Concrete Conflict: An Examination of the Israeli Security Barrier

On May 14, 1948 David Ben Gurrion declared the independence of the state of Israel. This event forever changed the climate of the Middle East. Today, the conflict born 64 years ago between Israel and Palestine continues on. Since 1948, the conflict has evolved to become extremely complex, encompassing all aspects of Israeli and Palestinian life. Throughout the years the conflict between the two groups has taken on many shapes. From terrorist attacks to failed peace negotiations the Israeli-Palestinian conflict has been the setting for one of the most well-known and controversial battles of the modern world

Chan v. Korean Air Lines, Ltd.: Skirting the Legislative History of the Warsaw Convention

On September 1, 1983, over the Sea of Japan, a Soviet Union military aircraft destroyed a Korean Air Lines Boeing 747 en route from Kennedy Airport in New York to Seoul, South Korea. All 269 persons on board the plane were killed. The Warsaw Convention ( Convention ), a multilateral treaty governing the international carriage of passengers, baggage, and cargo by air, provides a per passenger damage limitation for personal injury or death. The Convention further provides that passenger tickets must include notice of this limitation, and a private accord among airlines known as the Montreal Agreement ( Agreement ) states that this notice shall be in print size no smaller than 10-point type. In Chan v. Korean Air Lines, Ltd.,\u27 the United States Supreme Court held that international air carriers do not lose the benefit of the Warsaw Convention\u27s damages limitation if they fail to provide notice of that limitation. Accordingly, the liability of Korean Air Lines was limited to $75,000 per passenger. This Note first explores the majority and concurring opinions in Chan and concludes that the Court erred in enabling a carrier to benefit from the Warsaw Convention\u27s damage limitation when the carrier has failed to warn its passengers of that limitation. This Note further discusses how the Court created a confusing and disturbing precedent by failing to interpret the Montreal Agreement in conjunction with the Warsaw Convention, and by wrongly relying on a literal reading of the Warsaw Convention. for its conclusions. Finally, this Note asserts that the concurrence in Chan correctly resolved the fundamental issue by examining the drafting history of the Convention and concluding that an international air carrier cannot receive the benefit of the Convention\u27s damage limitation if it fails to provide adequate notice of that limitation on passenger tickets. The concurrence failed, however, to appreciate the relationship between the Montreal Agreement and the Convention and replaced a clear standard of adequate notice with an unclear standard

Chan v. Korean Air Lines, Ltd.: Skirting the Legislative History of the Warsaw Convention

On September 1, 1983, over the Sea of Japan, a Soviet Union military aircraft destroyed a Korean Air Lines Boeing 747 en route from Kennedy Airport in New York to Seoul, South Korea. All 269 persons on board the plane were killed. The Warsaw Convention ( Convention ), a multilateral treaty governing the international carriage of passengers, baggage, and cargo by air, provides a per passenger damage limitation for personal injury or death. The Convention further provides that passenger tickets must include notice of this limitation, and a private accord among airlines known as the Montreal Agreement ( Agreement ) states that this notice shall be in print size no smaller than 10-point type. In Chan v. Korean Air Lines, Ltd.,\u27 the United States Supreme Court held that international air carriers do not lose the benefit of the Warsaw Convention\u27s damages limitation if they fail to provide notice of that limitation. Accordingly, the liability of Korean Air Lines was limited to $75,000 per passenger. This Note first explores the majority and concurring opinions in Chan and concludes that the Court erred in enabling a carrier to benefit from the Warsaw Convention\u27s damage limitation when the carrier has failed to warn its passengers of that limitation. This Note further discusses how the Court created a confusing and disturbing precedent by failing to interpret the Montreal Agreement in conjunction with the Warsaw Convention, and by wrongly relying on a literal reading of the Warsaw Convention. for its conclusions. Finally, this Note asserts that the concurrence in Chan correctly resolved the fundamental issue by examining the drafting history of the Convention and concluding that an international air carrier cannot receive the benefit of the Convention\u27s damage limitation if it fails to provide adequate notice of that limitation on passenger tickets. The concurrence failed, however, to appreciate the relationship between the Montreal Agreement and the Convention and replaced a clear standard of adequate notice with an unclear standard

Cost of saving natural gas through efficiency programs funded by utility customers: 2012–2017

This study estimates the cost of saving a therm of natural gas from energy efficiency programs funded by utility customers during the period 2012 to 2017. Berkeley Lab researchers compiled and analyzed efficiency program data reported by investor-owned utilities and other program administrators in a dozen states representative of the four U.S. Census regions — Arkansas, California, Connecticut, Iowa, Massachusetts, Michigan, Minnesota, New Jersey, New York, Oklahoma, Rhode Island and Utah. Depending on the year, the dataset accounts for about 50 percent to 70 percent of annual national spending on natural gas efficiency programs. The estimated cost of saving natural gas during the study period is $0.40 per therm. The analysis also includes estimates of the program administrator cost of saved energy for three core sectors for natural gas: commercial and industrial, residential, and low-income households. It aggregates these sectors to provide regional and national values. Our metrics include savings-weighted averages, unweighted medians, and interquartile ranges (25th and 75th percentiles) of the levelized program administrator cost of saving gas, in constant 2017 dollars. In addition, the study analyzes cost trends during the study period, finding that average program costs trended downward. The U.S. Department of Energy’s Building Technologies Office supported this work

Applying Non-Energy Impacts from Other Jurisdictions in Cost-Benefit Analyses of Energy Efficiency Programs: Resources for States for Utility Customer-Funded Programs

Avoided energy and capacity costs are the primary yardstick utilities use to determine which energy efficiency programs are cost-effective for their customers. But sometimes "non-energy impacts" — not commonly recognized as directly associated with energy generation, transmission and distribution — represent substantial benefits, such as improving comfort, air quality and public health.Considering whether and how to include non-energy impacts is an important part of cost-benefit analyses for these programs. This report offers practical considerations for deciding which non-energy impacts to include and how to apply values or methods from other jurisdictions.Researchers reviewed studies quantifying non-energy impacts used in 30 states and applied a five-point system to indicate transferability of a value or method from each study for 16 categories of non-energy impacts:Water resource costs and benefitsOther fuels costs and benefitsAvoided environmental compliance costsEnvironmental impactsProductivityHealth and safety Asset valueEnergy and/or capacity price suppression effectsAvoided costs of compliance with Renewable Portfolio Standard requirementsAvoided credit and collection costsAvoided ancillary servicesComfortEconomic development and job impactsPublic health impactsEnergy security impactsIncreased reliabilityThe U.S. Department of Energy’s Building Technologies Office supported this work

gem-Dibromocyclopropanes and enzymatically derived cis-1,2-dihydrocatechols as building blocks in alkaloid synthesis

The application of the title building blocks, the 6,6-dibromobicyclo[3.1.0]hexanes and the cis-1,2-dihydrocatechols, to the total synthesis of crinine and lycorinine alkaloids is described.We thank the Australian Research Council and the Institute of Advanced Studies for generous financial support