2,988 research outputs found

    Harmonization of International Bankruptcy Law: A United States Perspective

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    The 1994 Inter-American Convention on the Law Applicable to International Contracts, and Trends for the 1990s

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    This Article emphasizes the importance of teaching transnational materials in the conflict of laws class. The rapid development of the global village has increased the importance and need for law students to understand how conflicts issues are resolved throughout the world. A failure to address transnational issues will leave students unprepared for the world, especially the legal marketplace, that they will enter after law school. The author suggests that the traditional study of public international law, regarding the law governing relations between states, as well as the law between states and intergovernmental and nongovernmental organizations, is insufficient for contemporary law students. Law schools would assist their students significantly by encouraging them to look through the \u27second window of private international law as well. Since the 1950s, a substantial body of private international law has developed to address transnational commercial activities. Looking at trends in private international commercial law, this Article focuses on the 1994 Inter-American Convention on the Law Applicable to International Contracts. The author discusses United States concerns regarding the negotiation of this convention and examines its salient features, scope of application, and substantive provisions. The Article also examines similar developments in two United Nations conventions. Finally, the Article concludes by suggesting several trends and opportunities for the late 1990s in private international law

    A comparative study of benchmarking approaches for non-domestic buildings: Part 1 ā€“ Top-down approach

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    Benchmarking plays an important role in improving energy efficiency of non-domestic buildings. A review of energy benchmarks that underpin the UKā€™s Display Energy Certificate (DEC) scheme have prompted necessities to explore the benefits and limitations of using various methods to derive energy benchmarks. The existing methods were reviewed and grouped into top-down and bottom-up approaches based on the granularity of the data used. In the study, two top-down methods, descriptive statistics and artificial neural networks (ANN), were explored for the purpose of benchmarking energy performances of schools. The results were used to understand the benefits of using these benchmarks for assessing energy efficiency of buildings and the limitations that affect the robustness of the derived benchmarks. Compared to the bottom-up approach, top-down approaches were found to be beneficial in gaining insight into how peers perform. The relative rather than absolute feedback on energy efficiency meant that peer pressure was a motivator for improvement. On the other hand, there were limitations with regard to the extent to which the energy efficiency of a building could be accurately assessed using the top-down benchmarks. Moreover, difficulties in acquiring adequate data were identified as a key limitation to using the top-down approach for benchmarking non-domestic buildings. The study suggested that there are benefits in rolling out of DECs to private sector buildings and that there is a need to explore more complex methods to provide more accurate indication of energy efficiency in non-domestic buildings

    Trade-offs between ventilation rates and formaldehyde concentrations in new-build dwellings in the UK

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    The current policies and regulatory frameworks in the construction sector aim to improve energy efficiency of new buildings whilst maintaining acceptable level of indoor environmental quality (IEQ) including indoor air quality (IAQ). In practice, however, there are often important trade-offs between these objectives. The aim of this paper is to investigate the concentrations of volatile organic compounds (VOCs) in a recently built residential block in the UK and the potential trade-offs between ventilation rates and VOCs. Concentration levels of VOCs that are likely to have concentrations higher than their respective exposure limit values (ELVs) in low energy dwellings were measured in five sample apartments in this block during typical weeks in winter and summer using diffusive sampling methods. Whilst most target VOCs had concentrations lower than ELVs, benzene and formaldehyde levels were regularly higher than the limits. Measurement of outdoor concentrations showed that benzene levels were predominantly driven by outdoor sources whilst formaldehyde concentrations were driven by internal sources including construction material and furniture. To investigate how formaldehyde levels can be reduced in a given context determined by typical material used in the industry, two models were developed to calculate the effect of enhanced ventilation on formaldehyde levels and energy efficiency of the apartment with highest formaldehyde. Lack of clear definition of VOC characteristics of building material and ever-increasing use of material with high formaldehyde emission factors such as medium-density fibreboard (MDF) in indoor furniture may contribute to high formaldehyde concentrations in indoor air. The study found that to offset the effect of the existing internal sources in the case study apartment and comply with the best practice ELV for formaldehyde, the ventilation rate should be more than three times the existing rate required in the current Building Regulations, and this can significantly increase energy use. Formaldehyde is currently not regulated in the UK Building Regulations. Given the potential health impact of high formaldehyde concentrations and the empirical evidence, it is necessary to cover formaldehyde in the next edition of the Building Regulations. This study points to the significance of improving the existing regulations and standards to clearly define maximum permissible emission factors for various VOCs in building material and indoor furniture. It is also important to improve source control measures to reduce the concentration of formaldehyde. These measures may be complemented by enhanced ventilation. It is, however, necessary to investigate the implications of enhanced ventilation for energy efficiency

    Anvelopni solitoni i modulacijska nestabilnost u elektronsko-pozitronskoj plazmi

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    We have studied the formation of envelope soliton in a electron-positron plasma. The deduced nonlinear Schrƶdinger equation yields information about the modulational instability of the system for the different ranges of the plasma parameters. It is important to note that the modulational stability depends on the positron-electron density ratio. The theory is applicable to solitary waves in space plasmas.Proučavamo stvaranje anvelopnih solitona u elektronsko-pozitronskoj plazmi. Izvedena nelinearna Schrodingerova jednadžba daje podatke o modulacijskoj nestabilnosti sustava za razna područja parametara plazme. Važno je primijetiti kako modulacijska nestabilnost ovisi o omjeru gustoće elektrona i pozitrona. Teorija se može primijeniti na solitonske valove u svemirskoj plazmi

    Anvelopni solitoni i modulacijska nestabilnost u elektronsko-pozitronskoj plazmi

    Get PDF
    We have studied the formation of envelope soliton in a electron-positron plasma. The deduced nonlinear Schrƶdinger equation yields information about the modulational instability of the system for the different ranges of the plasma parameters. It is important to note that the modulational stability depends on the positron-electron density ratio. The theory is applicable to solitary waves in space plasmas.Proučavamo stvaranje anvelopnih solitona u elektronsko-pozitronskoj plazmi. Izvedena nelinearna Schrodingerova jednadžba daje podatke o modulacijskoj nestabilnosti sustava za razna područja parametara plazme. Važno je primijetiti kako modulacijska nestabilnost ovisi o omjeru gustoće elektrona i pozitrona. Teorija se može primijeniti na solitonske valove u svemirskoj plazmi

    Study protocol: Delayed intervention randomised controlled trial within the Medical Research Council (MRC) Framework to assess the effectiveness of a new palliative care service

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    Background: Palliative care has been proposed to help meet the needs of patients who suffer progressive non-cancer conditions but there have been few evaluations of service development initiatives. We report here a novel protocol for the evaluation of a new palliative care service in this context. Methods/Design: Using the MRC Framework for the Evaluation of Complex Interventions we modelled a new palliative care and neurology service for patients severely affected by Multiple Sclerosis (MS). We conducted qualitative interviews with patients, families and staff, plus a literature review to model and pilot the service. Then we designed a delayed intervention randomised controlled trial to test its effectiveness as part of phase II of the MRC framework. Inclusion criteria for the trial were patients identified by referring clinicians as having unresolved symptoms or psychological concerns. Referrers were advised to use a score of greater than 8 on the Expanded Disability Scale was a benchmark. Consenting patients newly referred to the new service were randomised to either receive the palliative care service immediately (fast-track) or after a 12-week wait (standard best practice). Face to face interviews were conducted at baseline (before intervention), and at 4ā€“6, 10ā€“12 (before intervention for the standard-practice group), 16ā€“ 18 and 22ā€“24 weeks with patients and their carers using standard questionnaires to assess symptoms, palliative care outcomes, function, service use and open comments. Ethics committee approval was granted separately for the qualitative phase and then for the trial. Discussion: We publish the protocol trial here, to allow methods to be reviewed in advance of publication of the results. The MRC Framework for the Evaluation of Complex Interventions was helpful in both the design of the service, methods for evaluation in convincing staff and the ethics committee to accept the trial. The research will provide valuable information on the effects of palliative care among non-cancer patients and a method to evaluate palliative care in this context

    Eulerian time-stepping schemes for the non-stationary Stokes equations on time-dependent domains

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    This article is concerned with the discretisation of the Stokes equations on time- dependent domains in an Eulerian coordinate framework. Our work can be seen as an extension of a recent paper by Lehrenfeld and Olshanskii (ESAIM: M2AN 53(2):585ā€“614, 2019), where BDF-type time-stepping schemes are studied for a parabolic equation on moving domains. For space discretisation, a geometrically unfit- ted finite element discretisation is applied in combination with Nitscheā€™s method to impose boundary conditions. Physically undefined values of the solution at previous time-steps are extended implicitly by means of so-called ghost penalty stabilisations. We derive a complete a priori error analysis of the discretisation error in space and time, including optimal L2(L2)-norm error bounds for the velocities. Finally, the theoretical results are substantiated with numerical examples
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