The Interpretation of Surface Easements in Severance Deeds as a Limit on Hydraulic Fracturing Practices

Hydraulic fracturing has driven a boom in natural gas production in the Marcellus Shale. While providing a growing source of domestic energy, this boom also raises signicant environmental concerns. Many of the impacts of hy draulic fracturing predominantly affect the inhabitants of the property where the drilling occurs. Yet when those inhabitants own only the surface estate, they have relatively little influence over whether and how the drilling occurs and will not profit from the gas extraction. This article provides a jurisdictional case stud4 set in West Virginia to assist in understanding the nuances relevant to an interpretation of the scope of express and implied surface easements pertinent to mineral extraction. West Virginia takes a unique approach to the accommodation doctrine. It permits a surface ovner to argue that certain overly burdensome practices may not have been contemplated by the parties to the original severance deed and easement, thus weakening the likelihood of their propriety and giving surface ovners leverage. Depending on the tlpe of easement at issue, the analysis can include a review of the burden to the surface, the nature of surface uses, the necessity of a practice, the compatibility of a practice, and/or contractual intention

Population allocation at the housing unit level: estimates around underground natural gas storage wells in PA, OH, NY, WV, MI, and CA

Background Spatially accurate population data are critical for determining health impacts from many known risk factors. However, the utility of the increasing spatial resolution of disease mapping and environmental exposures is limited by the lack of receptor population data at similar sub-census block spatial scales. Methods Here we apply an innovative method (Population Allocation by Occupied Domicile Estimation – ABODE) to disaggregate U.S. Census populations by allocating an average person per household to geospatially-identified residential housing units (RHU). We considered two possible sources of RHU location data: address point locations and building footprint centroids. We compared the performance of ABODE with the common proportional population allocation (PPA) method for estimating the nighttime residential populations within 200 m radii and setback areas (100 – 300 ft) around active underground natural gas storage (UGS) wells (n = 9834) in six U.S. states. Results Address location data generally outperformed building footprint data in predicting total counts of census residential housing units, with correlations ranging from 0.67 to 0.81 at the census block level. Using residentially-sited addresses only, ABODE estimated upwards of 20,000 physical households with between 48,126 and 53,250 people living within 200 m of active UGS wells – likely encompassing the size of a proposed UGS Wellhead Safety Zone. Across the 9834 active wells assessed, ABODE estimated between 5074 and 10,198 more people living in these areas compare to PPA, and the difference was significant at the individual well level (p = < 0.0001). By either population estimation method, OH exhibits a substantial degree of hyperlocal land use conflict between populations and UGS wells – more so than other states assessed. In some rare cases, population estimates differed by more than 100 people for the small 200 m2 well-areas. ABODE’s explicit accounting of physical households confirmed over 50% of PPA predictions as false positives indicated by non-zero predictions in areas absent physical RHUs. Conclusions Compared to PPA – in allocating identical population data at sub-census block spatial scales –ABODE provides a more precise population at risk (PAR) estimate with higher confidence estimates of populations at greatest risk. 65% of UGS wells occupy residential urban and suburban areas indicating the unique land use conflicts presented by UGS systems that likely continue to experience population encroachment. Overall, ABODE confirms tens of thousands of homes and residents are likely located within the proposed UGS Wellhead Safety Zone – and in some cases within state’s oil and gas well surface setback distances – of active UGS wells

Signs and symptoms of temporomandibular disorders and oral parafunctions in urban Saudi arabian adolescents: a research report

BACKGROUND: The aim of this study was to evaluate the prevalence of signs and symptoms of temporomandibular disorders (TMD) and oral parafunction habits among Saudi adolescents in the permanent dentition stage. METHODS: A total of 385 (230 females and 155 males) school children age 12–16, completed a questionnaire and were examined clinically. A stratified selection technique was used for schools allocation. RESULTS: The results showed that 21.3% of the subjects exhibited at least one sign of TMD and females were generally more affected than males. Joint sounds were the most prevalent sign (13.5%) followed by restricted opening (4.7%) and opening deviation (3.9%). The amplitude of mouth opening, overbite taken into consideration, was 46.5 mm and 50.2 mm in females and males respectively. TMJ pain and muscle tenderness were rare (0.5%). Reported symptoms were 33%, headache being the most frequent symptom 22%, followed by pain during chewing 14% and hearing TMJ noises 8.7%. Difficulty during jaw opening and jaw locking were rare. Lip/cheek biting was the most common parafunction habit (41%) with females significantly more than males, followed by nail biting (29%). Bruxism and thumb sucking were only 7.4% and 7.8% respectively. CONCLUSION: The prevalence of TMD signs were 21.3% with joint sounds being the most prevalent sign. While TMD symptoms were found to be 33% as, with headache being the most prevalent. Among the oral parafunctions, lip/cheek biting was the most prevalent 41% followed by nail biting 29%

Hunger Artists: Yeast Adapted to Carbon Limitation Show Trade-Offs under Carbon Sufficiency

As organisms adaptively evolve to a new environment, selection results in the improvement of certain traits, bringing about an increase in fitness. Trade-offs may result from this process if function in other traits is reduced in alternative environments either by the adaptive mutations themselves or by the accumulation of neutral mutations elsewhere in the genome. Though the cost of adaptation has long been a fundamental premise in evolutionary biology, the existence of and molecular basis for trade-offs in alternative environments are not well-established. Here, we show that yeast evolved under aerobic glucose limitation show surprisingly few trade-offs when cultured in other carbon-limited environments, under either aerobic or anaerobic conditions. However, while adaptive clones consistently outperform their common ancestor under carbon limiting conditions, in some cases they perform less well than their ancestor in aerobic, carbon-rich environments, indicating that trade-offs can appear when resources are non-limiting. To more deeply understand how adaptation to one condition affects performance in others, we determined steady-state transcript abundance of adaptive clones grown under diverse conditions and performed whole-genome sequencing to identify mutations that distinguish them from one another and from their common ancestor. We identified mutations in genes involved in glucose sensing, signaling, and transport, which, when considered in the context of the expression data, help explain their adaptation to carbon poor environments. However, different sets of mutations in each independently evolved clone indicate that multiple mutational paths lead to the adaptive phenotype. We conclude that yeasts that evolve high fitness under one resource-limiting condition also become more fit under other resource-limiting conditions, but may pay a fitness cost when those same resources are abundant

Medicinal importance of grapefruit juice and its interaction with various drugs

Grapefruit juice is consumed widely in today's health conscious world as a protector against cardiovascular diseases and cancers. It has however, been found to be an inhibitor of the intestinal cytochrome P – 450 3A4 system, which is responsible for the first pass metabolism of many drugs. The P – glycoprotein pump, found in the brush border of the intestinal wall which transports many of these cytochrome P – 450 3A4 substrates, has also been implicated to be inhibited by grapefruit juice. By inhibiting these enzyme systems, grapefruit juice alters the pharmacokinetics of a variety of medications, leading to elevation of their serum concentrations. Most notable are its effects on the calcium channel antagonist and the statin group of drugs. In the case of many drugs, the increased serum concentration has been found to be associated with increased frequency of dose dependent adverse effects. In this review, we have discussed the phytochemistry of grapefruit juice, the various drugs involved in the drug – grapefruit juice eraction with their mechanisms of action and have presented the clinical implications of these interactions

The Interpretation of Surface Easements in Severance Deeds as a Limit on Hydraulic Fracturing Practices

Hydraulic fracturing has driven a boom in natural gas production in the Marcellus Shale. While providing a growing source of domestic energy, this boom also raises signicant environmental concerns. Many of the impacts of hy draulic fracturing predominantly affect the inhabitants of the property where the drilling occurs. Yet when those inhabitants own only the surface estate, they have relatively little influence over whether and how the drilling occurs and will not profit from the gas extraction. This article provides a jurisdictional case stud4 set in West Virginia to assist in understanding the nuances relevant to an interpretation of the scope of express and implied surface easements pertinent to mineral extraction. West Virginia takes a unique approach to the accommodation doctrine. It permits a surface ovner to argue that certain overly burdensome practices may not have been contemplated by the parties to the original severance deed and easement, thus weakening the likelihood of their propriety and giving surface ovners leverage. Depending on the tlpe of easement at issue, the analysis can include a review of the burden to the surface, the nature of surface uses, the necessity of a practice, the compatibility of a practice, and/or contractual intention