbance. However, the interaction among temperature, precipitation and disturbance shaped species richness and evenness. The effectwas manifested through a failure of species richness to increase substantially with temperature in transformed habitats at low precipitation. At low precipitation levels, evenness increased with temperature in undisturbed sites, peaked at medium temperatures in disturbed sites and remained low in transformed sites. In warmer climates with lower rainfall, the effects of increasing disturbance on species richness and evenness were akin to decreases in temperature of up to 98C. Anthropogenic disturbance and ongoing climate change may interact in complicated ways to shape the structure of assemblages, with hot, arid environments likely to be at greatest risk. © 2015 The Author(s) Published by the Royal Society. All rights reserved

Data from: Climate mediates the effects of disturbance on ant assemblage structure

Many studies have focused on the impacts of climate change on biological assemblages, yet little is known about how climate interacts with other major anthropogenic influences on biodiversity, such as habitat disturbance. Using a unique global database of 1128 local ant assemblages, we examined whether climate mediates the effects of habitat disturbance on assemblage structure at a global scale. Species richness and evenness were associated positively with temperature, and negatively with disturbance. However, the interaction among temperature, precipitation and disturbance shaped species richness and evenness. The effect was manifested through a failure of species richness to increase substantially with temperature in transformed habitats at low precipitation. At low precipitation levels, evenness increased with temperature in undisturbed sites, peaked at medium temperatures in disturbed sites and remained low in transformed sites. In warmer climates with lower rainfall, the effects of increasing disturbance on species richness and evenness were akin to decreases in temperature of up to 9°C. Anthropogenic disturbance and ongoing climate change may interact in complicated ways to shape the structure of assemblages, with hot, arid environments likely to be at greatest risk

Ant assemblage species richness and PIE

This data file includes details of species richness and PIE from pitfall-trapped ant assemblages across the globe. The data includes the following information for 1128 assemblages: Locality_ID - A unique code for each locality; Source - Details of reference source for each dataset; Cluster - Geographic cluster used as a random factor in analyses; Latitude - Latitude provided by authors; Longitude - Longitude provided by authors; Mean annual temperature - Derived from WorldClim; Total annual precipitation - Derived from WorldClim; Temperature range - Derived from WorldClim; Disturbance - Disturbance described by authors; Hemisphere - Derived from Latitude; Continent - Continent provided by authors; Pitfall days - Number of pitfalls multiplied by trapping days; Transect length - Distance from first to last trap in transect; Species richness - Total number of species collected; PIE - Probability of Interspecific Encounter, a measure of species evenness. Further details are provided in the paper