title: overflow: auto with persistent header
body: <p>I'm trying to create a scrollable list with a persistent nav header.  However when you scroll to the bottom of the list the last few items are not visible, as the list is pushed down by the header.  I created a jsfiddle to show the problem:</p>
  
  <p><a href="http://jsfiddle.net/U34vq/12/" rel="nofollow">http://jsfiddle.net/U34vq/12/</a></p>
  
  <p>The problem is the height: 100%.  How can I fix this?  I <em>could</em> use CSS3 calc() to make it, height: calc(100% - 3em);  However I'm targeting browsers that don't support calc().</p>
  
  <p>I guess my question is, can I have 2 nested elements, one with height measured in ems and the other in % and have that work, because it seems like I cannot.</p>