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A New Environment for Climate Change Litigation
With the federal executive branch backtracking from Obama-era climate change programs, the judicial branch may be increasingly receptive to novel forms of climate change litigation. In Juliana v. United States, Case No. 6:15-cv-01517-TC (D. Or.), a small group of young people and a climate scientist representing future generations are suing the federal government for violating their asserted constitutional rights to a stable climate system. In November of last year, U.S. District of Oregon Judge Ann Aiken denied a motion to dismiss that complaint.[1] Last month, Judge Aiken fully adopted the recommendation of Magistrate Judge Thomas Coffin to deny a related motion for interlocutory appeal.[2] Judge Coffin had found that the merits of the Juliana plaintiffs' admittedly groundbreaking claims were so strong that the denial of the motion to dismiss was not subject to reasonable difference of opinion. Both the denial of the motion to dismiss and the denial of the interlocutory appeal represent an unusual judicial receptiveness to climate change litigation. The fate of Juliana and other cases like it is worth watching closely as the federal judiciary reacts to the new administration.
Famous climate change cases of the recent past have tended to involve statutory disputes rather than constitutional law or even common law (e.g. tort) disputes. For example, in Massachusetts v. EPA, 549 U.S. 497 (2007), the U.S. Supreme Court first held that EPA has the authority to regulate greenhouse gas ("GHG") emissions under the Clean Air Act. The Court later narrowed that decision in Utility Air Regulatory Group v. EPA, 134 S. Ct. 2427 (2014), holding that EPA's regulations reaching businesses exclusively on account of their GHG emissions were not authorized by the Clean Air Act. The pending case of West Virginia v. EPA, No. 15-1362 (S. Ct.), asks, among other things, whether a previously unused section of the Clean Air Act can support the Clean Power Plan's requirement that power plants bring about external forms of energy savings, or possibly just shut down, in order to meet emissions targets. Back when EPA was eager to stretch its statutory authority to tackle the immensely complex problem of climate change, these cases were potential game changers for industry. In the present political climate, however, these cases may have short-lived effect.
Today, other forms of litigation related to climate change may have a greater likelihood of directly affecting industry in the near future. These may range from class action tort claims to NEPA challenges against individual projects to investor securities lawsuits.[3] Notably, across the full spectrum of these cases, basic climate change science is generally readily accepted.[4] Though doubts about the fundamentals of climate science — the occurrence of climate change and its cause by human activities — may still exist in the realm of the public discourse, they are not often entertained by the courts. From NEPA documents to judicial decisions, the international scientific consensus that climate change is happening, that it is both caused by and likely preventable through human activities, and that it presents an actual perilous risk, is taken seriously. The obstacles to judicial relief are a matter of who can be held liable and who has the authority or responsibility to do something about it.
Juliana represents a new type of climate change litigation, in which claims are brought against the federal government grounded in constitutional rights and/or the public trust doctrine. The plaintiffs in Juliana are coordinated by a nonprofit organization called Our Children's Trust, promoting a theory of the public trust doctrine most visibly advanced by Professor Mary Wood at the University of Oregon.[5] Our Children's Trust has brought a series of similar cases linked by their theory of the public trust doctrine. So far, Judge Aiken (a graduate of the University of Oregon Law School) appears to be their most receptive audience.
In November 2016, Judge Aiken denied the government and industry intervenors' motion to dismiss the plaintiffs' complaint.[6] The question at the motion to dismiss stage is whether, assuming all a plaintiff's factual allegations to be true, the plaintiff could possibly be entitled to legal relief. Judge Aiken held that neither the standing doctrine, the political question doctrine, the novelty of plaintiffs' asserted constitutional rights, nor the novelty of applying the public trust doctrine to the federal government, should bar the plaintiffs' claims at this early stage. By denying the motion to dismiss, Judge Aiken allowed plaintiffs to continue the lawsuit by now seeking the factual evidence to support their claims on the merits. The key allegations the plaintiffs will seek to substantiate through discovery are (1) that the U.S. federal government has known for decades that climate change is caused by human GHG emissions and presents serious risks to the American people, and yet (2) that it has deliberately disregarded that risk while not just failing to regulate but indeed promoting and subsidizing GHG emissions all the while.
Following the denial of the motion to dismiss, the departing administration took the opportunity to admit most of the factual allegations in the complaint, including with regard to the international consensus on climate change science and the threat that climate change poses to the public health and welfare of current and future generations.[7] It remains to be seen whether the new administration will attempt to revoke those admissions. Industry intervenors have now withdrawn from the case, largely to avoid answering a request for admissions regarding their agreement with the government's admissions.[8]
The ideal outcome for the plaintiffs in Juliana would be for the court to declare a certain threshold for global temperature increase or pounds of carbon dioxide equivalent in the atmosphere, at which their constitutional rights to a life-sustaining climate system are violated. The plaintiffs would then ask the court to order the government to figure out the extent to which the United States is contributing to the potential for crossing that threshold, and do whatever it takes to curtail that contribution. For example, the court might find that anything more than 2 °C warming is a constitutional violation. EPA might determine that the planet is actually headed toward 4 °C warming, for which U.S. emissions will contribute 25%. Congress, EPA, and other federal agencies might then have to come up with a plan to reduce U.S. emissions by whatever amount it would take, all else being equal, to bring expected planetary warming to 3.5 °C (i.e. eliminate the country's 25% contribution to the 2 °C of extra warming).
In light of this structure, the potential effect of the Juliana litigation on industry is fairly indirect — even if the litigation were successful, there would still be a lot of flexibility in how the various parts of the federal government brought about the necessary emissions reductions. Nevertheless, if the court-ordered emissions reduction is sufficiently substantial, assuming that Congress and the federal agencies actually complied with the order, high-emission industries could expect significant economic effects whether in the form of higher taxes, stringent performance standards, prescriptive regulations, or penalties.
To understand the likelihood of success for the Juliana plaintiffs, it is necessary to consider each of the major legal issues that underlies the litigation.
The standing doctrine — governing whether a particular plaintiff has "standing" to bring a particular lawsuit — was initially developed by progressive jurists in the minority during the early twentieth century "Lochner era," in an attempt to prevent challenges to progressive legislation.[9] Since at least the 1980s, however, the standing doctrine has served more to bar claims brought by progressive organizations.[10] The theory underlying the doctrine is that Article III of the Constitution empowers the federal courts to decide cases and controversies, not generalized grievances regarding the enforcement of the laws. Thus, the doctrine enjoys separation-of-powers significance in delineating which claims can be heard by the federal courts, and which must be left to the political process.
The standing doctrine requires that a plaintiff have a (1) concrete and personalized injury, which is (2) fairly traceable to the complained of conduct by the defendant, and which is (3) redressable by the court.[11] All three of these requirements have presented major hurdles for climate change litigation.
The trouble with the concrete and personalized injury requirement is that judges may feel that a particular plaintiff's allegedly climate change-induced harm is too difficult to attribute specifically to climate change and/or too much like everyone else's climate change-induced harm. But evolving science is chipping away at these problems, providing plaintiffs with more and more tools to trace specific injuries to climate change, from rising sea levels to drought to tropical storms to failing fish populations.[12] As more particularized injuries are linked to climate change, plaintiffs can point to the specific injuries that affect them in specific ways. In Juliana, Judge Aiken accepted plaintiffs' allegations at face value, finding that such alleged injuries as algae blooms harming the local drinking water supply, heat waves damaging a family orchard, and decreased snowpack shortening the local ski season all constituted fairly pleaded concrete and personalized injuries resulting from climate change.[13]
The causation requirement presents two potential difficulties in most climate change cases. In actions against private entities, the difficulty thus far has been the idea that climate change would still be occurring on almost exactly the same scale even without the actions of any particular entity. However, recent scientific advancements seem to have made it possible to calculate a single actor's contribution to climate change. The new science is making it possible to say that a particular entity contributed a specific portion of the emissions leading to climate change, even at a fraction of a percent.[14] While previous cases dismissed attempts to hold single corporations responsible for climate change harms, finding that the causal link between the corporation and the harm was simply too tenuous and indeterminable,[15] the new science might eventually lead to liability for an entity's fractional share of the damages. In the much-watched case of Lliuya v. RWE AG, a Peruvian farmer threatened by melting glaciers is currently testing this approach against a major German utility in German court. The Essen District Court dismissed the complaint, broadly finding that the new apportionment science was relevant to damages but not causation, however the case will be heard on appeal later this year.[16]
The difficulty in challenging the actions of governmental entities is in finding that the challenged governmental policies have caused the complained-of (typically private) GHG emissions. The advantage of Juliana is that it does not challenge any particular government regulation or lack thereof, but rather the whole of U.S. government's actions and inactions taken together over the past many decades. It seems clear that the combined actions and inactions of the U.S. government have had some effect on the extent of U.S. GHG emissions. As such, Judge Aiken readily found the causation requirement met for purposes of the standing inquiry.[17] Whether causation will ultimately be factually demonstrated in the case, and at a level significant enough to trigger the plaintiffs' alleged constitutional rights, cannot yet be determined.
The redressability issue depends on the type of relief being sought in any particular climate change case. In the case of monetary damages against a private defendant, the answer is usually easy: monetary damages are the court's forte, and will result in compensating the plaintiff for her injuries. In the case of injunctive relief, however, the court faces the question of whether stopping a particular activity will have enough of an effect on climate change to actually abate any of plaintiff's injuries. Assume, for instance, that a company is responsible for 1% of global GHG emissions. That would make it one of the biggest single emitters on the planet. However, even stopping its operations altogether would leave 99% of global GHG emissions unchanged, likely meaning that climate change would still occur and plaintiff would still, for instance, need to build his flood wall. But in Juliana, the challenged GHG emissions account for 25% of global emissions, and thus very well may have a significant impact on climate change outcomes.[18]
In a similar case in the Netherlands, Urgenda Foundation v. Kingdom of the Netherlands [2015] HAZA C/09/00456689, the District Court for The Hague recently accepted such reasoning. The court ruled that the Dutch government must do more to curb Dutch GHG emissions, using whatever means it might have available, both on the basis of the country's proportional responsibility for GHG emissions, and on the grounds that the Netherlands has a moral responsibility to exercise international leadership on the issue.[19] Should the plaintiffs in Juliana ultimately be found to have any of the constitutional rights they allege, it will be well within the court's traditional purview to remedy violations of those rights through injunctive relief. Thus, their climate change-caused injuries may well be redressable through the court's resulting power over 25% of global GHG emissions.
Political Question
The tension at the heart of the political question doctrine is whether it is necessary for the judiciary to be able to enforce the whole of the Constitution, or whether there are some parts of the Constitution within the exclusive authority of another branch and whose protection must be sought through that branch alone. The classic example is the power of impeachment, which the Constitution commits to the exclusive authority of Congress and which the federal courts do not have the power to second-guess.[20] Climate change, not being mentioned in the Constitution, is not such a clear case.
The more common but muddier analogy is the foreign affairs power of the executive, which the courts are generally loathe to encroach on.[21] The version of the political question doctrine used for dealing with more complicated territory like the foreign affairs power, known as the "prudential" political question doctrine, has recently been out of favor.[22] Nevertheless, Judge Aiken marched through the full prudential inquiry to analyze the motion to dismiss the Juliana complaint.
In the context of the rights asserted and the relief requested by the Juliana plaintiffs, the only prudential test Judge Aiken found to present a reasonable hurdle was the potential for serious conflict with the other branches of government. Pragmatically, courts must consider the possibility (though generally unstated) that the executive might choose to disobey a court order, such as an order to undertake sweeping reforms to deal with climate change. Such an event would be nationally embarrassing and might damage the credibility of the courts. However, assessing the Obama administration at the time, Judge Aiken reasoned that there was no risk of fundamental embarrassment from ordering the executive simply to take stronger action on climate change than it was already proclaiming its intention to do.[23]
Substantive Due Process
Though the Juliana complaint stated its constitutional rights in several different formulations, each presenting unique issues and implications, the version of those constitutional rights that Judge Aiken took up for analysis was the possible fundamental right to a climate system capable of sustaining human life. The doctrine thus implicated was substantive due process. Substantive due process is a protection attributed to the 5th and 14th Amendments against government infringement of those rights that are so rooted in the tradition and history of this country, or so implicit in the concept of ordered liberty, that they must not be infringed no matter what legal process is afforded. The only exception is for restrictions that are narrowly tailored to serve a compelling government interest.[24]
The list of rights protected by the substantive due process doctrine does not appear in the Constitution. Instead, those rights have emerged over time, typically in the most high-profile Supreme Court cases, as judges "discovered" their existence. For example, in Obergefell v. Hodges, 135 S. Ct. 2071 (2015), the Supreme Court found that the right to marry the person of one's choosing is a fundamental right, making it unconstitutional for states to refuse to grant or acknowledge same-sex marriages. In contrast to the use of the substantive due process doctrine in the modern era to secure progressive social protections, however, the Court in the early 1900s employed the doctrine to defeat progressive state labor protections by finding a fundamental right to economic liberty. The most famous such decision was Lochner v. New York, 198 U.S. 45 (1905), in which the Court invalidated New York's maximum hours law for bakery workers. The tension in the substantive due process doctrine is between protection of truly fundamental but unenumerated rights, particularly those of minority groups who cannot effectively protect their rights through the political process, versus fear of an unaccountable judiciary able to expand and contract the Bill of Rights at will.
In Juliana, Judge Aiken attempted to balance this tension by identifying a fundamental right that was as close as possible to the mere non-annihilation of the planet. Thus, Judge Aiken proposed that the right to a climate system capable of sustaining human life is a protected fundamental right, supposing that it may be possible to determine an emissions threshold at which the risk of climate-induced catastrophe is so high that the right is violated.[25]
One of the primary counterarguments to the existence of such a right is the argument that the Constitution does not guarantee affirmative rights. That is, the government may be prohibited from actively destroying the planet, but it is not required to bring about a sustainable planet. In this regard, the history of school desegregation provides an instructive analogy. First the Court found that "separate but equal" public schools violated children's right to equal protection.[26] But even after invalidating the laws requiring the segregation of public schools, most public schools remained segregated in fact. Ultimately, the federal district courts supervised a court-led process of affirmative integration. The courts never found a fundamental right requiring the government to affirmatively provide children with a racially diverse education (just as they may or may not ever find that the government has an affirmative obligation to provide its citizens a stable climate). However they did find that government action had created the problem in the first place, and so government action could be ordered by the courts in order to remedy the problem.
Public trust doctrine
The public trust doctrine says that the government holds certain especially important natural resources in trust for the public, with the primary consequence that it cannot do anything to permanently alienate or squander them. Thus, Illinois could not sell the Chicago harbor to the railroads in the late 1800s, potentially curtailing public and economic access to Lake Michigan forevermore.[27] Nor could California allow Los Angeles to drain all the water out of Mono Lake in the 1980s, irreparably destroying a unique and valuable ecosystem.[28] But troubles abound in applying the public trust doctrine in the Juliana litigation: it has never been used with respect to the atmosphere, it has never been clearly used against the federal government, and, indeed, it has hardly ever been used at all.
The public trust doctrine is most clearly tied to the protection of navigable waterways. At a time in history when travel by water was the essential way in which almost all movement of people, commerce, and even communications took place, it was practically unthinkable that any people could delegate to the government the right to privatize or impair those waterways, nor that it could have the right to do so at the expense of future generations. A basic principle underlying the doctrine is that a core part of what it means to have sovereignty over a territory is to be the trustee for the public resources of that territory in perpetuity. The idea that this doctrine could cover similarly essential public resources other than navigable waterways is not so farfetched. However, Judge Aiken declined to determine the doctrine's applicability to the atmosphere, finding that the effect of climate change on the territorial seas (a classically navigable water) was enough to trigger the doctrine.[29]
More troublesomely, the public trust doctrine has never been used by a court to require the protection of a resource by the federal government. The Supreme Court has even stated that the public trust doctrine "remains a matter of state law."[30] Accordingly, the D.C. Circuit recently held in an unpublished, three-page per curiam opinion that the doctrine really must not apply to the federal government — that it is a matter of state law only, and constrains the actions only of state governments.[31] Yet Judge Aiken found the D.C. Circuit's reasoning unpersuasive, finding in particular that it had taken the Supreme Court's statement out of context. She further reasoned that if the states take title to certain resources when they enter the Union subject to the public trust doctrine, they must acquire that trustee responsibility from the federal government. In other words, the federal government's title to certain public resources must be burdened by the public trust doctrine as well.[32]
Judge Aiken was not bothered by the rarity of the public trust doctrine. She described the doctrine as a tenet of sovereignty itself, a corollary of the Rousseauian social contract theory on which our republic is based. Thus, she concluded that it was best viewed as another unenumerated right of the people protected by the Constitution in the form of substantive due process.[33]
How likely are the Juliana plaintiffs to succeed, ultimately? What we have seen in the context of civil rights cases is typically a slow, iterative evolution toward the protection of broad new categories of rights by the judiciary. By contrast, if the plaintiffs in Juliana are successful, the expansion of the Constitution to encompass climate rights would be a sudden sea change. But one explanation for why other recent courts have been less receptive to climate change litigation is that they had perceived that a gradual and iterative process was occurring in the other branches — that the ship of the federal government was slowly turning toward action to protect the climate and that the federal courts did not need to worry about it. In the minds of many, that era has ended. Not only has Congress never enacted comprehensive climate change legislation, but the recent presidential election has put the executive branch on a path leading away from climate action.
The change in presidential administration will have a few effects directly on the dynamics of the Juliana litigation. First, Judge Aiken's assessment of whether the political question doctrine should bar the case from going forward relied in part on the progressive stance of the executive on climate change issues.[34] The new executive's nearly opposite stance will not necessarily move the courts to avoid a pro-climate rights ruling ex ante, however. The courts might instead anticipate a situation like the aftermath of Brown v. Board of Education, in which widespread state defiance of the Supreme Court's anti-segregation ruling led to the Court's much maligned "all deliberate speed" approach, directing federal district courts to supervise a gradual desegregation process that would take decades to make headway.
Second, the long-term prospects for the case on appeal may be affected by new perceptions of whether Congress and agencies like the EPA have climate change under control, or are currently able to vindicate the public interest. Most notably, the standing doctrine over the past decade or two has trended toward denying environmental plaintiffs their day in court. If that trend continues, the standing doctrine could be one of the more significant hurdles for Juliana on appeal. However, there is reason to think the standing doctrine may start trending in the other direction. A court that believes climate rights plaintiffs are not getting a fair hearing in the political process is likely to be more sympathetic toward giving them a hearing before the judiciary.
In the wake of Judge Aiken's denial of the government's motion for interlocutory appeal, the government has filed a petition for writ of mandamus with the Ninth Circuit.[35] The petition requests review of the standing, substantive due process, and public trust doctrine issues presented in the motion to dismiss. It argues that Judge Aiken committed clear error with regard to each of these issues, and that immediate relief is necessary to protect the government from a "serious intrusion on the separation of powers." The major legal issues underlying the litigation may thus be heard on appeal very soon, before the case moves into factual development. The most immediate potential outcome of the petition is that the Ninth Circuit may stay the District Court litigation pending its own review.
Even if the Juliana plaintiffs ultimately lose this case, it may be on narrow grounds. Future climate rights cases, like civil rights cases, may come closer and closer to achieving the outcome the Juliana plaintiffs are seeking. Thus, even without elected representatives eager to enact new emissions regulations, or overhaul subsidies benefitting high-emission industries, a court-ordered process could eventually lead things in that direction. During the Obama administration, those interested in emerging climate change law did well to keep their eye on EPA. Today, they would do well to keep their eye on the courts.
For more information, please contact any of the members of our Climate Change team.
[1] Juliana v. United States, Order Denying Motion to Dismiss, Case No. 6:15-cv-01517-TC (D. Or. Nov. 10, 2016).
[2] Juliana v. United States, Order Adopting Recommended Denial of Interlocutory Appeal, Case No. 6:15-cv-01517-TC (D. Or. June 8, 2017); Juliana v. United States, Findings & Recommendation re Interlocutory Appeal, Case No. 6:15-cv-01517-TC (D. Or. May 1, 2017).
[3] For an extensive overview of all climate change cases brought in the United States, see Columbia Law School Sabin Center for Climate Change Law & Arnold & Porter Kaye Scholer LLP, U.S. Climate Change Litigation.
[4] See William H. Rodgers, Jr. & Andrea K. Rodgers, Commentary, The Revival of Climate Change Science in U.S. Courts, 6 Wash. J. Envtl. L. & Pol'y 534 (2016).
[5] See, e.g., Mary Christina Wood & Charles W. Woodward, IV, Atmospheric Trust Litigation and the Constitutional Right to a Healthy Climate System: Judicial Recognition at Last, 6 Wash. J. Envtl. L. & Pol'y 633 (2016).
[6] Juliana, Order Denying Motion to Dismiss, supra note 1.
[7] See Juliana, Findings & Recommendation, supra note 2.
[8] Juliana v. United States, Order Granting Motions to Withdraw, Case No. 6:15-cv-1517-TC (D. Or. June 28, 2017).
[9] See Fairchild v. Hughes, 258 U.S. 126 (1922).
[10] See Allen v. Wright, 468 U.S. 737 (1984).
[11] Lujan v. Defenders of Wildlife, 504 U.S. 555, 560 (1992).
[12] See, e.g., Annie Sneed, Yes, Some Extreme Weather Can Be Blamed on Climate Change, Scientific American (Jan. 2, 2017). For an extensive catalog and map of events attributable to climate change, see ClimateSignals.org (currently in beta).
[13] Juliana, Order Denying Motion to Dismiss, supra note 1.
[14] Bethan Gilroy, A New Hope for Climate Change Litigation: Holding Corporations to Account for their Greenhouse Gas Emissions, G.U.L.S. L. Rev. (Feb. 16, 2017).
[15] See, e.g., Native Vill. of Kivalina v. ExxonMobil Corp., 663 F. Supp. 2d 863 (N.D. Cal. 2009), aff'd on other grounds, 696 F.3d 849 (9th Cir. 2012).
[16] Lliuya v. RWE AG, Case No. 2 O 285/15 Essen Regional Court (Dec. 15, 2016) (see unofficial English translation); Climate suit against German utility RWE: Higher District Court will hear appeal on 13 November, GermanWatch (May 13, 2017).
[17] Juliana, Order Denying Motion to Dismiss, supra note 1.
[18] Id.
[19] Urgenda Foundation v. Kingdom of the Netherlands [2015] HAZA C/09/00456689 (see English translation).
[20] See Nixon v. United States, 506 U.S. 224 (1993).
[21] See, e.g., Goldwater v. Carter, 444 U.S. 996 (1979).
[22] See Zivotofsky v. Clinton, 566 U.S. 189 (2012) (finding justiciable a statutory claim to list Israel as the passport birthplace without mentioning the traditional prudential inquiries); Lexmark Int'l, Inc. v. Static Control Components, Inc., 134 S.Ct. 1377 (2014) (reclassifying certain prudential standing tests as nonjurisdictional elements of the cause of action); Susan B. Anthony List v. Driehaus, 134 S. Ct. 2334 (2014) (reaffirming Lexmark and calling into question the prudential ripeness doctrine).
[23] Juliana, Order Denying Motion to Dismiss, supra note 1.
[24] See, e.g., Lawrence v. Texas, 539 U.S. 558 (2003).
[25] Juliana, Order Denying Motion to Dismiss, supra note 1.
[26] Brown v. Board of Ed. of Topeka, Shawnee County, Kan., 347 U.S. 483 (1954).
[27] Ill. Central R.R. Co. v. Illinois, 146 U.S. 387 (1892).
[28] Nat'l Audubon Soc'y v. Superior Ct. of Alpine Cnty., 33 Cal.3d 419 (1983).
[29] Juliana, Order Denying Motion to Dismiss, supra note 1.
[30] PPL Mont., LLC v. Montana, 565 U.S. 576, 603 (2012).
[31] Alec L. ex rel. Loorz v. McCarthy, 561 F. App'x 7 (D.C. Cir. 2014).
[32] Juliana, Order Denying Motion to Dismiss, supra note 1.
[33] Id.
[34] Id.
[35] United States v. U.S. Dist. Ct., Petition for Writ of Mandamus, Case No. 17-71692 (9th Cir. June 9, 2017).
This article is not a substitute for legal advice. Please consult with your legal counsel for specific advice and/or information. Read our complete legal disclaimer.


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Mark your calendar – Lids for Kids returns to Grand Rapids Saturday, May 30, 2020!!
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Michigan kids and their families are invited to join us for the annual Lids for Kids event. Trained professionals and volunteers will properly fit each child with a free bike helmet and share helpful bicycle safety tips. Children in attendance and wearing their new helmet may also fill out a raffle ticket for entrance into a drawing with tons of prizes and a chance to win a FREE bike! With opportunities to meet local law officials and firefighters, tour a fire engine, and fun activities and games, there's something for every kid and kid at heart!
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Surgeon and historian Jack C. Fisher sits down with Dr. David Granet to discuss fundamental differences between silicon and silicone. Though the fear surrounding their usage was unwarranted and not based in scientific fact, battles waged about their safety and government regulation followed suit. (#32611)
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In classical music, popular success begets critical disdain. In the last 20 years, the music of the Estonian composer Arvo Pärt has touched audiences all over the world. Like many composers before him, Pärt sees his music as an expression of his religious convictions, in his case Orthodox Christian. Certainly the majority of those moved by his music don't share those beliefs, yet critics deride his work as 'Holy Minimalism'. They portray the composer as an earnest aesthete, and, it has to be said, those who champion his music sometimes collude: the booklet accompanying the recording of his Passio, released by the German label ECM, includes a photo of Pärt's hands, as if in contemplation of a living saint.
In person the composer presents a different figure. Certainly he is serious but there is also a lively, self-deprecating and disarming wit. In June I met Pärt at a recording session in Stockholm where Paavo Järvi was conducting the Royal Stockholm Philharmonic's Virgin Classics recording of Nekrolog, written in 1960 when the composer was in his mid-twenties. After a play-through of the piece, composed in a jagged expressionist style far removed from his current music, Pärt threw up his hands in mock exasperation and exclaimed, 'I don't understand why young people like such noisy music!' At the end of a successful day's recording, the composer, conductor and recording team adjourned to one of Stockholm's smarter restaurants, where a sumptuous and beautifully presented meal elicited from Pärt the observation, delivered with wry solemnity, 'A music student could learn more from this meal than from a bad music teacher.'
Food, it seems, plays a significant part in the composer's life. Two weeks later we met again when he was in Norwich to see the cathedral choristers premiere his I am the True Vine. Just before a rehearsal, I sit down with Pärt and his wife. Not quite sure what kind of answer to expect, I ask, 'What do you do to help you through periods when writing music is difficult?' The reply is cautious. 'It's very rare that writing music is easy. But you should ask my wife: she suffers more in these cases than I do.' Frau Pärt suggests that, when the going gets tough, the composer gets into the kitchen, where he starts cooking. Arvo Pärt laughs. 'I peel potatoes, that calms me down.' Frau Pärt adds, 'Even when we don't need potatoes.' The image of the composer surrounded by bucketfuls of unwanted peeled potatoes will stay with me a long time.
Arvo Pärt was born in Estonia in 1935. In 1939 the Nazi-Soviet Pact handed the country to Stalin, and Pärt grew up under Soviet rule. That did not preclude a sophisticated musical education. He studied with the composer Heino Eller, whose teaching provides a thread running through modern Estonian music. Besides Pärt, Eller taught the great symphonist Eduard Tubin, who left Estonia in 1944; and his last student (Eller died in 1970) was Lepo Sumera, one of Estonia's leading contemporary composers. By no means a modernist, Eller was tolerated by the Soviet authorities, and Pärt recalls him fondly: 'There is only one central composition school in Estonia, and it's Eller's school. He gave me a path, but this path was very broad. He didn't push in any direction, he supported you even if what you wrote wasn't exactly like his own credo. He was very human, and it was a vivid apprenticeship.'
Still, it was not easy to be a composer in Estonia. In 1961, Pärt wrote what is widely acknowledged to be the first piece of Estonian serial music, his oratorio Maailma samm ('The Stride of the World'), a work no longer included in the composer's catalogue. The authorities regarded serialism as Western and decadent, and Pärt could not but come into conflict with those who controlled musical life, especially since much of his work was overtly religious. For many years he made his living working in radio and film, while writing music that struggled to find an audience. He abandoned serialism in the late 1960s, and a period of close study of medieval music led in 1976 to the style which Pärt labels 'tintinnabular' in recognition of his quest for a bell-like simplicity. Eventually the unending frustrations of Soviet life caused Pärt to emigrate in 1980, and he has lived in Berlin since 1982. His music continues to develop, but remains recognizably in the tintinnabular mode he discovered 20 years ago.
Understandably perhaps, Pärt is reluctant to talk about his life in Soviet Estonia, but his contribution to the country's musical life is readily acknowledged by others, some of whom had no less painful experiences. The conductor Neeme Järvi left Estonia at the same time as Pärt because, he says, 'I no longer had the possibility of serving Estonian art'. He has long promoted Pärt's music, including pieces written before the composer's tintinnabular style emerged. He recalls the problems he faced in getting the music performed: ' Pärt was, and still is, an adventurous composer, and a religious man. That was bound to cause problems during the Soviet era, and he simply couldn't make a living from being a composer. Under Soviet rule, every piece had to be shown to the Union of Composers before it was performed. I remember conducting his Credo in 1968, and of course it has a religious text. It was a huge success, but I didn't get a permit from the Union. Religious music was not permitted, so the next morning there was a big scandal. That was simply how it was then.'
Perhaps the official criticism of the piece hastened his decision to abandon serialism, for the Credo was Pärt's last serial work. Yet despite the long history of conflict, Pärt's music did find an audience in Estonia. Tonu Kaljuste, who conducts the performance of Litany on the new CD of Pärt's music, recalls encountering Pärt 's work at a very early age. 'I remember singing his cantata Our Garden as a member of a choir of 10,000 children taking part in the Estonian Children's Song Festival. It was a piece that gave pleasure to everyone who sang it. In fact, children still perform the piece today. My father, who conducted that performance, was very happy that a young composer, working in the Soviet era, could write such sincere music for children. There is in Pärt's music a sincerity that you could call childlike, even in the music he writes now. He writes in different languages, for different churches, but we must never forget the influence of the spirit of Orthodox church music. Whether in his vocal music, or his orchestral pieces, he is composing prayers.'
It is Pärt's vocal music that has won him the greatest appreciation. In giving expression to his innermost convictions, it can be seen as the core of his work. As Pärt himse lf says, 'The human voice is the most perfect instrument of all, the instrument that is closest to us, and we respond to its finest nuances. The words are very 'important for me, they define the music. The intonations, phrases, pauses, almost all the parameters of the text, have an important meaning. One can say that the construction of the music is based on the construction of text.'
Yet words don't come easily when Pärt talks about his music, and not only because our conversation is conducted in German, a second language for him, something rather less for me. His reluctance to discuss his work goes deeper than that, and when I ask whether he has anything to say about Litany and the other pieces o the new CD, he replies , 'My best recommendation is that Gramophone readers have a gramophone! Talking about my music traps me in a vicious circle and it's very seldom that I manage to escape it. If I'm writing a new piece then I mustn't talk about it because if I do then I have no impulse to write it any more. Once it's written, then there is nothing left to say. That's very apparent to me. It 's a matter of thinking in music, and I hope my music finds a direct way to the listener without any further explanation.'
Over the years , Pärt 's music has attracted performers who return to his work repeatedly, drawn by the demands and rewards of playing it. Christopher Bowers-Broadbent, a formidable exponent of new music for the organ, recalls his first encounter. 'It was about 15 years ago. The Hilliard Ensemble was preparing a broadcast for the BBC, and the producer rang up and said, 'We need an organist, a nd you're the only one I know who plays contemporary music.' I was used to playing music that you needed to study months in advance, so I told Paul Hillier of the Hilliards that I wanted some scores. Paul said, 'No, there's no problem, it's very straightforward, you can sig ht-read it all .' I turned up at the session and was completely stunned: here was a man who, in the best way, was articulating something that many people, composers, musicians, and audiences, were moving towards. More often than not, the simplest music is the hardest to perform. I often think "God, I wish I had more notes: this is exhausting to play."
'And it's emotionally draining. The performer needs enormous poise. I used to ask Arvo, "What speed should I play this piece at?" And he'd say, "What speed do you want? Play your heartbeat." That's not a cop-out, it's a very sensible reply. If you look at the score and think, "This should be played at crotchet=such-and-such", you've approached it in the wrong way.'
Paul Hillier now lives and works in California, where his ensemble Theatre of Voices has recorded a CD of Pärt 's music, to be released next spring by Harmonia Mundi. He has also completed a book on the composer's music, which will be published by Oxford University Press. He recalls his first meeting with Pärt: 'In the early 1980s I read an article by Susan Bradshaw, which encouraged me to get in touch with Arvo's publisher and ask to see some scores. That in turn encouraged him to get in touch with me and we met up: on Victoria Station, of all places. We talked, looked at scores, and some thing leapt out at me: this was the kind of music I had been waiting to perform. There was an instant recognition; the scores revealed, if you like, that they had much more to reveal.'
Like Bowers-Broadbent, Hillier is careful to point out that, despite that immediate impression, 'In a sense, the scores are empty, and I like their economy. At the same time, they're pregnant. It's not hard to get the notes right, to play or sing across the top of the music, making very beautiful sounds: what do you do next? It's only when you dig deeper that you pull something to the surface. Sometimes I rehearse a piece at a much slower tempo than the one at which I will perform it, just to see what forces itself to your attention that might otherwise go unnoticed. The interpretation is there to discover, to develop, to change over the course of time. And Arvo's own ideas change. That's healthy. I like it that not everything is fixed.'
Paul Hillier's place in the Hilliard Ensemble has been taken by Gordon Jones, who sings on the ECM recording of Litany, a piece written for the Hilliards. Jones vividly describes his encounter with the work: ' Like a lot of Arvo's music, Litany sounds terribly simple, but there are moments which are rather frightening. You have to be so still, so accurate; and some times you have to sing very quietly and very high at the same time. The technical demands are great, but not obvious. It's not like singing at full tilt, or singing a lot of incredibly high notes. It 's a matter of control: the stillness of the music suits the way we sing.'
That stillness is the central experience of Pärt's music, and it is an experience that has left its mark on other composers. The English composer/performer Gavin Bryars has written that 'the revelation of [Pärt's] music has been one of the most important factors in the development of a new sensibility in recent music.' That same opinion he reiterates now. 'The first music of Arvo's that I heard was the ECM recording of Tabula rasa. I found it surprising, but a confirmation of my own concerns. This was music that was about a state of affairs, rather than a narrative, or a logical argument, and that impresssed me immensely. Later, when Arvo was featured composer at the Almeida Festival in London in 1986, I had the chance to play the piano part in that piece; that was very rewarding, and rather nerve-wracking. It certainly opened up the piece for me. He's such a refreshing voice, and he has a fantastic ear. Remember that in Estonia he worked in radio and film, where you need an ear for the precise effect that suits each particular mood.'
Bryars insists that sharing Pärt's religious convictions is not integral to appreciating the music: 'Bach's St Matthew Passion moves me without me being a Lutheran Christian. Sometimes, in fact, I find that the religion can get in the way of Arvo's music. It's as if he has to set this number of word , because that is what the words are; and for a moment the music stops breathing. Instrumental pieces like Tabula rasa and Frartres are at least as moving, in a spiritual sense, as the works setting religious texts. The Passio is a great piece, but only if you get to the end where it goes into the major after this endless hour or so of the same minor chord. It wouldn't be as worthwhile without that hour, but getting there is hard work.'
Passio crystallizes one of the composer's most celebrated sayings: 'It is enough to play a single note beautifully.' I ask Pärt to expand on the point. 'If that happens then there's nothing to say about it. It can't be described. This is the mystery of music . It may sound a bit metaphorical. It's an inner attitude of the composer: your whole being must be prepared for it. I'm talking of an inner tone. You could perhaps compare it with the up-beat of a conductor. There is no music yet. We don't hear a thing, but the musicians can see it. They know character, dynamic, tempo: everything is there. This is the one tone.'
It's a long journey from what Pärt has called 'the sterile democracy' of 12-tone music, to the tintinnabulation of this 'one tone'. Yet the conductor Dennis Russell Davies makes what may seem a surprising connection. 'Arvo can write a piece lasting seven or eight minutes, that is a world unto itself, and quite exhausting to listen to if you listen intensively. In that respect, and in the way the small episodes are important to achieving the overall structure, a work like Festina lente has a strong similarity to certain structures in Webern, although the piece doesn't sound like Webern in any way. You need to understand what the overall shape of the piece is, then what the individual voices in a measure or two do. They have a life of their own: it's very difficult to achieve the fluidity that makes all these things apparent to the listener. To begin with, the architecture seems quite transparent , but the more time you spend with the music, and the more time you spend with him, the more you learn that what is notated is just the bare bones. For Arvo, the music is not ever finished.'
And yet each performance in itself must be achieved as fully as possible. The composer himself speaks eloquently of the tortuous experience of hearing a new work performed. 'There are two things happening simultaneously . Everything is known to me, and at the same time everything is unknown and new, and these two forces sometimes fight with each other. You have to be lucky when you hear a work for the first time. Performers not used to playing my music may think that the score looks simple, but you can't simply grasp it with your bare hands. You have to have good musicians who are conscious that they are really giving birth to music, who invest as much in the music as I do when composing it. Striving for special effects doesn't work, you really have to want to get to the inner core of the music, to discover something new for yourself. Sometimes a new piece doesn't sound right at the first performance. Then I think I've made a mistake, but sometimes it's to do with the performers. Obviously both sides have to be correct. You're always at the edge of the unknown, and that's precisely what is so fascinating.'
When a performance of Pärt's music comes off, the listener too may feel at the edge of the unknown, in some timeless zone where everything is about to begin. That sense of the slate having been cleared gives one of Pärt's most famous pieces its title, an expression he uses to describe the process of composition: 'When I begin a new work, I have to start from scratch again, from nothing. I have to be cleared of everything: Tabula rasa.'
This article originally appeared in the September 1996 issue of Gramophone. To enjoy exclusive interviews with classical music artists and composers every month, subscribe to Gramophone: magsubscriptions.com


text: As Tourism Rises in Bali, What to Do With Waste? 5/24/2009 By ERICA GIES Download PDF Link to Original Publication SAN FRANCISCO — Bali once had a reputation as a tropical idyll. But the unfettered expansion of mass tourism on the island has created mountains of trash, overwhelming the ability of the Balinese, who traditionally wrapped and served food in palm leaves or other biodegradable plant material, to manage the mess. Plastic and other waste has simply been dumped or burned. To deal with the problem, two conflicting waste management strategies have emerged. Each claims climate benefit and employment for the poor, each has received international recognition and each has suffered setbacks. Bali Fokus, a nonprofit organization founded in 2000 by Yuyun Ismawati, an environmental engineer, offers a community-based, low cost, decentralized approach. It teaches people in the towns of Denpasar, Gianyar and Badung to separate waste in their homes and in village facilities: organic waste is used to make compost and pig food. Bali Fokus also teaches women to make products out of recyclable materials that they can sell for profit. Ms. Ismawati's efforts have spread to several communities in Bali, and more than 40 others have asked to join the program next year, she said in an interview during a recent visit here to receive the Goldman Prize for environmental activism. Through Sanimas, a related project, Bali Fokus and other groups are also bringing sanitation to some 75 towns throughout Indonesia every year. Ms. Ismawati is working to expand Bali Fokus both on the island and nationwide. She says it has the potential to provide a large-scale solution to waste management while empowering some of Indonesia's poorest people. The Balinese island authorities have been contributing to Bali Fokus and other nongovernmental organizations, or NGOs, that do similar work. The local government "will support all NGOs who are concerned with environmental protection in Bali," said Made Sudarma, head of the Sarbagita Solid Waste Management Agency, a government office covering the towns of Denpasar, Badung, Gianyar and Tabaman, from which the acronym Sarbagita is derived. But even as Bali Fokus was scaling up, the local government, under pressure to deal with the trash problem, sought industrial-scale solutions. In 2004 it awarded a contract to Navigat Organic Energy Indonesia, part of a Jakarta-based energy company, which proposed a technology it called Galfad, an acronym for gasification, landfill and anaerobic digestion. Its winning design would process 800 tons of daily waste from the four towns. The first phase of the project, in which methane is captured from the landfill and burned to generate electricity, was completed in January. In the second phase, organic matter will be put into a sealed anaerobic digester, where it will be broken down into methane; in the third, trash will be subjected to extreme heat under oxygen-free conditions to produce a blend of carbon monoxide and hydrogen. In 2007, Navigat Organic received backing through the Kyoto Protocol's Clean Development Mechanism, or C.D.M., which will offer carbon credits that the company can sell on the open market. "Without the C.D.M. the project would not be viable," said Bernt Bakken, the company public relations manager. Navigat's application for credits said the project would reduce greenhouse gases by destroying methane and by supplying energy generated from waste to the local grid, displacing power generated by fossil fuels. Methane retains 25 times more heat in the atmosphere than carbon dioxide. When it burns, one molecule breaks down into a carbon dioxide molecule — 25 times less harmful — and two water molecules. The village-scale programs of Bali Fokus also reduce landfill methane, and the project has received monetary support through voluntary carbon offsets. Still, small organizations like Bali Fokus have trouble gaining carbon credits through the C.D.M. "You need to hire an international consulting firm on the order of $50,000 to $100,000 to try to shepherd your project through the process," said Neil V. Tangri, waste and climate change campaigner for the Global Alliance for Incinerator Alternatives, a group to which Bali Fokus belongs. "It's a very high barrier." Allegations of administrative and design failures in the C.D.M. program have led to calls for it to be altered or replaced in a new international climate treaty to update the Kyoto Protocol, the first phase of which ends in 2012. Reports from environmental activist organizations like Forests & the European Union Research Network, or FERN, and from institutions including Stanford University have raised questions about the C.D.M. program's ability to detect abuses in the credit award process, such as awards for projects already in progress; falsification of audit reports; and manipulation by companies of the data on which they base their credit claims. Still, it is far from clear that the mechanism will be changed, because big business, which once complained about the bureaucracy, now supports it, said Daphne Wysham, a fellow at the Institute for Policy Studies, an independent research organization in Washington that has also criticized the C.D.M. process. "It's ironic that we've set up a profit-making system for the very industries — coal and nuclear — that need to see themselves replaced by really clean, green energy alternatives," she said. The C.D.M. process allows project managers to set both their own baselines and the methodology by which reductions in environmental harm should be measured. The managers thus have a financial incentive to set their baselines high, to help them show larger reductions and thus claim higher carbon credits. Navigat's application baseline was 800 tons of waste a day, and it is now trying to obtain certification for a baseline of 1,000 tons a day. Robert Eden, technical director of the project, said the higher figure reflected increased dumping into the landfill at Suwung, near Denpasar, because tourism on Bali was depressed when baseline measurements were first taken. Far from being a benefit, the increase was a hurdle, delaying completion of the Galfad project, he said. "The C.D.M. authorities are concerned that we might be trying to bring in extra waste." The plant's anaerobic digester and gasification units, which were scheduled to start operating in 2008 and 2009, respectively, have not yet been built; and the uncertainty over permits for the additional waste has prevented the company from securing loans to move forward on construction. Environmental campaigners are not sorry to see the plant's completion delayed. Indeed, they are irked that it is earning carbon credits at all, because, they say, it will release more greenhouse gases than if the work of Bali Fokus were expanded. The Galfad technology would waste materials both in land-filling and gasification, Mr. Tangri, the anti-incinerator campaigner, said. Taking into account the whole product supply chain and life cycle, throwing away materials or burning them uses more energy than reuse, composting and recycling, he said. Bali Fokus does a better job of reusing the waste stream, he contended. Mr. Eden disagreed, explaining the company's vision of the completed project. "Anything that we can recycle, we recycle," he said. What goes to the gasification unit will be "beach wood and inert organics that have no use at all." "We're not burning plastic; we're not using supplementary fuel," he said. "We get carbon credits because we're generating renewable power out of waste materials, and when I say waste, I mean really, waste." Ms. Ismawati said a bigger issue was the question of who benefited from these projects, economically and from a waste services perspective. Governments had seized on carbon credits as a way to outsource their funding responsibility for waste management, without considering the relative merits of competing projects, she said. "Giving hope of revenues for carbon credits from other countries is like making them wait for the fruit to come, when it's falling in front of their eyes," she said. "They are not improving the waste system, and all of the money will go back to the investors and not trickle down to local governments and communities." Mr. Eden disputed that. He said local benefits from Navigat's project would include 200 jobs sorting and separating waste, and annual payments to the regional government at a rate based on the megawatts of power produced. Those payments, however, are themselves problematic. The government's financial interest in the success of the industrial project has jeopardized its support for Bali Fokus, according to Ms. Ismawati. "One of the heads of the environmental agency told me that they could no longer support our small-scale, low-cost, community-based approach because they need more waste coming to their landfill," she said. For now, neither Bali Fokus nor Navigat can handle all the island's waste, and the trash mountains are continuing to grow. "The question, then, is which one are we going to try to scale up?" Mr. Tangri asked. "One that is being backed by a company with powerful profit incentives and is getting carbon credits? Or the other, which is environmentally preferable, but is not?" Mr. Eden says there is enough trash to go around. "To be honest, I didn't know that Bali Fokus was doing composting," he said. "They're not a group that we would want to damage in any way. Maybe we need to see what they're up to and see if we can't align ourselves."


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Add insulation. A properly insulated basement can save you money on heating and provide a dry, comfortable living space. A variety of insulation types are available. For an unfinished basement, blanket (batt) or foam board insulation is a good choice, while loose-fill or spray foam products can be used to add insulation to an already finished space. R-Value measures the thermal performance of insulation products. To determine the appropriate insulation level for basement walls in your area, see R-Value Recommendations from the U.S. Department of Energy.
Seal air leaks. A substantial amount of warm air can leak out of gaps and cracks in the rim joists (where the joists in your basement meet the foundation), as well as plumbing and wiring holes on outside walls. Caulk is best for sealing gaps or cracks that are 1/4 inch or less. Use spray foam insulation to fill gaps from 1/4 inch to approximately 3 inches. Fill larger gaps with cut pieces of batt insulation.
Check crawl space. If you have a crawl space, make sure it is properly sealed and insulated. See Crawl Space Insulation from the U.S. Department of Energy for more information.
Install carpet. Basements often have cement or tile-covered floors. If you do not have moisture problems, consider installing carpet in basement living areas. This will give the floor warmth and feel better on your feet. For work rooms and laundry rooms, consider putting a rug down with a pad underneath.
Replace windows. If you have old, cracked, single pane windows in your basement, you are reducing comfort and increasing your energy bill at the same time. Replace old windows with glass block or ENERGY STAR certified high-performance windows. If you choose not to replace your older windows, seal them from the outside with caulk and winterize them from the inside using a window insulation kit purchased at your local hardware or do-it-yourself retailer.
Add a heating vent. You can tap into your existing ductwork and install a vent to add central heating to your basement. You might also want to consider a return air vent in finished areas. It is possible to do this yourself, but you may want to consult a heating and cooling professional; tapping into existing ductwork may have an impact on the performance of your overall heating and cooling system.
Use space heating. If you do not want to add vents for central heating, electric space heaters are a great way to add supplemental heat in smaller areas, such as a laundry room or work room. For a finished space, an electric fireplace is a good option. They combine the warmth and beauty of a traditional fireplace without the mess and they can be turned on and off instantly.
To help make sure your entire house stays warm and cozy throughout the season, see Is Your Home Ready for Winter?.
Appalachian Power offers a free home energy assessment. A professionally trained energy specialist will come to your home and help you assess how much energy your home uses and evaluate what measures you can take to improve efficiency.
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T-Mobile CEO John Legere wants folks to sign up for their wireless service and for the past couple of years has made his pitch in the most unusual of places, a weekly cooking show called "Slow Cooker Sunday."
To mark the 2nd anniversary of the show, Legere joined David Wasielewski, the managing partner of the popular Taiwanese dumpling chain Din Tai Fung, at their restaurant in Bellevue's Lincoln Square to cook up chicken soup and dumplings.
The unconventional wireless exec spends about 10 minutes every Sunday, usually from his kitchen, where he plugs T-Mobile, shares a crock pot recipe and answers viewer questions on Facebook Live. The shows are low-tech, kitschy and irreverent, with antics like Legere spraying Pam cooking oil on the floor and doing what he calls the "Pam shuffle dance."
The show has become immensely popular, with 2.3 million average viewers weekly and even topping 3 million views for an episode that starred actress Kate Hudson. The show has also helped Legere amass more than 5.7 million followers across Twitter, Facebook, Periscope and Instagram.
"I use tons of different ways to talk to customers, to talk to employees, get them excited about T-Mobile, but this has taken on a life of its own," said Legere. "I'm having a great time doing it, and customers and employees love it, and a lot of non-T-mobile customers watch this and then go in the store."
He's also pretty certain that his competitors in the wireless industry have taken notice of the show. "Trust me. They hear about this because their people wish that they were closer to employees and customers," said Legere. "I don't think most CEOs today can get out of their own way. They've got to portray an image. I don't think they're doing this."
The self-proclaimed Un-CEO also teased that he may have a cookbook coming in the future. The potential title? "The Un-Cooker."
If you'd like to make the "home version" of Din Tai Fung's house chicken soup from this week's episode, here is the recipe:
- 20 pcs chicken
- 5-6 green onions, sliced into 2-inch pieces
- 5 slices ginger
- 64oz Chicken Broth
- 4 tablespoons cooking wine
- Cook on high for 6 hours in the slow cooker


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From the First International Symposium on Dvāravatī Research, Bangkok, 2009
The French contribution to the rediscovery of Dvāravatī archaeology
Laurent HENNEQUIN
Fifty years of archaeological research at Dong Mae Nang Muang, an ancient gateway to the Upper Chao Phraya Basin
Stephen A. MURPHY and PIMCHANOK Pongkasetkan
Iconographical issues in the archeology of Wat Phra Men, Nakhon Pathom
Nicolas REVIRE
Nāga-Buddha images of the Dvāravatī period: A possible link between Dvāravatī and Angkor
Jean-Pierre GASTON-AUBERT
Safe haven: Mon refugees at the capitals of Siam from the 1500s to the 1800s
Edward VAN ROY
Towards a definition of Isan mural painting: Focus on the heartland
Bonnie Pacala BRERETON
Prominent Mon lineages from late Ayutthaya to early Bangkok
Edward VAN ROY
From the archives
Bruguière's journey overland from Penang to Ligor, thence to Bangkok, 1827
Kennon BREAZEALE, ed. and Michael SMITHIES, tr.
The Ambiguous Allure of the West: Traces of the Colonial in Thailand, edited by Rachel V. Harrison and Peter A. Jackson
Reviewed by Chris BAKER
Proper Islamic Consumption: Shopping among the Malays in Modern Malaysia, by Johan Fischer
Reviewed by Patrick JORY
Tourism in Southeast Asia: Challenges and New Directions, edited by Michael Hitchcock, Victor T. King and Michael Parnwell
Reviewed by Steve VAN BEEK
Bangkok, a Cultural and Literary History. by Maryvelma O'Neil
Reviewed by Michael SMITHIES
Jungle Book: Thailand's Politics, Moral Panic, and Plunder, 1996–2008, by 'Chang Noi'
Reviewed by Craig J. REYNOLDS
Thai Forestry: A Critical History, by Ann Danaiya Usher
Reviewed by Thomas ENTERS
Thaksin, by Pasuk Phongpaichit and Chris Baker
Reviewed by Edward VAN ROY
People of Virtue: Reconfiguring Religion, Power and Moral Order in Cambodia Today, edited by Alexandra Kent and David Chandler
Reviewed by John TULLY
Dependent Communities: Aid and Politics in Cambodia and East Timor, by Caroline Hughes
Reviewed by Benny WIDYONO
The Last Century of Lao Royalty: A Documentary History, by Grant Evans
Reviewed by Martin STUART-FOX
Creating Laos: The Making of a Lao Space between Indochina and Siam, 1860–1945, by Søren Ivarsson
Reviewed by Holly HIGH
Imagining Communities in Thailand: Ethnographic Approaches, edited by Shigeharu Tanabe
Reviewed by Anthony R. WALKER
Burmese Buddhist Murals: Vol. 1, Epigraphic Corpus of the Powin Taung Caves, by Christophe Munier and Myint Aung
Reviewed by Donald A. STADTNER
Books received for review
Thanpuying Lursakdi Sampatisiri, 1919–2010
Yoneo Ishii, 1929–2010
Charles F. KEYES
Constance Wilson, 1937–2010
John HARTMANN
Hans Penth, 1937–2009
Reinhard HOHLER
Contributors to this issue
Notes for contributors
Back to JSS main page>>>


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DePauw (14-2, 30-13) captured its second-straight North Coast Athletic Conference softball tournament championship after defeating Denison (10-6, 22-19), 6-0, in game 7 of the 2015 NCAC Softball Tournament on Saturday in Greencastle, Indiana. Game 7 was needed after Denison earned a 8-0 victory over DPU in the first championship game. In game 7, Linsey Button (Ballwin, MO/Lafayette) went 2-for-3 from the plate with a double, two runs scored and an RBI and freshman pitcher Emma Baldwin (Oak Park, IL/Oak Park River Forest) took a no-hitter into the sixth inning and allowed Denison just two singles en route to the victory.
The Tigers opened the tournment with a 9-2 victory over Denison in the opening round on Friday, and advanced to the championship round after knocking off second-seeded Wittenberg (11-5, 20-17), 1-0, in the winners' bracket later in the day. After losing its opener against DPU, the Big Red advanced to the championship round by winning back-to-back elimination games against Allegheny (10-5-1, 14-15-1), 4-1, and Wittenberg, 2-0.
Baldwin was named the Most Valuable Player of the NCAC Tournament, joining Tiger teammates Button, Alli Dennie (Fort Wayne, IN/Bishop Dwenger), Taylor Golden (Chicago, IL/Trinity), and Kahla Nolan (West Chicago, IL/Wheaton North) on the All-Tournament team. In three apperances, Baldwin posted a 1-0 record in the circle with a 0.00 ERA, 16 strikeouts and held opponents to a .095 batting average and just four total hits in 12 innings of work.
Three Denison players were named to the All-Tournament team as well, including Julie Rooney (Munroe Falls, OH/Stow-Munroe Falls), Lauren Secaras (Wilmette, IL/New Trier) and Sarah Herold (Orland Park, IL/Carl Sandburg). Also, named to the All-Tournament team were Wittenberg's Loren Combs (Cincinnati, OH/Turpin) and Kaela Hughes (Columbus, OH/Watterson), and Allegheny's Caitlin Nealer (New Kensington, PA/Valley).
The Tigers have been selected to host a Division III regional and will face Washington-St. Louis on Friday, May 8, at 3:30 p.m. EDT. With a victory over Wash. U., DePauw would move on to the winners' bracket semifinal against either Trine (37-3) or Thomas More (26-15). Should the Tigers lose in the opening round, DePauw would meet the loser of the Trine and Thomas More contest in an elimination game.
The regional round will be held May 8-10. Four teams will compete at 14 regional sites and three teams will compete at two regional sites. The team advancing from each regional will compete in the super regional round May 15 and 16. The finals, hosted by the Old Dominion Athletic Conference and the City of Salem, will be held May 21-26 at Moyer Sports Complex in Salem, Virginia. All rounds will use a double-elimination format.


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I have never been asked with questions about 'will I die', or 'when will i die' in my practice. Phew! Personally I do not wish to handle questions on death, because while the techniques of predicting death are reliable as an astrologer I could be wrong. The stake is huge here and given the complexities there could be error with my judgement.
So how questions on death can be judged? For example, when will I die? There are broadly two steps: firstly to cast a horary chart at the time the question is asked, and then to check with the birthchart of the querent. This is not a fail-safe, but it does mean you must get it wrong twice to be in error with your judgement.
In the horary chart what you do is to find out the significators of Lord 1 (querent) and Lord 8 (death). Well-behaved charts will have an applying aspect between the two. As ever, it does not matter which applies to which. Any aspects can kill. There are only two barriers that we cannot allow our significators to pass, i.e. (1) conjunction with the Sun and (2) station. Forget about the antiscion. Death cannot have the sense of the covert or hidden that antiscia can carry. Lord 1 on 8th cusp, or Lord 8 applying to the Ascendant are not testimonies because they only show the querent is thinking about death.
In those charts where there is no applying aspect between Lord 1 and Lord 8, we must find another significator for one or the other. This can be the Moon or the Sun as alternative Lord 1; Saturn, or the dispositor of the Part of Death for alternative Lord 8. When you have found the aspect showing death, time it in the usual way (ref John Frawley's Textbook on Horary Astrology).
After you get the result, double check the native's birthchart. I will employ the length of life technique as in Hellenistic astrology (I am still learning), without that one should search through years of progressions, profections and transits of the native.
This is a lot of work, I think this will take me a week to do all these in order to make a confident judgement. Afterall, do you really want to know when you will die? Although the idea of predicting death may seem off-putting, there are many reasons for people sincerely wanting to know. The most common are when the querent has to make financial provision for the care of an elderly relative and when the patient is receiving treatment for a potentially fatal illness.


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California Department of Education Management Bulletin 13-04 (Parent Appeals)
The purpose of Management Bulletin (MB) 13-04 (Parent Appeals) is to provide clarification on the process that child development contractors should use to conduct their parent appeal process as required in regulations.
MB 13-04 confirms a variety of due process protections for parents receiving child care subsidies.
MB 13-04 also confirms that contractors are responsible for ensuring effective communication with and a meaningful opportunity for parents who have Limited English Proficiency to participate in their child care programs.


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Ladies kurti are always in fashion in any season. These kurti come in different looks or ways, like kurti, tunic tops etc. Kurti looks very stylish and comfortable. The term kurti are used to describe the shorter kameez. Most women prefer to wear these without the dupatta. It can be short, long, three forth sleeves or without sleeves. Kurti is just a top. Girls nowdays wear kurti in colleges, office wear and daily wear over jeans, salwar, pant, capri and even a skirt. Indian kurti looks great and are famous worldwide. Kurtis look decent yet traditional.
Monday, August 13, 2012
Designer Cotton Kurtis for Women
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- August 16, 2016 at 11:42 AM


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Byerly's Roseville
Locally sourced products are abundant throughout the shelves of Byerlys. We thank the Byerlys team for their support of local Minnesota honeybees! Every purchase of Bare Honey goes to support local beekeepers and their honeybees!
You will find 10 ounce jars of Hot Honey, Lavender Blossom Honey, and Vanilla Bean Honey Spread all made with our local Minnesota wildflower honey on the shelves of your local Byerlys Store!
Byerly's Roseville
1601 West County Rd C
Roseville, MN, 55113
Phone: 651-633-6949
Ever wanted to suit up and experience beekeeping? Now you can. Come out and peek in to the secret world of BEES!


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Sunstar Engineering Americas
Weld Shop
Paint Shop
Assembly Line
Penguin Foam and Foamply System (FIPG)
A unique wet apply one component foam in place gasket material and a proprietary FOAMPLY system to mix the material with dry air to create a fast thermal cure flexible polyurethane Foam-in-Place Gasket (FIPG) designed to increase productivity, reduce takt time and the labor costs associated with cut gaskets.
With applications ranging from automotive, appliance and packaging to electronic and industrial components, Penguin Foam is the fastest and simplest way to seal your production parts.
Penguin Foam has been successfully used around the world since 1998. As Sunstar Engineering has production, sales and technical support throughout Asia, Europe and the Americas, the Penguin Foam is ideal for your global programs.
- Penguin Foam 3151 – Link to Technical Leaflet – PLEASE PROVIDE
- Penguin Foam 3160 – Link to Technical Leaflet – PLEASE PROVIDE
Using the same concept as the Penguin Foam Thermal Cure FIPG
products, R&D is developing a one component UV cure PAD
material to replace peel and stick/die cut pads for Buzz, Squeak
and Rattle. The concept will reduce the floor space required as
compared to an oven with the ability to use UV to cure the material
in less than 5 seconds.


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I received a lovely package from Koalascout! Looks like Agatha had a fabulous time in Georgia
Agatha was returned with a lot of souvenirs from her travels. Jewelry sets in blue and purple (her twin Ursula is purple); name charms for Agatha, Ursuala, and me; crocheted blankets for Agatha and Ursula; travel bingo games; scrapbooking stickers; flavored popcorn from the Scouts (Koalascout's son is in Boy Scouts); a mug from Krispy Kreme; and a photo album of all her adventures.
Close up of Agatha in her jewelry and sitting in the mug
Close up of the other jewelry and charms.
My favorite pictures from the album. Cherry the pup is so cute!
Thanks Koalascout!


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We don't currently have the facility to let you know when an item is due back in stock. As we like to offer you new and exciting products regularly, we don't tend to restock a lot of our items again.
You could look for something similar? All you need to do is type a description or trend into the search box on our website. You can narrow down the selection by using our 'Refine By' section on the left hand side of the screen.


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Food Service
Food Service from Cheltenham Catering Supplies
We work with all the major food companies and supply all fresh fruit & veg, ambient food, frozen, dairy etc. Too much to list here but please get in touch and we will prepare a bespoke quote. Again we guarantee to save you money. We stock everything at our warehouse in central Cheltenham and deliver daily.
Why Us?
Everything under 1 roof
Local company, established in 2008
Daily deliveries
We NEVER charge for delivery
No minimum order quantity
We match all Nisbets prices and online offers
We have a much higher level of customer service than the large
national call centres
Exceptional post sales care and a unique sourcing service – if we don't have what you need we'll find it and stock it for you
We guarantee the cheapest prices in the UK on everything we sell
We have a discount structure based on your monthly spend
Orders taken by phone, SMS, email Facebook Messenger… 24hrs a day
Friendly & experienced delivery staff


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Event description
About this Event
LADIES!! This show is two hours long packed with choreographed costume acts and interaction with the audience. It is a huge novelty and will sell out, so buy your tickets ASAP before they do! If you have any questions go to our Facebook and send us a message, or click contact us at the top of the page. Rember to bring your dollar bills!!


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Sarah Fishburn Roberts
Registered Member MBACP
Contact information
- Phone number
- 07725 462810
- Website
- http://www.sarahfishburnroberts.com/
Therapist - HOVE
- Flexible hours available
- Concessionary Rates
About me and my therapy practice
I am a BACP registered counsellor/psychotherapist who is committed to providing my clients with a warm, non-judgemental and safe environment in which to explore the thoughts, feelings and situations that are troubling them. Counselling is an opportunity to examine the difficulties and dilemmas we all face at various times in our lives. It enables us to gain insight and clarity, and to move forward with an increased sense of identity, purpose and meaning. I believe that counselling is about one person having the space to be truly listened to, supported and nurtured by another person. It is about human connection and relationship.
Please go to my website for more information. www.sarahfishburnroberts.com
What I can help with
Eating disorders, Abuse, Anxiety, Depression, Loss, Post-traumatic stress, Trauma, Service veterans, Personal development, AIDS/HIV, Cancer, Health related issues, Self esteem, Spirituality, Child related issues, Infertility, Pregnancy related issues, Relationships, Redundancy, Stress, Work related issues
Types of therapy
Existential, Gestalt, Humanistic, Phenomenological
Clients I work with
How I deliver therapy
Long-term face-to-face work, Short-term face-to-face work, Time-limited


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Hotel Approved for Scottish Mutual site
Plans for the construction of a new £50m hotel in Belfast have been approved by the Department of the Environment.
The hotel development will be at the Scottish Mutual site on College Avenue near the Castle Court Shopping Centre and will be known as the Mutual Hotel. The hotel is expected to have 250 bedrooms built over 10 floors and will be developed by a subsidiary of local design and build company McAleer and Rushe.
This is the latest in a series of new hotels that are planned for Belfast in the near future. The company has owned the site on College Avenue for a number of years and a number of previous planning applications have been made for the site with this latest application being submitted in September 2013. The application and approval will be taken as a further sign of a return to confidence in the local market. A significant number of jobs are expected to be created once construction begins and the entire project is expected to take around 18 months to reach completion.
Janice Gault of the Hotel Federation welcomed the news of the hotel plans adding that: "Belfast has a number of significant projects... Click to read more


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Liberace had a T.V. show that was really popular in the 1950's. His show was especially popular to females. One of the reasons for Liberace's show being such a big deal is because it was one of the first shows to be aired on England television.
[Created by Leslie]
page revision: 1, last edited: 10 Jun 2008 00:08


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Our CMBC season is rounding up and we've got a couple of great events to finish off the season. This Thursday is the last Twoonie race of the season at Mt. McIntyre. No more excuses!!! Come out and ride a fun course, and enjoy some great Yukon Brewing prizes. The registration is at 7:00 pm, with race start at 7:30 pm.
King of the Canyon – the Yukon Mountain Bike Championships – is happening on August 21st. This is an amazing chance to ride some great Yukon trails. Race registration is 10:30 am at Schwatka Lake, with race start at 11:00 am. The race will, once again, feature a long (50ish km) course and short (25ish km) course. I'll be posting more info on the course as soon as I can!


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Signed: Baichōrō Kunisada ga
Publisher: Tsutaya Kichizō
(Marks 556 - seal 03-004)
Censor's seal: aratame
Date: 10/1857
Related links: Museum of Fine Arts, Boston; Tokyo Metropolitan Library; National Diet Library; Staatsbibliothek, Berlin; National Museums Scotland ; Mead Art Museum, Amherst; A chart of Genji mon; Staatsbibliothek Berlin - #28; Lyon Collection - another print from this series;Art and Design Library, Edinburgh ;
Two figures in a butterfly dance. The whitish shell cartouche in the upper right corner gives the title of this series: 紫式部げんじかるた. The red shell cartouche gives the Genji mon and the corresponding chapter number.
This print is listed in Genji's World by Andreas Marks, 2012, but not illustrated.


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Coffee news started, by Jean Daum, in Winnipeg, Canada is a weekly information publication that's delivered to restaurants, espresso shops, reward outlets, motels and other small eateries and retailers. The best way to do this is to make sure the discharge is a story and not merely an commercial for what you are promoting. As a potential dwelling based mostly enterprise proprietor, exploring the espresso news publication can open the home windows of large cash making opportunities. A main information report is placed on the entrance web page with a giant headline and a large picture.
News items might be as soon as a day, features as soon as every week and interviews as soon as a month. Business owners can use press releases to give them these good tales whereas making a reputation for his or her company. Employee newsletters can also be a good way to interrupt down silos within a corporation by permitting you to share the activities and news from one division across the wider group. Mass media are particularly effective to unfold present information having information values.
If solar's power share amongst renewable energies reaches its forecast of 5% in 2020, it will translate into global cumulative installed capability of 560 gigawatts. Coffee information has benefits to local advertisers that bigger print publications can't provide.
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can you please confirm to me if booking in advance is required? can you please tell me the various room rate. is there any service that we can call from To? Thank you for your time Regards
Question about Mamzar Beach
This is a beach review not a hotel review - if you're looking for a hotel you can use the hotel tab and it should show you a whole lot of hotel options nearby.


text: Home > Bookshop > Australian Children's Books > Australian Children's Books - General « Back Elysium: A Paranormal Adventure Jinks, Catherine Our Price Retail Price AUD$14.95 Your Price AUD$12.70 Minimum Order: 1 In Stock (1) Dispatch: 1 day Elysium: A Paranormal Adventure/Jinks, Catheri/Paper/1741140811/S034-G AUD$12.70 QTY Gift Wrapping Add Gift Wrapping (click checkbox) If you would like a gift wrapping message, please add it in the Notes section on the checkout page, thank you. AUD$2.95 Publisher: Allen & Unwin ISBN-13: 9781741140811 Series: Allie's Ghost Hunters, Case 4 Binding: Paperback Year Published: 2007 Another deliciously spooky paranormal mystery for Allie's Ghost Hunters to solve, this time at the Jenolan Caves, where something is on the trail of Allie and her family .... Full of suspense, mystery and humour, the books in this series follow Allie as she investigates a number of possibly paranormal events with a mix of logic, intelligence and teenage attitude. The Jenolan Caves Ghost Tour sounded like the perfect weekend for a ghost hunter. But I didn't realise I was letting myself in for a whole lot more than just a haunted hotel and endless family squabbles. Something was on our trail. Something vicious, mysterious, and very, very smelly à ID: 64346 Code: AD001058


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Project Zomboid is an open-world, survival horror game developed by The Indie Stone for Microsoft Windows, Mac OS and Linux. At the moment the game is a single player game, in which you take on the role of Bob Smith, a man looking after his injured wife.
The story in Project Zomboid is a little vague at this point, due to it only being in Alpha. However, as Bob Smith you must protect your wife from the horde of the undead by gathering food, water and bandages to heal her wounds. In despair, Bob and Kate quickly take shelter in a home they found in Knox County. But be warned, undead aren't always the only threat.


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Topic: Law
Construction projects can be complicated processes, ones that balance multiple budgets and companies who are all coming together to literally build something great. For these kinds of projects, legal representation is key ( https://Actslaw.com/Construction-attorney ), and that is why most people and companies solicit the services of a construction attorney in Los Angeles. Armed with knowledge and experience, a construction attorney can help you with a number of aspects of your construction projects. Here are just a few ways in which they can help you.
1. Drafting and Negotiating Construction Contracts
One of the major duties for construction attorneys is drafting and negotiating construction contracts. These documents, whether they are for a relatively small renovation or a brand-new condo development, are extremely complicated documents.Drafting them up and negotiating on their terms requires someone who is familiar with local building practices, local construction laws, permits, worker's rights, and more. Without an experienced and professional construction attorney in Los Angeles, your contracts may not be as air tight as necessary, or they may leave out important stipulations.
With solid contracts, it is also easier for you to challenge any defects or issues that arise before, during, or after construction, and having legal representation can ensure any oversights or mistakes are corrected in a timely fashion. Without the right contracts and the right representation from a construction attorney in Los Angeles, however, you could end up with a project that isn't what you expected and no available recourse.
2. Recover Unpaid Sums
Sometimes, those who owe money try to get out of their bills. In the construction industry, it's more than spotting a friend money for dinner when they forget their wallet. This can be substantial amounts of money. In those instances, it pays to have a construction attorney in Los Angeles who will take the right action to ensure you are paid what you are owed.
3. Help Draft Construction Proposals
Before your project gets underway, you will need to submit a proposal to a number of different bodies, ranging from fellow investors to governmental bodies. A construction attorney in Los Angeles can help you draft proposals that touch on everything everyone needs to know, all while respecting the guidelines and expectations of each body. This can lead to better proposals that get approved with fewer changes or hassles.
4. Representation in Court
While most construction attorneys in Los Angeles spend more time at their desks and negotiating tables than in court, they are able to represent and fight for you in the court of law. They will do everything they can to ensure that your case is the best it can be, and that it is presented in a way that is compelling and convincing. They also understand how the courts work and can help you ensure that your case has the best chance of winning possible.
A construction attorney in Los Angeles is a legal professional who can help you with a number of issues related to construction, renovations, workers' rights, and more. They can help at almost every stage of your construction project, from drafting up initial contracts to gathering final unpaid invoices. If you are looking for a construction attorney ( https://Actslaw.com/About-us ), be sure to find a professional, experienced firm that can handle your case and help you in your future construction legal matters.
Posted by brucem231 at 6:42 AM EDT


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Cash seized from criminals has paid for £1.7 million of projects in Falkirk and West Lothian districts, helping the most deprived areas.
Cash seized from criminals has paid for £1.7 million of projects in Falkirk and West Lothian districts, helping the most deprived areas.
A total of £851,198 has been spent in West Lothian with a further £868,270 in Falkirk from the Scottish Government's Cashback for Communities scheme since it began in 2008.
The policy invests money confiscated from the proceeds of crime into good causes and money is distributed to local projects through national organisations such as the Scottish Football Association (SFA), Youth Link, Boxing Scotland and Creative Scotland.
Among the projects in Linlithgow are the Linlithgow Young People Project with Youthlink Scotland; Basketball Scotland work in Bridgend; Bank of Scotland Midnight Leagues for footballers at Linlithgow's Xcite sports centre; youth rugby coaching courses at Linlithgow Academy and primary schools; grants for Scout groups.
In Bo'ness projects are cash for youngsters to deliver Easter holiday provision for activities through the Duke of Edinburgh Award; money to set up a committee for a Youth Summit for expeditions; rugby at Bo'ness schools; youth engagement programme with Falkik Community Trust at schools and community centres; employment opportunities with The Prince's Trust Development Awards.
A further £17 million of funding has now been announced by the government with applications for grants to begin again early in the summer.
Justice Secretary and Falkirk West MSP Michael Matheson said: "I am extremely pleased to be able to announce a further £17 million of funding for the unique CashBack for Communities programme.
"This substantial amount will go a long way to changing the lives of our young people and it seems only fitting that this money seized from the criminals who seek to peddle misery in some of our most disadvantaged communities is reinvested back in to those same areas.
"We have made it clear that we want Scotland to be the best place to grow up and part of achieving that goal is making sure all of our young people have the best possible start in life.
"That is why this government created the CashBack for Communities programme and why we continue to support the valuable work it does."