text:
Scandal fans have only one more season to go before the drama ends its term at the White House. ABC is reportedly set to announce the end of the Shonda Rhimes production next week with the upcoming season 7 being the final one.
According to TVLine, the series announcement will be made at ABC's upfront presentation in New York on 16 May. ABC and ShondaLand have declined to comment.
Rhimes, who helms the political thriller centred on Olivia Pope (Kerry Washington) and her crisis management firm's relationship with the White House, has hinted time and again that the show would soon find itself closing, despite its high TV ratings.
"I've already decided when Scandal is ending," she previously told The Hollywood Reporter. "I think there's only so much Scandal you can tell satisfactorily."
In January, ABC also confirmed that the executive producer had an end date in mind. "I would say yes, in Shonda's head," ABC Entertainment chief Channing Dungey said regarding Rhimes' plans to end the show. "I know already that she has some great ideas for next season, which will be season seven. We have not really talked about what happens after that. But I love the show and I would happily keep the show on as long as she feels that she has creative runway to write the show."
Scandal has been one of the network's strongest weekday shows and helped ABC gain a Thursday night stronghold. In February, the show was confirmed for a seventh season along with Rhimes' Grey's Anatomy and How To Get Away With Murder.


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Posts Tagged Consumer protection
Salvoni v Fiermonte. CJEU confirms quasi-notarial nature of Brussels Ia's Article 53 certificate, other than for provisional measures. Consumer protection cannot be raised at that stage. Also rejects interpretative force of substantive consumer law rules for jurisdictional issues.
Posted by Geert van Calster in Conflict of Laws /Private international law on 06/09/2019
I reviewed Bobek AG Opinion in Case C-347/18 Salvoni v Fiermonte earlier. The referring court enquires whether the court of origin tasked with issuing the Article 53 Certificate (issued with a view to enabling swift recognition and enforcement) may, of its own motion, seek to ascertain whether the judgment whose enforcement is sought was issued in breach of the rules on jurisdiction over consumer contracts, so that it may, where appropriate, inform the consumer of any such breach and enable her to consider the possibility of opposing enforcement of the judgment in the Member State addressed.
The CJEU has entirely confirmed the AG's Opinion (no English version at the time of posting): no such second-guessing of jurisdiction.
At 34 ff the Court points out an important distinction with certificates issued with a view to enforcing provisional measures: there, the court issuing the certificate does carry out jurisdictional review (whether the court ordering the measures has jurisdiction as to the substance of the case).
At 40 ff the Court also confirms that substantive consumer protection laws (such as Directive 93/13) do not transfer to the procedural /jurisdictional rules of Brussels Ia: an important conclusion overall.
(Handbook of) European private international law, 2nd ed. 2016, Chapter 2, Heading 18.104.22.168, Heading 2.2.16.
Bobek AG in Salvoni v Fiermonte. Brussels Ia's Article 53 certificate and consumer protection.
Posted by Geert van Calster in Conflict of Laws /Private international law on 11/06/2019
Bobek AG Opined early May (excuse posting delay) in Case C-347/18 Salvoni v Fiermonte. The referring court enquires whether the court of origin tasked with issuing the Article 53 Certificate (issued with a view to enabling swift recognition and enforcement) may, of its own motion, seek to ascertain whether the judgment whose enforcement is sought was issued in breach of the rules on jurisdiction over consumer contracts, so that it may, where appropriate, inform the consumer of any such breach and enable her to consider the possibility of opposing enforcement of the judgment in the Member State addressed.
A related issue therefore to the CJEU judgment in Weil last week.
Mr Alessandro Salvoni, a lawyer based in Milan, asked the Tribunale di Milano (District Court, Milan) to issue Ms Anna Maria Fiermonte (who resides in Hamburg) with a payment order for an amount owed to him as consideration for the professional services rendered by him in connection with legal proceedings concerning a will. Payment order was granted, no challenge was made by Ms Fiermonte (at 24 the AG emphasises that evidently, the court needs to check whether proper service was made). Mr Salvoni then requested the same court to issue the Article 53 Certificate with respect to that order. However this time the same court (with the AG at 22 one can assume that composition was different) proprio motu (and belatedly: see at 15) classified the relationship as B2C under the relevant provisions of Brussels Ia. Ms Fiermonte should have been sued in Hamburg.
Bobek AG courteously calls the court's initiative ingenious and well-intended (at 29) but has no choice but to conclude that the Regulation simply has no tool for the Court somehow to mitigate let alone correct its earlier mistake. In a gesture effectively of public service (at 34; this rescues something useful from the otherwise fairly futile exercise; I doubt the CJEU will do something similar), the AG then rephrases the question into a more general one, which is detached from the specific course of action apparently contemplated by the national court: Is a national court, when issuing the Article 53 Certificate, entitled (or even obliged), under EU law, to ascertain whether the judicial decision that is to be certified was issued in breach of the rules on jurisdiction over consumer contracts?
At 44 ff the AG delightfully side-steps the chicken and hen issue of the C-54/96 Dorsch criteria (is an A53 court a 'court' entitled to preliminary review under Article 267 TFEU) and eventually concludes that there is no room for the A53 Court to assess the application of the consumer title. At 54: '
The interpretation of [A53] proposed by the referring court cannot easily be reconciled with the above considerations [speed; simplicity: GAVC]. In particular, that interpretation would in effect back-pedal on one of the main features of the new system introduced by Regulation No 1215/2012. Indeed, the checks that were previously made in the Member State addressed when issuing the exequatur would not be eliminated, but merely shifted to the certification stage carried out in the Member State of origin. That reading of the provision would thus run against the logic and spirit of Regulation No 1215/2012.'
At 81 and 82 the likely outcome of course is pointed at by the AG: Article 45(1)(e)(i) and Article 46 BIa grant consumers a special ground of refusal of recognition and enforcement in cases where the judgment in question conflicts with the jurisdictional rules for the protected categories. This ground has now been handed Ms Fiermonte on a plate – leaving the Milan courts with red cheeks.
(Handbook of) European private international law, 2nd ed. 2016, Chapter 2, Heading 18.104.22.168, Heading 2.2.16.
Pillar Securitisation v Hildur Arnadottir. Material EU consumer law does not dictate jurisdictional rules.
Posted by Geert van Calster in Conflict of Laws /Private international law on 07/05/2019
The CJEU held last week in C-694/17 Pillar Securitisation (v Hildur Arnadottir), on the Lugano Convention's protected category of consumers. I have review of Szpunar AG's Opinion here. The issues that are being interpreted are materially very similar as in Brussels I Recast hence both evidently have an impact on the Brussels I Recast Regulation, too (see in that respect also C‑467/16 Schlömp).
At stake in Pillar Securitisation is the meaning of 'outside his trade or profession' in the consumer title. The CJEU at 22 rephrases the case as meaning 'in essence, whether Article 15 of the Lugano II Convention must be interpreted as meaning that, for the purposes of ascertaining whether a credit agreement is a credit agreement concluded by a 'consumer' within the meaning of Article 15, it must be determined whether the agreement falls within the scope of Directive 2008/48 in the sense that the total cost of credit in question does not exceed the ceiling set out in Article 2(2)(c) of that directive and whether it is relevant, in that regard, that the national law transposing that directive does not provide for a higher ceiling.'
The CJEU notes that Pillar Securitisation claims that Ms Arnadottir acted for professional purposes and is not covered by the definition of a 'consumer'. However, the referring court has not referred any question to the Court on the purpose of the credit agreement concluded. On the contrary, as is clear from the wording of the question that it did refer, the referring court asks its question to the Court on the assumption that the contract at issue was concluded for a purpose that can be regarded as being outside Ms Arnadottir's profession. In addition, in any event, the order for reference does not contain sufficient information in order for the Court to be capable, where relevant, of providing useful indications in that regard (not much help therefore to assist with the interpretation of issues such as in Ang v Reliantco, on which I shall be reporting next).
As I wrote in my review of the AG's Opinion: the issue is how far does material EU law impact on its private international law rules. I referred in my review to the need to interpret Vapenik restrictively, and to Kainz in which the CJEU itself expressed caution viz the consistent interpretation between jurisdictional and other EU rules, including on applicable law and on substantive law.
I am pleased to note the Court itself makes the same observation, and emphatically so: at 35: 'the need to ensure consistency between different instruments of EU law cannot, in any event, lead to the provisions of a regulation on jurisdiction being interpreted in a manner that is unconnected to the scheme and objectives pursued by that regulation.' Subsequently establishing the very diffeent purposes of both sets of law, the CJEU rejects impact on one over the other (and also remarks that Pillar Securitisation's reference to the Pocar report needs to be taken in context: prof Pocar referred to Directive 2008/48 by way of example only).
Conclusion: for the purposes of ascertaining whether a credit agreement is a credit agreement concluded by a 'consumer' within the meaning of Article 15, it must not be determined whether the agreement falls within the scope of Directive 2008/48 in the sense that the total cost of credit in question does not exceed the ceiling set out in Article 2(2)(c) of that directive, and it is irrelevant, in that regard, that the national law transposing that directive does not provide for a higher ceiling.
A good judgment.
(Handbook of) European Private International Law, 2nd ed. 2016, Chapter 2, Heading 184.108.40.206.
Milivojević v Raiffeisenbank: Free movement of services yet also protected categories and rights in rem /personam.
Posted by Geert van Calster in Conflict of Laws /Private international law on 13/03/2019
The CJEU held in C-630/17 Milivojević v Raiffeisenbank on 14 February. The case in the main concerns Croatian legislation restricting financial services with Banks other than Croatian ones – a free movement of services issue therefore which the CJEU itself explains in its press release.
Of relevance to the blog is the issue of jurisdiction under the consumer title and Article 24(1)'s exclusive jurisdictional rule.
The Croatian legislation at issue, in the context of disputes concerning credit agreements featuring international elements, allows debtors to bring an action against non-authorised lenders either before the courts of the State on the territory of which those lenders have their registered office, or before the courts of the place where the debtors have their domicile or registered office and restricts jurisdiction to hear actions brought by those creditors against their debtors only to courts of the State on the territory of which those debtors have their domicile, whether the debtors are consumers or professionals.
Croatian law therefore first of all infringes Article 25(4) juncto Article 19 Brussels Ia. Their combined application does not rule out choice of court even between a business and a consumer (subject to limitations which I do not discuss here). It moreover infringes Article 25 (and Article 4) in and of itself for it precludes choice of court even in a B2B context.
Next, may a debtor who has entered into a credit agreement in order to have renovation work carried out in an immovable property which is his domicile with the intention, in particular, of providing tourist accommodation services be regarded as a 'consumer' within the meaning of Article 17(1) Brussels Ia? Reference is made ex multi to Schrems, emphasising the difficult balancing exercise of keeping exceptions to Article 4's actor sequitur forum rei rule within limits, yet at the same time honouring the protective intention of the protected categories.
A person who concludes a contract for a dual purpose, partly for use in his professional activity and partly for private matters, can rely on those provisions only if the link between the contract and the trade or profession of the person concerned was so slight as to be marginal and, therefore, had only a negligible role in the context of the transaction in respect of which the contract was concluded, considered in its entirety (per Schrems following C-464/01 Gruber). Whether Ms Milivojević can so be described as a 'consumer' is for the national court to ascertain.
Finally, does Article 24(1)'s rule on an action 'relating to rights in rem in immovable property', apply to an action for a declaration of the invalidity of a credit agreement and of the notarised deed relating to the creation of a mortgage taken out as a guarantee for the debt arising out of that agreement and for the removal from the land register of the mortgage on a building?
Reference here is made to all the classics, taking Schmidt v Schmidt as the most recent portal to earlier case-law. At 101: with regard to the claims seeking a declaration of the invalidity of the agreement at issue and of the notarised deed related to the creation of a mortgage, these 'clearly' (I assume based on the national law at issue) are based on a right in personam which can be claimed only against the defendant.
However at 102: re the request for removal from the land register of the registration of a mortgage, it must be noted that the mortgage, once duly constituted in accordance with the procedural and substantive rules laid down by the relevant national legislation (see indeed my comment above re passerelle of national law), is a right in rem which has effects erga omnes. Such an application does fall within Article 24(1). At 104 the Court again inadvertently or not highlights the potential for a procedural strategy, opening up forum connexitatis hinging unto A24(1) exclusivity: 'in the light of that exclusive jurisdiction of the court of the Member State in which the immovable property is situated to the request for removal from the land register for the registration of mortgages, that court also has a non-exclusive jurisdiction based on related actions, pursuant to Article 8(4) of Regulation No 1215/2012, to hear claims seeking annulment of the credit agreement and the notarised deed related to the creation of that mortgage, to the extent that these claims are brought against the same defendant and are capable, as is apparent from the material in the file available to the Court, of being joined.' (idem in Schmidt v Schmidt).
(Handbook of) European Private International Law, 2nd ed. 2016, Chapter 2, Heading 2.2.6, Heading 184.108.40.206.
Bosworth (Arcadia Petroleum), and Pillar Securitisation v Hildur Arnadottir. Two AGs on protected categories (consumers, employees) in the Lugano Convention- therefore also Brussels I Recast.
Posted by Geert van Calster in Conflict of Laws /Private international law on 29/01/2019
Update 11 April 2019. The CJEU held today in Bosworth: no contract for employment. the AG's Opinion and Gross J's analysis confirmed.
Update 06 02 2018 I have inserted in the analysis below of Arcadia, a reference to De Bloos, in the context of the forumshopping considerations (I have also tidied up punctuation in that section).
Twice last week did the Lugano Convention's protected categories title feature at the Court of Justice. On Tuesday, Szpunar AG opined in C-694/17 Pillar Securitisation v Hildur Arnadottir (consumer protection), and on Thursday Saugmansgaard ØE opined in C-603/17 Bosworth (Arcadia Petroleum) (employment contracts).
The issues that are being interpreted are materially very similar as in Brussels I Recast hence both evidently have an impact on the Brussels I Recast Regulation, too.
At stake in Pillar Securitisation (no English version of the Opinion at the time of writing) is the meaning of 'outside his trade or profession' in the consumer title. Advocate General Szpunar takes the case as a trigger to fine-tune the exact relationship between private international law such as was the case, he suggests, in Kainz and also in Vapenik.
I wrote in my review of Vapenik at the time: 'I disagree though with the Court's reference to substantive European consumer law, in particular the Directive on unfair terms in consumer contracts. Not because it is particularly harmful in the case at issue. Rather because I do not think conflict of laws should be too polluted with substantive law considerations. (See also my approval of Kainz).'
Ms Arnadottir's case relates to the Kaupting reorganisation. Her personal loan exceeded one million € and therefore is not covered by Directive 2008/48 on credit agreements for consumers (maximum threshold there is 75K). Does that exclude her contract being covered by Lugano's consumer Title?
The Directive's core notion is 'transaction', as opposed to Lugano's 'contract' (at 30 ff). And the Advocate-General of course has no option but to note the support given by the Court to consistent interpretation, in Vapenik. Yet at 42 ff he suggests a narrow reading of Vapenik, for a variety of reasons, including
- the presence, here, of Lugano States (not just EU Member States);
- the need for consistent interpretation between Lugano and Brussels (which does not support giving too much weight to EU secondary law outside the private international law sphere);
- and, most importantly, Kainz: a judgment, unlike Vapenik, which directly concerns Brussels I (and therefore also the link with Lugano). One of the implications which as I noted a the time I like a lot, is precisely its respect for the design and purpose of private international law rules as opposed to other rules of secondary law; and within PIL, the distinction between jurisdiction and applicable law.
At 52 ff Advocate General Szpunar rejects further arguments invoked by parties to suggest the consumer title of the jurisdictional rules should be aligned with secondary EU consumer law. His line of reasoning is solid, however: autonomous interpretation of EU private international law prevents automatic alignment between consumer law and PIL.
Should the CJEU follow its first Advocate General, which along Kainz I suggest it should, no doubt distinguishing will be suggested given the presence of Lugano parties in Pillar Securitisation – yet the emphasis on autonomous interpretation suggest a wider calling.
C‑603/17 Bosworth v Arcadia then was sent up to Luxembourg by the UK's Supreme Court [UKSC 2016/0181, upon appeal from [2016] EWCA Civ 818]. It concerns the employment Title of Lugano 2007. (Which only the other week featured at the High Court in Cunico v Daskalakis).
As helpfully summarised by Philip Croall, Samantha Trevan and Abigail Lovell, the issue is whether the English courts have jurisdiction over claims for conspiracy, breach of fiduciary duty, dishonest assistance and knowing receipt brought against former employees of certain of the claimant companies now domiciled in Switzerland. In the main proceedings, the referring court must therefore determine whether the courts of England and Wales have jurisdiction to rule on those claims or whether it is the courts of Switzerland, as courts of the domicile of the former directors implicated, that must hear all or part of the claims.
Gross J at the Court of Appeal had applied Holterman and Brogsitter, particularly in fact the Opinion of Jääskinen AG in Brogsitter – albeit with caution, for the AG's Opinion was not adopted 'wholesale' by the CJEU (at 58, Court of Appeal). The mere fact that there is a contract of employment between parties is not sufficient to justify the application of the employment section of (here) the Lugano Convention. Gross J at 67: "do the conspiracy claims relate to the Appellants' individual contracts of employment? Is there a material nexus between the conduct complained of and those contracts? Can the legal basis of these claims reasonably be regarded as a breach of those contracts so that it is indispensable to consider them in order to resolve the matter in dispute?". Gross J had answered that whilst not every conspiracy would fall outside the relevant section, and those articles could not be circumvented simply by pleading a claim in conspiracy, in the circumstances of this case, however precisely the test was formulated, the answer was clearly "no". Key to the alleged fraud lay in his view not in the appellants' contracts of employment, but in their de facto roles as CEO and CFO of the Arcadia Group.
The facts behind the case are particularly complex, as are the various wrongdoings which the directors are accused of and there is little merit in my rehashing the extensive summary by the AG (the SC's hearings leading to the referral lasted over a day and a half).
Saugmansgaard ØE essentially confirms Gross J's analysis.
Company directors who carry out their duties in full autonomy are not bound to the company for which they perform those duties by an 'individual contract of employment' within the meaning of the employment section – there is no subordination (at 46). Note that like Szpunar SG, Saugmansgaard ØE too emphasises autonomous interpretation and no automatic colouring of one field of EU law by another: 'the interpretation which the Court of Justice gives to a concept in one field of EU law cannot automatically be applied in a different field' (at 49).
In the alternative (should the CJEU accept a relationship of employment), he opines that a claim made between parties to such a 'contract' and legally based in tort does fall within the scope of that section where the dispute arose in connection with the employment relationship. Secondly, he argues that an 'employer' within the meaning of the provisions of that section is not necessarily solely the person with whom the employee formally concluded a contract of employment (at 109). What the AG has in mind are group relations, where 'an organic and economic link' between two companies exists, one of whom sues even if the contract of employment is not directly with that company.
It is in this, subsidiary section, at 66 ff, that the AG revisits for the sake of completeness, the difference between 'contract' and 'tort' in EU pil. This is a section which among others will delight (and occupy) one of my PhD students, Michiel Poesen, who is writing his PhD on same. Michiel is chewing on the Opinion as we speak and no doubt will soon have relevant analysis of his own.
At 82 ff the AG points to the difficulties of the Brogsitter and other lines of cases. '(T)he case-law of the Court is ambiguous, to say the least, in so far as concerns the way in which Article 5(1) and Article 5(3) of the Brussels I Regulation and the Lugano II Convention are to be applied in cases where there are concurrent liabilities. It would be useful for the Court to clarify its position in this regard.'
At 83: it is preferable to adopt the logic resulting from [Kalfelis] and to classify a claim as 'contractual' or 'tortious' with regard to the substantive legal basis relied on by the applicant. At the very least, the Court in the AG's view should hold on to a strict reading of the judgment in Brogsitter': at 79: 'the Court meant to classify as 'contractual' claims of liability in tort the merits of which depend on the content of the contractual duties binding the parties to the dispute.' This in the view of the AG should be so even if (at 84) this authorises a degree of forum shopping, enabling the applicant to choose jurisdiction, with an eye to the appropriate rules. The AG points out that forum shopping particularly for special jurisdictional rules, is not at all absent from either Regulation or Convention.
Forum shopping considerations in (now) Article 7(1) have been an issue since the seminal case of De Bloos, C-14/76: at 13: 'for the purposes of determining the place of performance within the meaning of Article 5, quoted above, the obligation to be taken into account is that which corresponds to the contractual right on which the plaintiff's action is based.' Among others Brogsitter may be seen as an attempt by the Court to manage the forum shopping considerations arising from De Bloos. It would be good for the Court to clarify whether De Bloos is still good authority, given the many textual changes and case-law considerations of (now) Article 7(1).
Finally, there is of course an applicable law dimension to the dispute although this does not feature in the reference. The relationships between companies and their directors are governed not by employment law, but by company law (at 52). For an EU judge, the Rome I and Rome II Regulations kicks in. Rome I contains, in Article 8, provisions relating to 'individual employment contracts', however it also provides, in Article 1(2)(f), that 'questions governed by the law of companies' concerning, inter alia, the 'internal organisation' of companies are excluded from its scope (at 55). Rome II likewise has a company law exemption. That puts into perspective the need (or not; readers know that I am weary of this) to apply Rome I and Brussels /Lugano consistently.
One had better sit down for a while when reviewing these Opinions.
Handbook of) European Private International Law, 2nd ed. 2016, Chapter 2, Heading 22.214.171.124, Heading 18.104.22.168, Heading 18.104.22.168.9.
Jurisdiction re prospectus liability. CJEU reiterates Universal Music in Löber v Barclays. Unfortunately fails to identify the exact locus damni and leaves locus delicti commissi unaddressed.
Posted by Geert van Calster in Conflict of Laws /Private international law on 14/09/2018
I reviewed Advocate-General Bobek's Opinion in C-304/17 Löber v Barclays here. The following issues in particular were of note (I simply list them here; see the post for full detail): First, the AG's view, coinciding with mine, that the CJEU's finding in CDC that locus damni for a pure economic loss, in the case of a corporation, is the place of its registered office, is at odds with precedent (he made the same remark in flyLAL). Next, on locus delicti commissi, the AG suggests that despite Article 7(2)'s instruction, a single ldc within the Member State in the case at hand cannot be determined. Further, for locus damni, I disagree for reasons explained in the post with the AG's suggestions.
The Court held on Wednesday. At 26 it immediately cuts short any expectation of clarification on locus delicti commissi: 'In the present case, the case in the main proceedings concerns the identification of the place where the damage occurred.'
The referring court's questions were much wider, asking for clarification on 'jurisdiction' full stop. Yet the Court must have derived from the file that only locus damni was in dispute. A missed opportunity for as I noted, Bobek AG's views on that locus delicti commissi are not obvious.
On locus damni then, I may be missing a trick here but the Court simply does not answer the referring court's question. As the AG notes, Ms Löber in order to acquire the certificates, transferred the corresponding amounts from her current (personal) bank account located in Vienna, to two securities 'clearing' accounts in Graz and Salzburg. Payment was then made from those securities accounts for the certificates at issue. The Court refers to Kolassa and to Universal Music, to reiterate that the simple presence of a bank account does not suffice to establish jurisdiction: other factors are required, such as here, at 33,
'besides the fact that Ms Löber, in connection with that transaction, had dealings only with Austrian banks, it is furthermore apparent from the order for reference that she acquired the certificates on the Austrian secondary market, that the information supplied to her concerning those certificates is that in the prospectus which relates to them as notified to the Österreichische Kontrollbank (Austrian supervisory bank) and that, on the basis of that information, she signed in Austria the contract obliging her to make the investment, which has resulted in a definitive reduction in her assets.'
The Court concludes that 'taken as a whole, the specific circumstances of the present case contribute to attributing jurisdiction to the Austrian courts.'
That however was not seriously in doubt: the more specific question is which one: Vienna? (which had rejected jurisdiction) Graz and /or Salzburg? Article 7(2) requires identification of a specific court (which the AG had identified in his opinion: I may not follow his argumentation, but it did lead to a specific court): not merely a Member State, and the Oberster Gerichtsthof had specifically enquired about the need for centralisation of the claim in one place.
All in all a disappointing judgment which will not halt further questions on jurisdiction for prospectus liability.
(Handbook of) EU Private International Law, 2nd ed. 2016, Chapter 2, Heading 22.214.171.124.7
Jurisdiction re prospectus liability (misrepresentation) before the CJEU again. Bobek AG in Löber v Barclays.
Posted by Geert van Calster in Conflict of Laws /Private international law on 30/05/2018
Even Advocate-General Bobek has not managed to turn jurisdictional issues re prospectus liability into the prosaic type of analysis which many of us have become fond of. His Opinion in C-307/17 Löber v Barclays is a lucid, systematic and pedagogic review of the CJEU's case-law on (now) Article 7(2)'s jurisdiction for tort in the context of 'prospectus liability' aka investment misrepresentation. Starting with the direct /indirect damage distinction; and focusing of course on the determination of pure economic loss.
Ms Helga Löber invested in certificates in the form of bearer bonds issued by Barclays Bank Plc. In order to acquire those certificates, the corresponding amounts were transferred from her current (personal) bank account located in Vienna, Austria to two securities accounts in Graz and Salzburg. Payment was then made from those securities accounts for the certificates at issue.
Note immediately that the jurisdictional discussion is a result of Article 7(2) not just identifying a Member State: it identifies specific courts within that Member State. Here: claimant brought her claim before a court in Vienna, the place of her domicile. This is also where her current bank account is located, from which she made the first transfer in order to make the investment. The first- and second-instance courts in Vienna however decided that they did not have jurisdiction to hear the case. The case is now pending before the Oberster Gerichtshof (Supreme Court, Austria). That court is asking, in essence, which of the bank accounts used, if any, is relevant to determine which court has jurisdiction to hear the claim at issue.
Close reference is made to Kolassa. In my posting on that case at the time, I noted that the many factual references which the Court built in in its decision, gave it dubious precedent value. Bobek AG in Löber necessarily therefore distinguishes many factual situations. The almost sole focus lies on 7(2): unlike in Kolassa, contracts neither consumer contracts are an issue.
Here are a few things of note:
First, in his review of the existing case-law the AG at 38 points out like I did at the time of the judgment, that the CJEU's finding in CDC that locus damni for a pure economic loss, in the case of a corporation, is the place of its registered office, is at odds with precedent (he made the same remark in flyLAL).
Next, on locus delicti commissi, the AG suggests that despite Article 7(2)'s instruction, a single ldc within the Member State cannot be determined. The relevant point in his view is the moment from which the prospectus can, by operation of law, start influencing the investment behaviour of the relevant group of investors. In the present case, and considering the national segmentation of the capital market regulation at issue, that relevant group is made up of investors on secondary markets in Austria. At 65: once it became possible to offer the certificates on the Austrian secondary market, that possibility was immediately available for the whole territory of Austria. 'The nature of the tort of misrepresentation at issue does not allow for the identification of a location within the national territory because once the author of the tort is allowed to influence the given national territory, that influence immediately covers the whole territory, irrespective of the actual means used for the publication of a specific prospectus.' As we know from CDC, the Court does not readily accept that a single ldc cannot be determined.
Further, for locus damni, the AG suggests (at 78) 'The place where…a legally binding investment obligation is factually assumed… The exact location of such a place is a matter for the national law considered in the light of available factual evidence. It is likely to be the premises of a branch of the bank where the respective investment contract was signed, which may correspond, as in the Kolassa case, to the place where the bank account is held.' That in my view first of all is not a warranted outcome. The investor in Löber is not a consumer within the protected categories of the Regulation. Suggesting the place of conclusion of the obligation leaves room for the claimant to manipulate the forum of any future suit in tort. This is exactly what the Court objected to in Universal Music. Moreover, note the reference to 'the national law'. It is quite unusual to suggest such a role for lex fori in light of the principle of autonomous interpretation. Unless the AG in fact means the 'lex contractus', presumably to be determined applying Rome I.
In summary there are quite a few open questions here – not something of course which I would necessarily object to.
(Handbook of) EU Private International Law, 2nd ed. 2016, Chapter 2, Heading 126.96.36.199.7
Planet49: pre-ticked agreement with clauses in terms and conditions.
Posted by Geert van Calster in Conflict of Laws /Private international law on 08/03/2018
Update 1 October 2019 the CJEU held today and as expected found such agreements to be invalid. Update 21 March 2019. Szpunar AG opined today and suggests there is no such valid consent. Update 14 November 2018 Hearing took place yesterday – Opinion AG scheduled for 28 February 2019.
A quick flag to those of you following consumer protection and the Directive (2002/58) on privacy and electronic communications. In Case C-673/17 Planet49 the Court of Justice is being asked to clarify to what extent a website which pre-ticks boxes in general terms and conditions (here: to share relevant personal data) is compatible with relevant EU laws.
File of the case here (in Dutch only).
Douez v Facebook: Consumers as protected categories in Canadian conflict of laws.
Posted by Geert van Calster in Conflict of Laws /Private international law on 07/03/2018
Postscript 16 May 2018 Tanya Monestier article re same here.
Thank you Stephen Pittel for flagging 2017 SCC 33 Douez v Facebook Inc. Stephen also discusses the forum non conveniens issue and I shall leave that side of the debate over to him. What is interesting for comparative purposes is the Supreme Court's analysis of the choice of court clause in consumer contracts, which it refuses to enforce under public policy reasons, tied to two particular angles:
- 'The burdens of forum selection clauses on consumers and their ability to access the court system range from added costs, logistical impediments and delays, to deterrent psychological effects. When online consumer contracts of adhesion contain terms that unduly impede the ability of consumers to vindicate their rights in domestic courts, particularly their quasi-constitutional or constitutional rights, public policy concerns outweigh those favouring enforceability of a forum selection clause.' (emphasis added)
Infringement of privacy is considered such quasi-constitutional right.
- 'Tied to the public policy concerns is the "grossly uneven bargaining power" of the parties. Facebook is a multi-national corporation which operates in dozens of countries. D is a private citizen who had no input into the terms of the contract and, in reality, no meaningful choice as to whether to accept them given Facebook's undisputed indispensability to online conversations.'
With both angles having to apply cumulatively, consumers are effectively invited to dress up their suits as involving a quasi-constitutional issue, even if all they really want is their PSP to be exchanged, so to speak. I suspect however Canadian courts will have means of sorting the pretended privacy suits from the real ones.
A great judgment for the comparative binder (see also Jutta Gangsted and mine paper on forum laboris in the EU and the US here).


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Social Media in an English Village
Daniel Miller
Daniel Miller spent 18 months undertaking an ethnographic study with the residents of an English village, tracking their use of the different social media platforms. Following his study, he argues that a focus on platforms such as Facebook, Twitter and Instagram does little to explain what we post on social media. Instead, the key to understanding how people in an English village use social media is to appreciate just how 'English' their usage has become. He introduces the 'Goldilocks Strategy': how villagers use social media to calibrate precise levels of interaction ensuring that each relationship is neither too cold nor too hot, but 'just right'.
He explores the consequences of social media for groups ranging from schoolchildren through to the patients of a hospice, and he compares these connections to more traditional forms of association such as the church and the neighbourhood. Above all, Miller finds an extraordinary clash between new social media that bridges the private and the public domains, and an English sensibility that is all about keeping these two domains separate.
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- anthropology
- Culture
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- Society
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- World Wide Web


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Why Some Will Have to Delay Their 2010 Tax Filing
Since the 2010 Tax Act was passed so late in the year, the IRS is having to delay the start of processing for some returns, since their systems have to be updated. While most returns can begin being processed pretty much immediately in January, there are some that will have to be delayed for processing until sometime in mid- to late-February.
The three specific areas that will cause the delay are:
- Taxpayers claiming itemized deductions on Schedule A. Itemized deductions include mortgage interest, charitable deductions, medical and dental expenses, as well as state and local taxes. In addition, itemized deductions include the state and local general sales tax deduction extended in the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010. The primary benefit is for folks who live in areas without state and local income taxes and is claimed on Schedule A, Line 5.
- Taxpayers claiming the Higher Education Tuition and Fees Deduction. This deduction for parents and students – covering up to $4,000 of tuition and fees paid to a post-secondary institution – is claimed on Form 8917. However, the IRS emphasized that there will be no delays for millions of parents and students who claim other education credits, including the American Opportunity Tax Credit and Lifetime Learning Credit.
- Taxpayers claiming the Educator Expense Deduction. This deduction is for kindergarten through grade 12 educators with out-of-pocket classroom expenses of up to $250. The educator expense deduction is claimed on Form 1040, line 23, or Form 1040A, line 16.
For those that fall into these categories, whether filing electronically or on paper, returns will not be processed until mid- to late-February.


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Today's assignment class is to compare and contrast lumberjacks and ultrarunners.
As I was chainsawing my way through the woods in my back yard, I began to think about how similar, and dissimilar, these two groups of people are. You see, my nickname is The Lumberjack. That's not actually what I do for a living. If I did, I think I'd last about a month or two before I cut a limb off my own body instead of the tree. I know enough to get myself in trouble. While I'm much better with an axe, I still have a lack of appreciation for just how sharp that axe can be. At least I will until I take a toe off.
I wish I smelled like a man when I ran. Instead I smell like a bear that forgot to wipe.
So as I thought about these two groups of people, I began to realize how much alike they are. They both go out into the woods for hours on end. They both sweat as they toil. They may even drink and eat whatever they feel like to fuel their massive energy needs. Both groups are lean and stringy with muscles and can work for hours upon hours before taking a break. They like to work hard but also like to party hard. They live life to the fullest and don't have time for crap. Both use trees as their bathroom when nature calls.
I really dig these hats. Might need one for my birthday.
Yet these two groups are also entirely different. While ultrarunners tend to be vegetarian or even vegan, lumberjacks tend to eat meat like it's going out of style. While lumberjacks cut down trees and are poorly stereotyped for not caring about the environment, ultrarunners lean the other way and try to preserve the environment they run through and have a bad stereotype of being hippies. Ultrarunners dress in technical fabrics that fit to their form while lumberjacks wear denim and canvas and flannel. Lumberjacks wear big boots with steel toes and ultrarunners were trail shoes with ultra-thin soles. Ultrarunners worry about bears, running out of water, and getting lost. Lumberjacks worry about tree hugging hippies, running out of gas, and spiked trees.
So as you can see, both lumberjacks and ultrarunners share a lot of similarities. And while they may work hard at what they love and bring home small paychecks for their efforts, they are two distinct groups that may not get along well in the local bar.


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Charleston, IL Medical Malpractice Lawyers
Exposing Negligence by Healthcare Professionals in Central & Southern Illinois
If a medical professional causes harm to you or a loved one because of a mistake or act of carelessness, you may be entitled to compensation. Medical malpractice is defined as negligence by any healthcare professional, such as a physician, surgeon, nurse, nurse's aide, physician's assistant, or technician. It occurs when a healthcare professional or facility departs from accepted medical practices and causes injury to a patient. Some instances of medical malpractice even lead to wrongful death.
Serving clients from our offices Charleston, IL and St. Louis, MO, our team at The Tapella & Eberspacher Law Firm is here to help if you or someone you know has suffered serious injuries due to healthcare negligence. Our medical malpractice lawyers have the legal experience and know-how to expose substandard medical care and prove its link to a patient's injuries.
For a free, confidential review of your medical malpractice case, call (217) 394-5885. We handle such cases on contingency, which means you pay no legal fees unless we win.
Types of Medical Malpractice
Malpractice can occur in a variety of ways. Individuals can commit medical malpractice by failing to provide standard care in the diagnosis or treatment of a patient. Hospitals can also commit malpractice due to inadequate supervision, the failure to follow established policies and procedures, or inadequate staffing.
Our Charleston, IL medical malpractice attorneys can take on cases involving:
- Failure to diagnose a disease
- Improperly treating a patient's condition
- Administering or prescribing the wrong medication
- Surgery errors and malpractice
- Emergency room mistakes
- Failing to follow-up with a patient after a diagnosis or treatment
- Negligent post-operative care
- Hospital infections
- Birth injuries
- Misdiagnosis of an illness or injury
Financial Compensation for Patients & Family Members
When medical malpractice occurs, the patient is entitled to seek "damages" for past medical expenses, as well as any medical expenses needed to care for the patient in the future. Patients may also recover for past lost wages and any future loss of earnings. Damages for pain, suffering, disfigurement, and any sort of physical or psychological limitations may be recovered as well.
If a patient loses his or her life due to medical malpractice, the surviving spouse or another family member may pursue a wrongful death action against the at-fault professional or facility. Compensation may be pursued for loss of companionship or consortium, loss of contributions by the family member, medical expenses, lost earnings, burial expenses, and more.
Over 100 Years of Collective Experience
The attorneys at The Tapella & Eberspacher Law Firm in Charleston, IL and St. Louis have substantial experience handling medical malpractice cases. Our on-staff nurse and network of top medical professionals bring invaluable expertise to these highly technical cases, and we hire the best independent surgeons, infectious diseases specialists, radiologists, pathologists, and others to develop powerful cases on behalf of our clients.
If you believe medical professionals caused a permanent injury or death to you or a loved one, call (217) 394-5885 or fill out our online contact form. We are here to help.
A History of successmillions recovered for our clients
Car Accident $16,550,000 Settlement
Wrongful Death $5,900,000 Verdict
Hospital Negligence $5,400,000 Settlement
Medical Malpractice $4,000,000 Settlement
Tractor Death and Injury $2,400,000 Settlement
Medical Malpractice $2,100,000 Settlement
Truck Accident Resulting in Eye Injuries $2,000,000 Settlement
Product Liability $1,750,000 Settlement
Negligent Care $1,750,000 Verdict
Hospital Negligence $1,245,000 Settlement
The Right Attorney can Make a difference
Unwavering Dedication
We will fight for a just outcome & won't give up in the face of difficult or unexpected challenges.
A Record of Proven Results
Over our hundred years of combined legal experience, we have recovered millions of dollars for injured clients.
Respected in Our Community
When attorneys need an attorney, they call us. Over 200 attorneys routinely refer clients to our capable & qualified team.
Compassionate Advocacy
We genuinely care about the outcome of your case & commit to standing by your side every step of the way.
Committed to Our Clients
We pride ourselves in going the extra mile to make all of our clients feel comfortable, well-informed, and secure.
Clear Communication
Our attorneys are committed to actively listening to our clients and to setting realistic, justifiable expectations.


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Soin lèvres Olive Mangue sauvage - Cattier - 4 g
Barcode: 3283950912396 (EAN / EAN-13)
Product characteristics
Common name: Baume à lèvres
Quantity: 4 g
Brands: Cattier
Categories: Lip-cosmetics, Face, Lip-balms
Labels, certifications, awards: Organic, fr:cosmetique-bio-charte-cosmebio, fr:ecocert
Manufacturing or processing places: France
Period of time after opening: 12 months
Stores: Pharmacie
Countries where sold: France
→ Ingredients are listed in order of importance (quantity).
Details of the analysis of the ingredients » We need your help!
- Without Parabens
- Without Formaldehyde-releasers
- Without Allergenic-fragrances
- Without Silicones
- Without Phenoxyethanol
- Without Triclosan
- Without Cetrimonium-bromide
- Without Methylisothiazolinone
- Without Aluminum-salts
Note: ingredients can be listed with many different names, please let us know if you think the analysis above is incorrect.
NOVA group
Product added on by miel2thym.
Last edit of product page on by sebleouf.


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Han's Bike
3115 6th St
Austin , Texas ,  78745.
Hans Hanson
Expand Bio
Brenda Lynn
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Harold Lumis
Lead Designer/30%
Expand Bio
Ruby Choi
Expand Experience
Pritka Prajeem
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Marcus Ogilvy
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Our Story
Han's Bike specializes in eco-friendly bike production. We believe that we can work with nature to produce a product that doesn't hurt the environment. (Sample Deal)... Expand Story
Product Description
Han's Bikes are made of 100% recycled materials and use environmental friendly production methods. We cater to people who care about the environment and who also want to live a healthy life.(Sample Deal)... Expand Description
Business Category
Shopping & Retail
Customers and Market
We are targeted towards health and environmentally conscious consumers.
"Their bikes are great!" The staff is extremely friendly as well! -Charles Brice
"They set a great example of what a company can do if it cares enough! " Laura Lynn
Business Certifications- B-Corp
Business Associations-Austin Green Fit
Incubators-Capital Factory
We have been featured on Forbes, and had a successful Seed A round.
Previous Investments
50000 in VC funding to jump start production.


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Income Producing, Recreational Property In East Tennessee
- Photos
- Aerial
- Satellite
Big acreage being offered with potential for many uses. Parcels include timber and reclaimed coal areas with extensive road system and power in multiple parcels. Incredible views with springs and creeks throughout. Perfect habitat for deer, elk, and turkeys, along with income producing opportunities, is hunting, recreation, and timber sales. Great opportunity for personal, business, or conservation uses.
Property Details
- 10 miles to Jellico, 23 miles to Williamsburg KY, 42 miles to Clinton, 50 miles to Knoxville
- Entrance gates at multiple locations
- Existing gas well leases
- Multiple home sites, timber parcels, hunting parcels, and recreation opportunities
- Power and telephone in some locations
- Existing road system throughout
- Multiple ponds, creeks, and springs throughout the property
Rural Route
Duff, Tennessee 37729
Calculate Loan
Estimate Your Monthly Payments
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Senior Center Grants
The Holliston Senior Center is proud to announce that it has received a number of major grants in the last three months. As Holliston's elder population continues to grow, these donations and grants have become lifelines for the Center's vital work.
In April, three community groups, Holliston's Newcomers, Lions and Celebrate Holliston gave the Center a total of over $3,000 to purchase new tables and chairs for the Center. Currently, the Center's chairs are in disrepair and their tables are worn. Director Lina Arena-DeRosa acknowledged "The chairs are over 25 years old and very wobbly, almost unsafe, and many of the tables have broken legs that are in constant need of repair. We have purchased thirty new tables and over a hundred new chairs thanks to these wonderful local organizations that care about the needs of our elder community".
In mid-May, St. Mary's Knights of Columbus presented the Center with a $5,000 check to help with the enormous growth of its twice weekly nutrition program. This program serves 30-40 seniors a hot and nutritious lunch (catered by Holliston's Fairview Restaurant) on Mondays and Wednesdays. Although a $3 donation is requested, the cost is $7 per meal. Director Lina Arena-DeRosa stated "Many of our seniors choose between affording a hot meal or their medications. Moreover, these meals offer an opportunity for seniors to get together and socialize, and for those living alone, a chance to see old friends and neighbors."
In late May, the Center received word that Middlesex Savings Bank Foundation awarded the Center a $12,000 grant that will help the Center keep track of its growth and its needs through a digital program called My Senior Center. Currently, all Center statistics are recorded manually, but with the Center's growth in usage, it has become enormously labor intensive. Director Lina Arena-DeRosa believes this new program will allow every senior to have an individual card that they can swipe at either entrance and then record the program they attend. This innovative digital program which will help the Center keep accurate statistical information that is required by the State.
Finally, last week, MetroWest Health Foundation granted the Center almost $10,000 to host a Falls Prevention Program in Holliston and surrounding communities called "A Matter of Balance". Each year thousands of elders fall and these falls are not only expensive they can be life changing. A Matter of Balance is a Stanford University Evidence Based Program that teaches seniors that falling can be prevented as well as hope to cope in case of a serious injury. The Center's Director noted "seniors want to age at home and A Matter of Balance educates them on simple ways to prevent falls as wells helps senior overcome the fear of falling".
Senior Center Director, Lina Arena-DeRosa said "We are pleased and excited that we have been underwritten by so many non profit groups and Foundations in the past few months. Our growth has been tremendous over the last five years but without the continued support of these groups, we could not meet the needs of our expanding elder population. I am grateful and humbled that so many are willing to help us help them."
For further information, contact Lina Arena-DeRosa @ firstname.lastname@example.com or at 508-429-0622.


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Enter your Email Address and click 'Continue' Example: email@example.com Submit Cancel Forgot Password Close /GarnetHill/US/Global/Popups/forgot_password Enter your email address
10 0
false pdp {"scheme":"product1_cr"}
false pdp {"scheme":"product2_cr"}
Hooded Down Coat is rated out of 5 by 20.
Rated 5 out of 5 by Mramisch from Pretty coat I bought this on sale of the day and although I haven't had a chance to wear it yet, I love the feel of this coat and the color
Date published: 2020-05-10
Rated 5 out of 5 by Eve88 from Beautiful coat! Just bought for next winter. Beautiful soft blue. When reading previous reviews, it appeared to run large so I ordered one size smaller than normal and the fit is perfect. It's warm but not heavy in weight. The hood will be great for my state's ample snowfall. Look forward to wearing next winter.
Date published: 2020-05-02
Rated 5 out of 5 by ChicagoGetsCold from We love it Great sale priced coat- warm, light, down filled, the hood is just right and looks to be the usual sturdy GH construction. TTS. Ordered the black- would have loved the blue but out of stock. Did not have a problem with the sleeve length for my average 5'6 build.
Date published: 2020-05-01
Rated 5 out of 5 by JudyG from Perfectly balanced I really like this coat. I bought the blue, which is soft and cozy and the style is really nice! I'm in my 50s, size 12 was slightly more snug at the hip than I'd love, but the straight style really appealed to me 18yo daughter, so I'm coming back to order one for her! Nice coat.
Date published: 2020-04-16
Rated 5 out of 5 by GSchneider from Love It! Great quality, looks sharp, including fake fur on hood. And that hood - just the right size - not overwhelming like some can be! And VERY warm. SOOO glad I purchased. I'm 5'8", 145lbs and the size 8 was just right. I could probably have been ok with size 10 if 8 hadn't been available, because of the slim style.
Date published: 2020-02-24
Rated 5 out of 5 by Cape Cod Babe from PERFECT FIT Beautiful blue/gray color. I am a size 12. This coat is true to size. It is also lightweight and perfect for travel. Perfect for me.
Date published: 2020-01-15
Does the light color stain easily?
This coat washes and dries very well. If you do get a stain on it, please follow the care instructions.
Date published: 2020-01-21
Is it washable?
Please click on the Care tab below the details to view the garment care instructions.
Date published: 2020-01-10
What is the length of the coat? I am 5'2 and wondering where it will fall on my legs/knees
The length of the coat varies depending on size ordered. Please click the "Fit & Garment Measurements" tab for this item on the Garnet Hill web site to see all available sizing information.
Date published: 2019-11-29
Can the fur on the hood detachable?
The hood is detachable but the fur is not.
Date published: 2019-12-15
if the hood is detachable, is it zipped on or snapped onto the coat?
The hood is detachable. It is zipped onto the coat.
Date published: 2019-12-15
Can you please put up the measurements for this coat? Thank you!
Click the "Fit & Garment Measurements" tab for this item on our website to see all available sizing information.
Date published: 2019-09-21
The measurements that were put up aren't for sizes 0, 2, 4, etc., which is how the coat is sold. They are for XS, S, M etc. Also, the sleeve length cannot be correct! Please put up the correct measurements for the coat in individual sizes Thanks!
The measurements for the jacket are correct. Click the "Fit & Measurements" tab for this item on our web site to see all available sizing information. Note: we measure the sleeve from the center back of the garment.
Date published: 2019-09-16
Product:46867-Hooded Down Coat


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Most Popular Truck in America
Want to know the most popular pickup truck in America? We have it right here:
Total new registrations of light trucks in the US broke 9 million and around 12 million in 2019. Pickup trucks broke 2 million and is projected around 2.8 million for the year. (Note: the definition of a "light truck" is defined by GVW and includes pickups, SUVs, CUVs and some station wagons).
Most popular truck in America: full-size pickup
|Full Size Pickup
|2019 Sales
|1. Ford F-Series pickup
|580,000 Units
|2. Ram pickup
|416,000 Units
|3. Chevrolet Silverado pickup
|395,000 Units
|4. GMC Sierra pickup
|162,000 Units
|5. Toyota Tundra pickup
|90,000 Units
|6. Nissan Titan/Titan XD pickup
|30,000 Units
|7. Honda Ridgeline pickup
|27,000 Units
Last year at this time there were 1.9 light trucks sold for every automobile. In 2019 that jumped to 2.5 light trucks sold for every automobile.
You can see in the chart the Ford F-series pickups continue their traditional dominance as the most popular pickup truck in the US.
The Ram is not the most popular truck in America but it's making a run for it. The Ram pickup has "picked up" second place, traditionally held by the Chevy Silverado, now at number 3.
The list rounds out with Chevy Silverado's sister pickup, the GMC Sierra, at number four, followed by the Toyota Tundra (#5), Nissan Titan and Titan XD (#6), and Honda Ridgeline (#7).
Believe it or not, the Ford F-series trucks have been the most popular truck in America for over 42 years (as of December 2019). Its reign as the most popular truck began in 1977, according to Ford. The first F-series, the Ford F1, was introduced way back in January, 1948, nearly 72 years ago.
America's favorite truck is going electric, too. Ford has announced a new all-electric version of the F-150 is coming in the future, and a hybrid version will be available as early as 2020.
The most popular fuel for full-size pickup trucks is gasoline or flex fuel. Diesel fuel is used in the heavy-duty versions of these trucks and ranges from 12% of all trucks sold (Chevy Silverado) to high-teens (GMC Sierra and Ford F-Series) to 20% (Ram and Nissan).
Most popular pickup in America, mid-size
In the mid-size pickup category, you can see how Toyota dominates. It easily outsells the second most popular mid-size truck, the Chevy Colorado.
Another import, the Nissan Frontier, comes in at #3 beating the Ford Ranger.
The new Jeep Gladiator comes in at #6 but it has only been shipping for a few months.
|Mid Size Pickup
|2019 Sales
|1. Toyota Tacoma pickup
|176,000 Units
|2. Chevrolet Colorado pickup
|98,000 Units
|3. Nissan Frontier pickup
|53,000 Units
|4. Ford Ranger pickup
|46,000 Units
|5. GMC Canyon pickup
|28,000 Units
|6. Jeep Gladiator pickup
|18,000 Units
Keep your eye on the Jeep Gladiator mid-size pickup (also known as the Jeep JT). It resembles a Jeep Wrangler JLU Unlimited with a pickup bed attached. It started shipping in May 2019 as a 2020 model and is already very popular.
There were a lot of Gladiators at the 2019 SEMA Show, such as this one sporting the overland style, complete with mounted tent.
With 18,000 sold in less than half a year, 2020 could see the Gladiator threaten the Ford Ranger's position, especially with incentives offered by FCA. The Gladiator will also be very versatile if you want to go off-road or just look the part.
Will the Tesla Cybertruck ever be the most popular truck in America?
But judging by the publicity around its November 2019 unveiling, it may be the most discussed truck in America.
With a unique profile and all-electric drivetrain it certainly stands out. With the optional Tri Motor AWD version it's claimed to accelerate from zero t0 60 mph in 2.9 seconds. And have 7,500 lbs. towing capacity.
Tesla claims the Tesla Cybertruck will be in production in late 2021. The Tri Motor AWD trim version is expected to begin production in late 2022.
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text:
Getting started with unit testing for Node.js
I'm diving into unit testing with Node.js, and my first stop is nodeunit. Luckily, Caolan McMahon wrote an excellent introduction to nodeunit on his blog. Thanks, Caolan.
I installed nodeunit via npm no problem: npm install nodeunit
All the examples in the Installing nodeunit section worked fine, but I needed to add
var events = require('events');
to the first code sample in the Testing asynchronous code section to get those tests to pass. So, the top of my test-doubled.js file looks like:
var doubled = require('../lib/doubled'); var events = require('events'); ...
Farther down in the blog post, in the Shared state and sequential testing section, there's a code sample with the events include in it, so I think I'm on the right track.
In the Test cases, setUp and tearDown section, I had trouble getting the tests to run. After referencing the project's README file, I tried adding a callback arg to setUp() and tearDown(), and calling the callback, which worked. So, my code looks like:
... var testCase = require('nodeunit').testCase; exports.read = testCase({ setUp: function (callback) { this._openStdin = process.openStdin; this._log = console.log; this._calculate = doubled.calculate; this._exit = process.exit; var ev = this.ev = new events.EventEmitter(); process.openStdin = function () { return ev; }; callback(); }, tearDown: function (callback) { // reset all the overidden functions: process.openStdin = this._openStdin; process.exit = this._exit; doubled.calculate = this._calculate; console.log = this._log; callback(); }, ...
With the minor tweaks above, I was able to get all tests to pass:
3 Responses
[…] recently started exploring testing options for Node.js. Yesterday, I wrote about my experiences with nodeunit. Today, I found Christian Johansen's blog post Unit testing node.js apps. Thanks for the […]
I'm stuck for a while following Caolan's blog as well.
Same as you, I got to know that I have to explicitly invoke callback in setUp and tearDown. I don't know why they set API like this.
IMHO, there is no arguments to callback. Why not just have the system trigger it? For asynchronous? I don't understand.
Thank you very much! I had exactly the same problem and didn't wanted to quit from that great blog with errors 😀


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How to Finish "Grow Island"by Joshua BenjaminUpdated September 22, 2017
"Grow Island" is one of the larger games on the flash-game site "Eyemaze." Like the other games on the site, gameplay consists of clicking on specific items in a pre-determined order to make things happen in the game. In this case, the items you click on will convert a small island from a completely undeveloped land mass into a bustling metropolis--or an alien planet, depending on how you go about it.
Click the "Mechanical Engineering" (the bolt) icon, followed by the "Civil Engineering" (Pickaxe) icon.
Watch your little yellow man dig a circular pathway, then click the "Architecture" (Logs) icon.
Wait for the little yellow man to pave the road with the machine that appeared, then click the Steering Wheel icon.
Watch the little man use his leveled-up machine to cut away a section of the island for a port (with a sword, no less), then click the "Environmental Engineering" (Smokestack) icon.
Watch as things begin to really get moving on the island -- the proposal of the man, the advent of the car, and other changes -- then click the "Electrical Engineering" (Battery) option.
Click the "Computer Science" (microchip) icon once the animations have finished.
Click the "Applied Chemistry" (burner) icon to complete the island and finish the game.
You can also achieve the secret "Alien" ending by choosing the icons in this order: Steering Wheel, Pick Axe, Logs, Microchip, Battery, Bolt, Burner, Smokestack.


text:
Meet The Team
Dr. Jerry Reeves, MD
Chair, Desert Meadows AHEC
Las Vegas, NV
Gerald Ackerman
Director, AHEC Program Office
Elko, NV
Eileen Colen
Director, Desert Meadows AHEC
Las Vegas, NV
Keith Clark
Director, Frontier AHEC
Elko, NV
Get Involved
Your support is important to our work at High Sierra AHEC. There are many ways you can contribute towards our causes, and every little bit that you commit goes a long way in helping us fulfill our mission. Learn more about how you can get involved and take advantage of the opportunity to do some good.


text: Macular degeneration is the leading cause of vision loss and blindness in those over 55. According to the American Macular Degeneration Foundation (AMDF), it affects more than 10 million Americans. After the age of 75, one in three Americans is at risk of developing this incurable disease. While the cause … (read full article)


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Really, Really, Good Meatloaf
Has anyone ever said to you "I make the greatest meatloaf in the world" and then invited you dinner? Well, someone said this to me and since I'm a nice person I will refrain from naming names but, like an elephant I NEVER forget…the year was 1985. I'm fairly sure they never figured out WHY I didn't go back for dinner ever again but, rest assured the MEATLOAF was the reason. Mashing a large amount of ground beef into a pan with chucks of bread large enough to see and onion soup mix does NOT a meatloaf make nor does smothering it in globs of ketchup or mushroom sauce made from a can of condensed soup. I know it sounds harsh but, when you tell me it's the BEST meatloaf ever I'm expecting at least edible. Yes…I'm a food snob. Take it or leave it and frankly if I'm the one eating the food it better darn well be up to snuff.
We all remember meatloaf growing up, especially if you were born in the 50's or 60's. It was practically a staple along with Spam, Wagon Wheels (cringe) and Mom's apple pie (right out of the box).
I promise this recipe will not be concocted of Spam, ketchup and sawdust topped off with a nuclear Wagon Wheel gravy. This is just like the name says: REALLY REALLY GOOD MEATLOAF.
Minced meat loaves were cooked as early as the 5th century, and mentioned in the famous Roman cookery collection "Apicius". American meatloaf has its origins in scrapple, a mixture of ground pork and cornmeal served by German-Americans in Pennsylvania since Colonial times. However, meatloaf in the contemporary sense did not appear in cookbooks until the late 1800's.
Prep Time: 10 minutes
Cook Time: 1 hour, 30 minutes
Total Time: 1 hour, 40 minutes
1 lb ground beef
1/2 lb ground pork
1/2 lb ground veal
1/2 cup onion, finely chopped
1/4 cup red bell pepper, finely chopped
1/2 cup fine bread crumbs
1/2 cup chopped parsley
1 tbsp dried basil
1 large egg
1 tsp salt
1/2 tsp black pepper
6 slices bacon
Turn oven to 350f. Combine all ingredients, except bacon, in a large mixing bowl. Use your hands to mix the ingredients well. Only mix until all ingredients are evenly distributed. Do not squeeze or press down the meat or your meatloaf will become dense.
Line a loaf pan with foil and spoon meatloaf mixture onto the pan. Shape into a loaf and cover with bacon slices.
Bake for approximately 1 to 1 1/2 hours. Meatloaf should have an internal temperature of 170 degrees.I choose to serve the meatloaf alone with just the bacon on top but…YOU may want to try some fried mushrooms or even ketchup to accompany yours. To each their own.
FOOTNOTE: Meatloaf is not exactly gourmet food but can be a tasty meal accompanied with garlic mashed potatoes and some veggies. It also makes GREAT sandwiches.


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the people who work here are so sweet and the food is SO good. i've been coming since i was little and i can't find anything better in haifa. the falafel is crispy on the outside and soft on the inside, always fresh and also gluten free :)
Harp of David
- Price $$$$
The idyllically situated Harp of David restaurant, evokes the days of King David himself, offering magnificent views, a delicious kosher dairy menu and a magical atmosphere. Situated close to King David's tomb and Dormition Abbey just outside the Old City, the restaurant is perfectly located, whether it's for grabbing a bite to eat along the way or celebrating a special event. The views of the Zion Gate, Old City walls, Mount of Olives and Judean Desert provide the perfect backdrop for any occasion.
The restaurant is renowned for its kosher, biblically-inspired menu and Mediterranean buffet, which includes an exotic selection of fish, cheese, hummus, tahini and stuffed vegetables followed by luscious hand-made sweets and desserts. A favorite choice for receptions, family gatherings, bar and bat mitzvah parties, corporate events and intimate musical evenings, the restaurant offers special menus for groups every day of the week, including Saturday. Table arrangements are flexible and the restaurant can seat 70 in its banquet hall and 80 in the quaint courtyard.
The restaurant also offers a number of workshops on culinary topics, art and antiquity restoration.
TripAdvisor Reviews
Данное заведение мы посетили без всяких рекомендаций, просто был сделан произвольный выбор ....и нам понравилось. ..Ну во первых, в этом заведении оказался прекрасный выбор блюд из рыбы и морепродуктов,(мы заказали мидий в чесночном соусе) и не ошиблись, очень конечно вкусно!), во вторых: это гостепримное и внимательное обслуживание, в третьих это классная внутреняя атмосфера!


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An International Journal Dedicated to Fundamental Questions in Physics
The Elite Journal since 1988
For purchase of this item, please read the instructions.
Volume 14: Pages 299-308, 2001
M. John Wymelenberg
2500 California Plaza, Adm. Bldg., Omaha, Nebraska 68178‐0522 U.S.A.
The photon is likened to a simple harmonic wavelength in a string. A comparison of the energy expression for that wavelength to the energy equation of a photon suggests an electromagnetic wave energy equation containing an expression for the fine‐structure constant. The compound amplitude of the electromagnetic wave‐function is a constant and has the dimension of electric charge. A helical wave structure suits the known physical properties of the photon, which in turn relates to an electron model.
Keywords: analogy, energy‐density equation, wave‐breadth and amplitude, wave potential, inchoate electric charge, primitive electrodynamics, electromagnetic wavespeed, fine‐structure constant, angular momentum, helical structure, electron model
Received: January 23, 2001; Published online: December 15, 2008


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I have so much to be thankful for this year! In pondering my blessings, I've listed my top 7. They may seem cliche' or predictable, but that's okay! There are many more I could have added, but these are the things I thank God for every day.
2. MY KIDS. Yes, they are to blame for my gray hair, but I wouldn't trade them for anything in the world. I am so blessed to be the mother of two awesome teenagers who make me laugh, warm my heart, and keep me young (along with the Garnier Nutrisse).
3. MY FAMILY. My husband and kids have already been mentioned, but I'm talking about the rest of my family. My mom...my dad...brothers...in-laws...So if you shook my family tree, a few nuts would fall out, but I happen to be a fan of nuts!
4. MY FRIENDS. Diane...Cari...Ginger...Deb...Susan...I seriously have some of the most fabulous friends in the world. Whether it's encouragement, a shoulder to cry on, a hug, a good laugh, or a movie and/or coffee buddy, each one offers something different, yet exactly what I need.
5. MY CHURCH. Okay, so I know there are a lot of great churches out there, and I may be biased, but my church rocks. Not only literally - as in rockin' praise and worship - but it is filled with the most real, accepting, Christ-like people I've ever met, and Pastor Duane is an awesome teacher and genuinely great guy. Plus, God rocks my socks off by allowing me to do really cool things like co-write our church's Christmas production, How Christmas Saved the Grinch, which will be attended by a projected 20,000 people this year! Is that cool, or what? I am so grateful for the opportunity to use my gifts to minister to people and am so honored to be part of a church that's alive and growing!
6. MY JOB(S). I am so thankful that I am able to stay home and do what I love to do instead of going to a job I dread every day. Not to say it's always a piece of cake, and there are days I feel like tossing my laptop out the window, but God has opened so many doors to the writing world for me (mostly through people I've met along the way) and I never take it (or them) for granted.
I know I'm not the most faithful blogger, nor am I the most amusing, entertaining or interesting. I probably over-promote myself to the point where you want to gag, and sometimes I'm sure I don't respond to you guys like I should. That's why I am thankful for every single one of you who reads my blog - even if only clicking over for a quick skim - and those of you who take extra time to comment. I appreciate you more than you know!
"Be thankful for what you have; you'll end up having more. If you concentrate on what you don't have, you will never, ever have enough." - Oprah Winfrey
What are you most thankful for this year?


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From travel accommodations (Airbnb, VRBO) to transportation (Uber, Car2Go) or work (Upwork, TaskRabbit), the Collaborative Economy has disrupted many industries. Thousands of new opportunities have already emerged with successful revenue models based on memberships (Zipcar, Bag Borrow or Steal), service fees (Airbnb), and micropayments for usage (BIXI, BabyPlays).
The Sharing economy (also known as shareconomy or collaborative consumption) is a hybrid market model (in between owning and gift giving) which refers to peer-to-peer-based sharing of access to goods and services (coordinated through community-based online services).[1][2] basically it enables people to get what they need from each other.
It is reinventing not just what we consume but how we consume.
The research and advisory firm Altimeter Group published a report, "The Collaborative Economy," which outlines the landscape and its growth. The report highlights the necessity for businesses to take advantage of the collaborative economy. One conclusion is that the collaborative economy is becoming a part of the mainstream economy, and that businesses that do not leverage this model—either to make their operations more efficient, or to incorporate into their own revenue model—will struggle to compete.
Collaborative Consumption is consumer and community orientated, but its benefits are shared for businesses. First, it's needed. Small businesses can struggle to build a business and they can't afford unnecessary spending. Second, it is more efficient for them. It boosts their productivity, lowers barriers to entrepreneurship, and helps them maintain better relationships with their clients. Third, it's based on Web technology, which can help to match up consumers and businesses, promote relationships based on trust, and to complete business transactions.
As companies start to redefine themselves as a bridge between individual users and the community, people will trust them more, and as a result they will begin to interact in different ways. This broader and deeper relationship provides an opportunity to offer more services, such as personalization.
Yocale is grounded in the principles of collaborative economies. By creating a large marketplace of service providers, we're not only creating a valuable platform of shared resources and collected reviews and experiences, but also a strong interconnected network of referrals between businesses serving the same customers.
Adapting your business to the sharing economy means finding ways to collaborate with either complementary businesses to provide smarter, more in-depth service or collaborating for your customers to connect them with more of what they need.
Using the resources of combined information, complementary services and a deeper level of service relationship will increase your trust and value level to your customer. When your "know-like-trust" factor goes up, sales go up.
An example of this in the service industry might be:
- Joining or creating a referral network in your community.
- Sharing your office space for community events.
- Offering your customers valuable content in a monthly newsletter, that's not just about your own service, but things that will make their lives better.
- Creating a group (Facebook) for your customers to share their experiences/questions/learnings not only with you but each other. Allow them to "swap" tips/ideas etc.
In the Shareconomy, business isn't about staying secret or proprietary. As the collaborative economy grows, the more you can open your business to creating community connections and sharing knowledge, the more it will help you grow as a trusted resource. [bctt tweet="In the Shareconomy, business isn't about staying secret or proprietary. Create Communities & Share Knowledge to Grow."]


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2D Planet Mars Cutout
Product Code: SPC08
Quantity Held: 1
* more may be available on request3D Backdrops, Backdrops, Screens & Fences, Film, Books & TV, Futuristic, Product Groups, Sci-Fi, Space, Star Wars, Themes
Free standing 2D cutout of planet Mars for hire.
Perfect prop for your sci-fi or science related party.
Please note that this prop is single sided.
|Height (mm)
|Width (mm)
|Depth (mm)
|400mm (base)
|Weight (kg)


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Writers Are Weird
Writers are the weirdest people you'll ever meet. Well, perhaps not the weirdest, but nowhere near what society would call 'normal.' Their minds are seldom in the here and now; they might look calm and collected on the outside, but behind their eyes, their imaginations are always running wild. Writers come in all varieties of personality types, but one thing you'll find unites them all is this: they never stopped playing make-believe. That childlike sense of wonder about the world around us stood the test of time against the odds of our society's tendency to encourage people to 'outgrow' their imagination. It's why I like meeting other writers. Regardless of our differences, be they race, religion, income, or any other arbitrary categorization we use to define human beings, our souls are going to connect on a similar wavelength.
In high school, my Expository Writing teacher said to the class, quoting E. L. Doctorow, "Writing is a socially-acceptable form of schizophrenia." I think every writer at some point in his or her life has questioned their own sanity. I know I have. People make jokes about hearing voices in their head not being normal, and I would think to myself, "I hear voices in my head all the time." Don't be alarmed, however. These voices come in the forms of personalities and characters who might one day find themselves on the pages of a future novel. While not true of all writers, you'll find that most of us tend to talk aloud to ourselves, and not just when we're working.
Writers Are Artists
In twenty-first century America, we find, heartbreakingly so, that fewer and fewer people read. If I had a dollar for every time I heard someone say, "I'm just not much of a reader," I wouldn't need to write to make money anymore. Living in a digital age, with a buffet of streaming media at the tips of our fingers, more people prefer television and film. So why produce art fewer people will appreciate? Well, have you ever heard someone say, "The book was even better than the movie,"? There's a reason for that: visual entertainment, no matter how crammed-packed with special effects, will never—I repeat, never—compete with the human imagination. You see, especially for those of us who write fiction, it is the part of the human mind to which we appeal.
When someone says they are an 'artist,' we typically think painter, sculptor, dancer, or musician. When someone says they are a 'writer,' we have a tendency to put them in a separate compartment. But that's what we are: artists. Our canvas is a blank piece of paper or computer screen, our paintbrush, a pen or keyboard, and our finished product, an experience. It may come in the form of a story, a poem, an essay, or a blog. We use words to paint a picture in the minds of our readers in hopes to take them to another place, perhaps another time, and see through the eyes and ears of someone who doesn't even exist. And why? Because we want other people to read our work and enjoy it? Sure. That's a part of it. But real writers do it because they love it more than anything else in the world. Just ask one.
Writers Understand People
Writers are a scary judge of character and it's rare to find one gullible or easily-duped. We spend so much time trying to understand people in order to make our characters as believable and relatable as possible. We don't force our characters say or do anything, we invent them, and let them loose. We constantly ask ourselves, "What would he say?" or "What would she do?" and develop a honed skill at reading people as a result. After studying human behavior for so long, trying to not only understand it, but essentially replicate it, writers can usually deduce the motivation behind people's words or actions. Long-story-short, I wouldn't recommend trying to bullshit a writer, though you're welcome to try. You'll just give them the opportunity to call out what you're doing and why.
On the flipside of this, oftentimes you'll find writers make great friends. We pay attention to what people respond to, positive and negative, and for those we love: we aim to please. For this reason, you'll notice writers sometimes wear different hats depending on who they are around. It's not faking or insincere, but another representation of who they are—one they think you'll respond to best. What can I say? We're a complicated lot, rich with layers and complexities, and sometimes downright ridiculous. But as Marilyn Monroe once said, "Imperfection is beauty, madness is genius, and it's better to be absolutely ridiculous than absolutely boring."
Writers Work Hard
If you're familiar with 'Family Guy,' you have probably seen the bit where Stewie heckles Brian about writing a novel. If don't know what I'm talking about, I've included the entire quote here for your pleasure.
"How you uh, how you comin' on that novel you're working on? Huh? Gotta a big, uh, big stack of papers there? Gotta, gotta nice litte story you're working on there? Your big novel you've been working on for 3 years? Huh? Gotta, gotta compelling protaganist? Yeah? Gotta obstacle for him to overcome? Huh? Gotta story brewing there? Working on, working on that for quite some time? Huh? (voice getting higher pitched) Yea, talking about that 3 years ago. Been working on that the whole time? Nice little narrative? Beginning, middle, and end? Some friends become enemies, some enemies become friends? At the end your main character is richer from the experience? Yeah? Yeah? (voice returns to normal) No, no, you deserve some time off."
People love to say this to me for some reason. I suppose they think it's funny and I suppose it is; I laughed when I saw it—the first time. There's a terrible misconception concerning writers: that they sit around doing nothing, but nothing could be further from the truth. Writers work hard. Really hard. Don't believe me? Sit down at your computer, shell out 80,000 words that make sense, comb through it to make sure it's as free from grammatical and spelling errors as possible, and then try to talk someone else into paying you for the opportunity to read it. After you're done, let me know how long it took you to do it.
The truth is we pour our heart and soul into our work. We are just as passionate as any other artist about our work. Blood, sweat, tears, countless hours, and cups of coffee go into transforming ideas for others to understand and enjoy. Another misconception is that all writers are 'starving artists.' Some of us are pretty darn good at what we do and make a decent living doing so. Next time you hear someone say they are a writer, remember that just like any person with any profession, they take great pains to produce quality work, and are proud of the accomplishments like anyone would be.
To My Fellow Ink-Slingers
If you've stayed with me until this point, hopefully you're reading this saying, "Yes! Yes!" I know what it's like being a writer. Every challenge, every insecurity, every snarky comment from every hater who thinks our craft obsolete or irrelevant, I've faced it all, and I'm sure you have too. Being a writer isn't easy. The work is hard, the pay sucks, and the label comes with all kinds of disheartening stigma. But chances are though, you're like me and you don't do it for the money or the approval of others; you do it because you love it and you can't imagine doing anything else. To that I say, "More power to you!"
Our craft is not obsolete and it is not irrelevant. While fewer people read nowadays, the global population is larger today than ever before, and a great many of them still read. Your efforts are not in vain and under no circumstances should you let discouragement of any kind dissuade you from pursuing your dreams. You will find success if you make the decision to never quit and possess the three necessary ingredients: talent, skill, and determination.
For those of you who took the time to read, thank you. Readers are a writer's best friend. I appreciate you more than I could adequately articulate with words alone. I hope this has given you some insight into what writers, as people, are really like. For my fellow writers, remember this if nothing else: you can't lose if you refuse to quit. Oh! And one more thing: don't ever stop listening to the voices in your head.


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Gujarat Narmada Valley Fertilisers & Chemicals (GNFC)
GNFC provides "commissioning services for TDI, Methanol and other plants" located in Iran. (GNFC WEbsite, "36th Annucal Report: 2011-2012")
"Iran is likely to supply gas at USD 3 per mmbtu for India's proposed urea and ammonia plant to be set up in the Persian Gulf nation. Rashtriya Chemicals and Fertilisers (RCF) and Gujarat Narmada Valley Fertilisers & Chemicals (GNFC) have been jointly working on this project. The project will also include an Iranian firm. The project is proposed to set up at a petrochemicals hub at Chahbahar, Iran, using natural gas as feedstock with an estimated investment of about Rs 7,000 crore. 'Talks are at an advanced stage and there have been indications from the Iranian authorities for supplying gas at USD 3 per mmbtu,' sources said. As per the proposal, the Iraninan government will assure supply of gas at fixed rate and India will lift the total quantity of soil nutrients produced at the proposed plant. Work on the project has expedite following the lifting of sanctions on Iran by the US in November last year…The Fertiliser Ministry had also received a letter from the Iranian embassy inviting a delegation from India to discuss gas prices and supply for the proposed urea plant there, sources added. However, the Indian government is already in talks with Iran to provide financial assistance and develop Chabahar port." (Business Standard, "Iran may supply gas at $3/mmbtu to India's proposed urea plant," 4/17/14)
"India is likely to expedite the process of setting up of urea and chemical plants in Iran and a delegation may visit the country next month discussions on gas prices as the Persian Gulf nation gets relief from global sanctions. Rashtriya Chemicals and Fertilisers (RCF), Gujarat Narmada Valley Ferilisers & Chemicals (GNFC) and Gujarat State Ferilisers & Chemicals Ltd (GSFCL) are planning to jointly set up urea and chemical plants in Iran with an estimated investment of Rs 7,500-8,000 crore…'A delegation of officials from the Fertiliser Ministry, RCF, GNFCL and GSFCL are likely to visit Iran next month to discuss about assured gas supply and prices for the proposed urea plant to be set up there,' a senior official of GNFC told PTI. The plant is proposed to set up at a petrochemicals hub at Chahbahar, Iran, using natural gas as feedstock. 'Gas prices are lower in Iran as compared to domestic prices. This is the reason we are looking forward to set up a plant in Iran,' the GNFC official said. However, Indian government is already in talks with Iranian government to provide financial assistance and develop Chabahar port." (Economic Times, "Indian delegation may visit Iran for discussions on urea plant," 11/25/13)


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ESTEVAN, Sask. — Environment Minister Peter Kent affirmed Canada's plan to gradually phase out traditional coal-fired power plants, announcing on Friday proposed regulations that would require any new units that begin producing power after July 1, 2015 to match the lower greenhouse gas emissions of natural gas generation.
Decisions will have to be made about existing coal-fired units as they reach the end of their economic lifespan at about 45-years-old, as they will have to be made to meet new performance standards if they are to continue operating.
"We want to encourage the shift to cleaner alternatives and to ensure money is spent on clean technology and innovation like carbon capture and storage," Kent said, speaking Friday at the site of SaskPower's Boundary Dam plant.
The proposed rules will be published on Aug. 27, followed by a 60-day public comment period.
"We have recognized the very different situations — even in some provinces plant to plant, but certainly region by region in the principal coal-fired provinces of Alberta, Saskatchewan and Nova Scotia — and we have recognized transition phases that will allow those who invest sooner rather than later, how they can get through without stranding capital, without risking new investment to meet these (regulations) in 2020 and through that decade. Some will only fully meet their requirements by 2030," Kent said.
If a new coal-burning plant were to be constructed and begin operating before the 2015 date — such as a proposed new coal-fired Maxim Power Corp. plant in Alberta — the new, more stringent regulations would not apply until the end of the life of that plant.
Kent said about two-thirds of the country's coal-fired generating stations are approaching the end of their natural operating lives. Nineteen of them will be there by 2015, he added. He said the new regulations will not mean huge hikes to consumer power bills, contending that by 2020 the average Canadian residential electricity bill will increase by only an estimated $5 a year.
The minister toured the Boundary Dam plant, where Unit 3 is undergoing a $1.24-billion conversion for carbon capture and storage by 2014. It's expected to be the first commercial scale power plant with a fully integrated carbon capture system, which should help it meet tougher emission rules.
Units 1 and 2 at Boundary Dam, the oldest of the province's three coal-fired plants, will be decommissioned within a few years, and SaskPower will have to consider how to proceed with rebuilds of two of the station's other aging units later this decade.
Saskatchewan Environment Minister Dustin Duncan said the federal announcement provides regulatory certainty that a company such as SaskPower needs to make decisions.
"SaskPower believes that they can make a very compelling argument for not only the emission reductions that they will get out of using this (carbon capture and storage) technology but also the economic benefits of being able to sell the CO2 into the nearby oilfields," he said. "We'll look at the success that we can achieve by that and then go forward with making future decisions as we get to the timing based on the federal regulations."
But some environmental groups said the federal proposal is not aggressive enough. Climate Action Network Canada noted the current federal proposal would still see Canada burning coal for several decades and said the country should be phasing out the existing coal power plants much more rapidly.
Tim Weis, director of renewable energy and efficiency for the Pembina Institute, a sustainable energy think-tank, said the new regulations apply to too few coal-fired plants.
"The government needs to address pollution from all of Canada's coal-fired power plants, not just future or very old units," he said in a news release. "Under these regulations about two-thirds of currently operating plants do not have to meet the standard until after 2020, and nine will operate past 2030 without constraint."
The Canadian Electricity Association called the regulation a step forward in encouraging non- and lower-emitting technologies, but described it as incomplete. President and CEO Pierre Guimond said some companion policies are required, including one that addresses natural gas generation.
"We'd like to have some sort of indication from government that we can go to natural gas without waking up 10 years from now with a bunch of investments that are stranded," Guimond said. He added that older coal plants will be closed over time, but there needs to be certainty that they can operate in the meantime without having to "spend unduly" on changes to meet standards on other air pollutants.
Environment Canada said the proposed new regulations, when combined with other federal and provincial measures, are expected to result in a drop of 31 megatonnes of greenhouse gas emissions from electricity generation between 2005 and 2020. The government is trying to reach a target of reducing the country's greenhouse gas emissions 17 per cent from 2005 levels by 2020 through what it calls a "sector by sector" approach.