Equitable principles can also limit the granting of equitable remedies. The Andersen framework also makes a distinction between equitable and inequitable access. The defendant may also assert counterclaims for damages or equitable relief against the plaintiff. Punitive damages can also be awarded for equitable wrongs. Georgists argue that taxing economic rent is efficient, fair and equitable. The federal approach has been described as merging principles of equitable tolling and equitable estoppel. The law is less settled regarding equitable wrongs. Equity is concerned mainly with trusts and equitable remedies. The new public health advocates for population-based policies that improve health in an equitable manner. Gender-sensitive practices necessitate equitable and appropriate attention to all learners. Membership was selected with regard to equitable geographical distribution. Fairness is the quality of being just, equitable, and impartial. Legal and equitable title also arises in trust. As an equitable doctrine, the court has discretion. This role gave rise to the basic distinction between legal and equitable interests.