The Public Trust Doctrine and Natural Law: Emanations Within a Penumbra

In American jurisprudence, the public trust doctrine emerged as a means of protecting certain limited environmental interests, such as coastal waterways and fishing areas, which were preserved for the benefit of the public and distinguished from grants of private ownership. However, modern scholars have called for an expansive application of the public trust doctrine, citing the growing inventory of “changing public needs” in the environmental context, such as the need for improved air and water quality, and the conservation of natural landscape. This Article examines the history and scope of the public trust doctrine to determine how modern resource management fits within the doctrine’s development under the Constitution and common law. Such an examination is incomplete without reviewing the important principles of Natural Law underlying the original doctrine. In the end, the Article concludes that modern trust expansion should be limited within the ancient values of principled economic reasoning

The Public Trust Doctrine and Natural Law: Emanations with a Penumbra

In American jurisprudence, the public trust doctrine emerged as a means of protecting certain limited environmental interests, such as coastal waterways and fishing areas, which were preserved for the benefit of the public and distinguished from grants of private ownership. Modern scholars have, however, called for an expansive application of the public trust doctrine - citing, as such, the growing inventory of changing public needs in the environmental context, such as the need for improved air and water quality, and the conservation of natural landscape. This Article examines the history and scope of the public trust doctrine in order to determine how modern resource management fits within the doctrine\u27s development under the Constitution and the Common Law. Such an examination is incomplete without reviewing the foundational Principles of Natural Law underlying the original doctrine. In the end, the Article concludes that modern trust expansion should be limited within the ancient values of principled economic reasoning

The Public Trust Doctrine and Natural Law: Emanations with a Penumbra

In American jurisprudence, the public trust doctrine emerged as a means of protecting certain limited environmental interests, such as coastal waterways and fishing areas, which were preserved for the benefit of the public and distinguished from grants of private ownership. Modern scholars have, however, called for an expansive application of the public trust doctrine - citing, as such, the growing inventory of changing public needs in the environmental context, such as the need for improved air and water quality, and the conservation of natural landscape. This Article examines the history and scope of the public trust doctrine in order to determine how modern resource management fits within the doctrine\u27s development under the Constitution and the Common Law. Such an examination is incomplete without reviewing the foundational Principles of Natural Law underlying the original doctrine. In the end, the Article concludes that modern trust expansion should be limited within the ancient values of principled economic reasoning

Response of Soybean Grown on a Claypan Soil in Southeastern Kansas to the Residual of Different Plant Nutrient Sources and Tillage

The residual effects of turkey litter and fertilizer amendments applied in previous years had little effect on the yield, yield components, and dry matter production of the following soybean crop grown in 2014

Selective and Differential Feeding on Marine Prokaryotes by Mucous Mesh Feeders

Microbial mortality impacts the structure of food webs, carbon flow, and the interactions that create dynamic patterns of abundance across gradients in space and time in diverse ecosystems. In the oceans, estimates of microbial mortality by viruses, protists, and small zooplankton do not account fully for observations of loss, suggesting the existence of underappreciated mortality sources. We examined how ubiquitous mucous mesh feeders (i.e. gelatinous zooplankton) could contribute to microbial mortality in the open ocean. We coupled capture of live animals by blue-water diving to sequence-based approaches to measure the enrichment and selectivity of feeding by two coexisting mucous grazer taxa (pteropods and salps) on numerically dominant marine prokaryotes. We show that mucous mesh grazers consume a variety of marine prokaryotes and select between coexisting lineages and similar cell sizes. We show that Prochlorococcus may evade filtration more than other cells and that planktonic archaea are consumed by macrozooplanktonic grazers. Discovery of these feeding relationships identifies a new source of mortality for Earth\u27s dominant marine microbes and alters our understanding of how top-down processes shape microbial community and function

Host-specific symbioses and the microbial prey of a pelagic tunicate (Pyrosoma atlanticum)

Pyrosomes are widely distributed pelagic tunicates that have the potential to reshape marine food webs when they bloom. However, their grazing preferences and interactions with the background microbial community are poorly understood. This is the first study of the marine microorganisms associated with pyrosomes undertaken to improve the understanding of pyrosome biology, the impact of pyrosome blooms on marine microbial systems, and microbial symbioses with marine animals. The diversity, relative abundance, and taxonomy of pyrosome-associated microorganisms were compared to seawater during a Pyrosoma atlanticum bloom in the Northern California Current System using high-throughput sequencing of the 16S rRNA gene, microscopy, and flow cytometry. We found that pyrosomes harbor a microbiome distinct from the surrounding seawater, which was dominated by a few novel taxa. In addition to the dominant taxa, numerous more rare pyrosome-specific microbial taxa were recovered. Multiple bioluminescent taxa were present in pyrosomes, which may be a source of the iconic pyrosome luminescence. We also discovered free-living marine microorganisms in association with pyrosomes, suggesting that pyrosome feeding impacts all microbial size classes but preferentially removes larger eukaryotic taxa. This study demonstrates that microbial symbionts and microbial prey are central to pyrosome biology. In addition to pyrosome impacts on higher trophic level marine food webs, the work suggests that pyrosomes also alter marine food webs at the microbial level through feeding and seeding of the marine microbial communities with their symbionts. Future efforts to predict pyrosome blooms, and account for their ecosystem impacts, should consider pyrosome interactions with marine microbial communities

Diverse and Variable Community Structure of Picophytoplankton across the Laurentian Great Lakes

The Laurentian Great Lakes provide economic support to millions of people, drive biogeochemical cycling, and are an important natural laboratory for characterizing the fundamental components of aquatic ecosystems. Small phytoplankton are important contributors to the food web in much of the Laurentian Great Lakes. Here, for the first time, we reveal and quantify eight phenotypically distinct picophytoplankton populations across the Lakes using a multilaser flow cytometry approach, which distinguishes cells based on their pigment phenotype. The distributions and diversity of picophytoplankton flow populations varied across lakes and depths, with Lake Erie standing out with the highest diversity. By sequencing sorted cells, we identified several distinct lineages of Synechococcales spanning Subclusters 5.2 and 5.3. Distinct genotypic clusters mapped to phenotypically similar flow populations, suggesting that there may not be a clear one-to-one mapping between genotypes and phenotypes. This suggests genome-level differentiation between lakes but some degree of phenotypic convergence in pigment characteristics. Our results demonstrate that ecological selection for locally adapted populations may outpace homogenization by physical transport in this interconnected system. Given the reliance of the Lakes on in situ primary production as a source for organic carbon, this work sets the foundation to test how the community structure of small primary producers corresponds to biogeochemical and food web functions of the Great Lakes and other freshwater systems

Performance of an environmental test to detect Mycobacterium bovis infection in badger social groups

A study by Courtenay and others (2006) demonstrated that the probability of detecting Mycobacterium bovis by PCR in soil samples from the spoil heaps of main badger setts correlated with the prevalence of excretion (infectiousness) of captured badgers belonging to the social group. It has been proposed that such a test could be used to target badger culling to setts containing infectious animals (Anon 2007). This short communication discusses the issues surrounding this concept, with the intention of dispelling any misconceptions among relevant stakeholders (farmers, policy makers and conservationists)

Parameterized Complexity of the k-anonymity Problem

The problem of publishing personal data without giving up privacy is becoming increasingly important. An interesting formalization that has been recently proposed is the $k$-anonymity. This approach requires that the rows of a table are partitioned in clusters of size at least $k$ and that all the rows in a cluster become the same tuple, after the suppression of some entries. The natural optimization problem, where the goal is to minimize the number of suppressed entries, is known to be APX-hard even when the records values are over a binary alphabet and $k=3$, and when the records have length at most 8 and $k=4$ . In this paper we study how the complexity of the problem is influenced by different parameters. In this paper we follow this direction of research, first showing that the problem is W[1]-hard when parameterized by the size of the solution (and the value $k$). Then we exhibit a fixed parameter algorithm, when the problem is parameterized by the size of the alphabet and the number of columns. Finally, we investigate the computational (and approximation) complexity of the $k$-anonymity problem, when restricting the instance to records having length bounded by 3 and $k=3$. We show that such a restriction is APX-hard.Comment: 22 pages, 2 figure

Dual captures of Colorado rodents: implications for transmission of hantaviruses.

We analyzed dual-capture data collected during longitudinal studies monitoring transmission and persistence of Sin Nombre virus in rodents in Colorado. Our data indicate that multiple captures (two or more rodents captured in a single trap) may not be random, as indicated by previous studies, but rather the result of underlying, species-specific social behavior or cohesiveness. In the pairs we captured, most often, rodents were of the same species, were male, and could be recaptured as pairs. Therefore, dual captures of rodents, which are unusual but not rare, tend to occur among certain species, and appear to be nonrandom, group-foraging encounters. These demographic and ecologic characteristics may have implications for the study of the transmission of hantaviruses