Municipal Corporations - Financial Powers - Power to Expend Public Funds in Aid of Industry

Taxpayers and voters of Frostburg, Maryland, sought to restrain the holding of an election under enabling legislation to obtain authority both to issue municipal bonds and to devote the proceeds to acquiring a site and contributing to the cost of construction of a building for sale to a private manufacturing company. The chancellor issued an injunction against the holding of such election on the ground that the enabling act, in authorizing the use of public funds for private purposes, was unconstitutional. On appeal, held, reversed. The location of new industry in furnishing employment and increasing the financial well being of the community serves a public purpose. City of Frostburg v. Jenkins, (Md. 1957) 136 A. (2d) 852

Real Property - Adverse Possession - Between Cotenants

C. V. James and his wife and children owned certain property as tenants in common. In 1931 defendant Fallon recovered a judgment against C. V. James, and the land was sold by a sheriff under execution. Fallon became the purchaser at the sheriff\u27s sale and was issued a sheriff\u27s deed purporting to convey the entire interest in the property. Thereafter he was in the actual, visible, distant, hostile, exclusive, continuous and uninterrupted possession of the land and paid all taxes thereon. Plaintiffs, the wife and children of James, brought this action to determine the ownership of the property. Fallon claimed title by adverse possession under an eighteen-year statute of limitations. The lower court held that the plaintiffs, as tenants in common, were the owners of a ¼ interest in the land and that defendant had claim only to the ¾ interest formerly owned by the judgment debtor. On appeal, held, affirmed. The sheriff\u27s deed passed to defendant only such interest as was owned by the judgment debtor, making him a tenant in common with plaintiffs. The statute of limitations does not begin to run against cotenants until an ouster of the cotenants has been established, and under the facts presented Fallon did nothing amounting to an ouster. Fallon v. Davidson, (Colo. 1958) 320 P. (2d) 976

Future Interests - Rule Against Perpetuities - Recent Statutory Amendment in New York

After 128 years of criticism and confusion and enormous amounts of litigation, New York has amended its statutory rule against perpetuities. The old rule provided that the absolute power of alienation could not be suspended for longer, than two lives in being at the creation of the estate plus a minority exception in some cases. Under the new rule the absolute power of alienation can be suspended for a period measured by any number of lives in being at the creation of the estate so long as they are not so designated or so numerous as to make proof of their end unreasonably difficult. There is, however, still no period in gross provided for in the New York statutes. N.Y. Sess. Laws 1958 (McKinney) chapters 152 and 153

Mapping biodiversity value worldwide: combining higher-taxon richness from different groups

Maps of large-scale biodiversity are urgently needed to guide conservation, and yet complete enumeration of organisms is impractical at present. One indirect approach is to measure richness at higher taxonomic ranks, such as families. The difficulty is how to combine information from different groups on numbers of higher taxa, when these taxa may in effect have been defined in different ways, particularly for more distantly related major groups. In this paper, the regional family richness of terrestrial and freshwater seed plants, amphibians, reptiles and mammals is mapped worldwide by combining: (i) absolute family richness; (ii) proportional family richness; and (iii) proportional family richness weighted for the total species richness in each major group. The assumptions of the three methods and their effects on the results are discussed, although for these data the broad pattern is surprisingly robust with respect to the method of combination. Scores from each of the methods of combining families are used to rank the top five richness hotspots and complementary areas, and hotspots of endemism are mapped by unweighted combination of range-size rarity scores

Balancing Queueing Systems With Excess Demand

In a rough economic environment and increased competition, one issue critical to many businesses is to achieve an optimum balance between supply and demand. Double-ended queuing structure, where demand and supply occur simultaneously, can be utilized to model various manufacturing and service activities. By associating costs per time unit due to a unit of excess of supply or demand, the total cost will include now costs due to imbalance of demand and supply. The authors examine the queuing behavior and how to minimize the above total cost by advanced planning aimed to hold imbalance costs at a minimum.In this paper, the main focus will be on situations where a stochastic system has become unstable due to demand exceeding supply. To determine how sensitive optimal solutions are to changes in model parameters, for each policy, either decreasing demand or increasing supply, exact optimal solutions were found for a large number of scenarios and then used this scenarios database to fit the best possible regression model. The paper ends illustrating the use of the model to research funding where typically proposals compete for scarce funding resources

Observation of playa salts as nuclei in orographic wave clouds

During the Ice in Clouds Experiment-Layer Clouds (ICE-L), dry lakebed, or playa, salts from the Great Basin region of the United States were observed as cloud nuclei in orographic wave clouds over Wyoming. Using a counterflow virtual impactor in series with a single-particle mass spectrometer, sodium-potassium-magnesium-calcium-chloride salts were identified as residues of cloud droplets. Importantly, these salts produced similar mass spectral signatures to playa salts with elevated cloud condensation nuclei (CCN) efficiencies close to sea salt. Using a suite of chemical characterization instrumentation, the playa salts were observed to be internally mixed with oxidized organics, presumably produced by cloud processing, as well as carbonate. These salt particles were enriched as residues of large droplets (>19 μm) compared to smaller droplets (>7 μm). In addition, a small fraction of silicate-containing playa salts were hypothesized to be important in the observed heterogeneous ice nucleation processes. While the high CCN activity of sea salt has been demonstrated to play an important role in cloud formation in marine environments, this study provides direct evidence of the importance of playa salts in cloud formation in continental North America has not been shown previously. Studies are needed to model and quantify the impact of playas on climate globally, particularly because of the abundance of playas and expected increases in the frequency and intensity of dust storms in the future due to climate and land use changes

Investigation of a Large Gap Cold Plasma Reactor for Continuous In-package Decontamination of Fresh Strawberries and Spinach

The aim of this work was to investigate the efficacy of a large gap atmospheric cold plasma (ACP) generated with an open-air high-voltage dielectric barrier discharge (DBD) pilot-scale reactor, operated in either static (batch) or continuous mode for produce decontamination and quality retention. Significant reductions in the bacterial populations inoculated on the strawberries and spinach were obtained after the static mode of ACP treatment with 2.0 and 2.2 log10 CFU/ml reductions for E. coli and 1.3 and 1.7 log10 CFU/ml reductions for L. innocua, respectively. Continuous treatment was effective against L. innocua inoculated on strawberries, with 3.8 log10 CFU/ml reductions achieved. No significant differences in colour, firmness, pH or total soluble solids (TSS) was observed between control and ACP-treated samples with the effects of treatment retained during the shelf-life period. The pilot-scale atmospheric air plasma reactor retained the strawberry quality characteristics in tandem with useful antimicrobial efficacy. Industrial relevance This in-package plasma technology approach is a low-power, water-free, non-thermal, post-package treatment. Generating cold plasma discharges inside food packages achieved useful antimicrobial effects on fresh produce. Depending on the bacterial type, produce and mode of ACP treatment significant reductions in the populations of pathogenic microorganisms attached to the fresh produce was achieved within 2.5 min of treatment. The principal technical advantages include contaminant control, quality retention, mitigation of re-contamination and crucially the retention of bactericidal reactive gas molecules in the food package volume, which then revert back to the original gas

Miniaturized data loggers and computer programming improve seabird risk and damage assessments for marine oil spills in Atlantic Canada

Obtaining useful information on marine birds that can aid in oil spill (and other hydrocarbon release) risk and damage assessments in offshore environments is challenging. Technological innovations in miniaturization have allowed archival data loggers to be deployed successfully on marine birds vulnerable to hydrocarbons on water. A number of species, including murres (both Common, Uria aalge, and Thick-billed, U. lomvia) have been tracked using geolocation devices in eastern Canada, increasing our knowledge of the seasonality and colony-specific nature of their susceptibility to oil on water in offshore hydrocarbon production areas and major shipping lanes. Archival data tags are starting to resolve questions around behaviour of vulnerable seabirds at small spatial scales relevant to oil spill impact modelling, specifically to determine the duration and frequency at which birds fly at sea. Advances in data capture methods using voice activated software have eased the burden on seabird observers who are collecting increasingly more detailed information on seabirds during ship-board and aerial transects. Computer programs that integrate seabird density and bird behaviour have been constructed, all with a goal of creating more credible seabird oil spill risk and damage assessments. In this paper, we discuss how each of these technological and computing innovations can help define critical inputs into seabird risk and damage assessments, and when combined, can provide a more realistic understanding of the impacts to seabirds from any hydrocarbon release

Towards an assessment of on-farm niches for improved forages in Sud-Kivu, DR Congo

Inadequate quantity and quality of livestock feed is a persistent constraint to productivity for mixed crop-livestock farming in eastern Democratic Republic of Congo. To assess on-farm niches of improved forages, demonstration trials and participatory on-farm research were conducted in four different sites. Forage legumes included Canavalia brasiliensis (CIAT 17009), Stylosanthes guianensis (CIAT 11995) and Desmodium uncinatum (cv. Silverleaf), while grasses were Guatemala grass (Tripsacum andersonii), Napier grass (Pennisetum purpureum) French Cameroon, and a local Napier line. Within the first six months, forage legumes adapted differently to the four sites with little differences among varieties, while forage grasses displayed higher variability in biomass production among varieties than among sites. Farmers’ ranking largely corresponded to herbage yield from the first cut, preferring Canavalia, Silverleaf desmodium and Napier French Cameroon. Choice of forages and integration into farming systems depended on land availability, soil erosion prevalence and livestock husbandry system. In erosion prone sites, 55-60% of farmers planted grasses on field edges and 16-30% as hedgerows for erosion control. 43% of farmers grew forages as intercrop with food crops such as maize and cassava, pointing to land scarcity. Only in the site with lower land pressure, 71% of farmers grew legumes as pure stand. When land tenure was not secured and livestock freely roaming, 75% of farmers preferred to grow annual forage legumes instead of perennial grasses. Future research should develop robust decision support for spatial and temporal integration of forage technologies into diverse smallholder cropping systems and agro-ecologies.</p

Asymétrie d’information et marchés financiers : une synthèse de la littérature récente

Cet article est une synthèse des recherches récentes en matière d’asymétrie d’informations sur les marchés financiers. L’impact de différentes hypothèses sur l’existence et l’efficience informationnelle des équilibres est étudié. Le cas de la concurrence parfaite est d’abord analysé (Grossman et Stiglitz, 1980). Puis la concurrence imparfaite est analysée. On distingue deux cas, selon que le bruit qui empêche le prix d’être parfaitement révélateur provient d’une offre exogène (KyIe, 1985, 1989), ou d’une dotation aléatoire des agents informés (Glosten, 1989; Bhattacharya et Spiegel, 1990; Bossaerts et Hughson, 1991). Dans le premier cas, l’équilibre existe toujours. Dans le second cas, il n’existe que si le bruit est assez élevé ou si le support de sa distribution est borné.The impact of different hypotheses on the existence and informativeness of rational expectations equilibria is analyzed within a simple synthetic model. The case of perfect competition is first analyzed (Grossman and Stiglitz, 1980). Second imperfect competition with exogenous noise trading is studied (KyIe 1985, 1989). Informational efficiency is lower than in the previous case, because of the strategic behaviour of the insider. Third, imperfect competition without noise trader, but with unknown random endowments of the informed agent is analyzed (Glosten, 1989; Bhattacharya and Spiegel, 1990; Bossaerts and Hughson, 1991). In contrast with the previous case, equilibrium exists only if there is enough noise