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Letter Ruling Alert: A Blueprint for Creating a Taxable Subsidiary
August 1, 2002, The Exempt Organization Tax Review
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Exempt organizations have been creating
taxable subsidiaries for many years to meet
a variety of needs, including spinning off
unrelated businesses, protecting the parent
organization from potential liabilities, and
providing a means of sharing the profits
from money making ventures with employees.
In a recent private letter ruling (LTR
200225046 (March 28, 2002), reprinted on
p. 322), the IRS has provided a comprehensive blueprint for
creating and structuring an exempt organization's relationship
with such a subsidiary. The ruling not only addresses the
more routine topics of how to protect the tax-exempt status
of the parent organization and whether certain payments from
the subsidiary to the parent will be treated as unrelated business
taxable income, but also provides guidance regarding
how to structure resource sharing arrangements and how to
grant stock and stock options to employees of both the subsidiary
and the parent. Although the Service imposed a few
requirements that go beyond those existing in current law
and did not resolve all of the unrelated business taxable
income questions raised by the facts before it, the ruling
provides both a helpful summary of the legal principles that
apply to taxable subsidiaries and a useful example of the
application of those principles.
M is a section 501(c)(3) educational organization engaged
in various endeavors relating to a certain subject. It has
dues-paying members from around the world, and serves all
levels of practitioners, educators, and students. Its activities
include producing a magazine and other publications, hosting
workshops, seminars, and conferences, and facilitating the
networking of its members.
M created a taxable entity, N, to operate an Internet portal
("N.com") that will serve as a comprehensive source of information,
products, and services targeted at business professionals
working in M's area of concentration. N's specific
activities will include establishing links to merchants through
affiliate agreements, providing online recruiting and career
resources, producing industry directories, and providing advertising.
Although not explicitly stated in the ruling, it appears
that M will be transferring essentially all of its Internet
activities to N. M provided three reasons for making this
transfer: to insulate itself from liability arising
from affiliate agreements related to M's
Web site with third parties; to carry out certain
activities in a manner that would not
affect M's exempt status under section
501(c)(3); and to minimize M's potential liability
for unrelated business income tax under
The actual creation of N was straightforward.
M caused N to be incorporated as a
for-profit corporation, and then contributed
cash and certain intangible assets to N in
exchange for shares of N's common stock,
making N a wholly owned subsidiary of M. N will establish
a separate telephone number and separate telephone listing(s),
bank accounts, and stationery, although N will have the same
mailing address as M, at least initially. N will also obtain a
benefits package for its employees and insurance to cover its
operations, and will not comingle or combine its funds and
assets with those ofM. N's board of directors will have regular
meetings throughout the year, will maintain complete and
accurate minutes of meetings, and will be the sole governing
and policy-making body for N.
Although not stated explicitly, M will presumably appoint
all of the members of N's board of directors, at least as long
as M is N's sole shareholder. A majority of the five directors
will not, however, be officers or directors of M. The board
will initially consist of M's CEO, a member of M's board or
M's executive committee, the president/CEO of N, and two
individuals who are not currently directors, officers, or employees
of M. M also has veto power over certain actions by
N as long as M continues to hold more than 50 percent of
N's outstanding voting stock. These actions include: amending
N's governing documents; major corporate actions such
as a merger, consolidation, reorganization, dissolution, filing
for bankruptcy, creating a subsidiary, changing taxable status,
and issuing shares of capital stock; removing any director
appointed by M; disposing of any material asset other than
in the ordinary course of business for fair market value consideration;
and any action that could be reasonably expected
to have a material adverse effect on M's tax-exempt status.
N's first two employees will be its president/CEO and its
"director, Web site architecture." Neither of these employees
will be an employee of M, although the director, Web site
architecture had previously worked for M. N's officers and
employees will be in charge of N's day-to-day activities.
M and N plan to enter into the following series of agreements
governing financial transactions between them;Msubmitted
copies of the agreements to the Service as part of the
ruling request.
- Administrative services agreement: N may, at least
during its start-up phase, obtain administrative services
from M in exchange for reimbursing M for the costs
M incurs in providing those services.
- Advertising agreement: M will receive banner advertising
space on N's Internet portal, and N, in exchange,
will receive a proportionate amount of advertising
space in M's publications. M will report the value of
the advertising space it receives as unrelated business
taxable income.
- Affiliate agreement: This agreement will govern the
terms of the sale of M products and services on N's
Internet portal, withMdetermining the pricing for such
items and N receiving a commission on the sale of any
such items through N's portal.
- Directory agreement: N will receive a non-exclusive,
non-transferable license to M's directory of service
providers for a term of 10 years, with a 10-year automatic
renewal unless N provides written notice of nonrenewal.
In exchange, N will market, promote, and
make available on the Internet the directory information,
and will pay M an annual royalty with a fixed
minimum plus 50 percent of the gross revenues from
the sale of directory listings in excess of that minimum.
M will also establish standards and guidelines for the
permitted use and depiction of directory information.
- Lease: N's office, at least initially, will be a separate
area in M's office, with the rent paid to M set at M's
cost for that space.
- Licensing agreement: Under this agreement,
- N will license from M M's trademark, logos, and
domain name, and certain content from M's publications,
for use in and relating to N's Internet portal.
N will also licenseM's membership database, which
contains contact, financial transaction, and demographic
information about M's members and which
M does not license or rent to other parties.
- N will provide on N's Internet portal anM"members
only" section, links to M Chapter Web sites, and
priority positioning for M's products and services.
- N will try to obtain discounts for M's members on
products and services provided through N's affiliate
programs with third parties.
- N will pay M a royalty of 10 percent of "gross
revenues," as defined in the agreement, with a minimum
royalty guaranteed for the first two fiscal years.
- N will not provide comparable Web site hosting
services to any other entity selling products or services
targeting those with an interest in M's subject
- M will not license its content to any other Web
site that is directed toward the North American
- M will have the option of extending the terms of
the Agreement to any foreign jurisdiction that N
seeks to enter for purposes of establishing an Internet
portal.
- Upon termination, M will be granted a royalty-free
perpetual (but apparently non-exclusive) license to
the software developed to operateN's Internet portal,
N will assign to M all of N's third-party affiliate
agreements for its Internet portal, and M will have
the option of purchasing N's Internet portal hardware
at fair market value.
The Agreement will have a 10-year term, with an
automatic 10-year renewal absent a written notice from
M of nonrenewal.
N will adopt a stock grant plan as part of the compensation
to be paid to its officers, directors, and employees for their
services, subject to the total compensation paid being reasonable,
as determined by a compensation consultant. N may
also in the future seek other investors to provide additional
capital, including through possibly forming one or more joint
ventures. M will offer N stock and stock options to M's key
employees, subject to the total compensation, including the
fair market value of any N stock or stock option granted,
received by any employee being reasonable.
IRS Conclusions and Rationale
Separate Entities
The Service first addressed the most important aspect of
the creation of N: whether M had succeeded in creating a
separate entity, the activities of which would not be attributable
to M. Relying on the familiar cases of Moline Properties
Inc. v. Commissioner, 319 U.S. 436 (1943) and Britt v. United
States, 431 F.2d 227 (5th Cir. 1970), as well as Krivo Industrial
Supply Co. v. National Distillers and Chemical Corp.,
483 F.2d 1098 (5th Cir. 1973), which involves a lengthy
discussion of when one corporation is an "instrumentality"
of another corporation such that the liability of the first
corporation can be attributed to the second corporation, the
Service concluded that M had succeeded in creating an entity
with a bona fide business purpose and which was not a "mere
instrumentality" of M.
In reaching this conclusion, the Service relied on the fact
that N's Internet portal would benefit not only the members
ofM but also other professionals, that a majority of N's board
would not be board members or officers of M, and that the
day-to-day management ofNwould be in the hands of officers
of N who will be independent of M. The Service also relied
on the fact that N would maintain separate books and records,
financial reports, employee benefits, and insurance, and that
financial transactions between N and M would be carefully
documented, with M being fully reimbursed for any use by
N of M's office space or administrative services.
Given this conclusion, the Service then ruled that neither
the formation nor the initial capitalization of N would adversely
affect M's tax-exempt status as an organization described
under section 501(c)(3) or result in UBTI to M. The
Service also ruled that N's taxable income would not be
treated as UBTI to M, any proceeds from the sale of stock
by N would not result in UBTI to M, and any dividends
received by M from N would be excluded from M's UBTI
by section 512(b)(1).
Payments from Taxable Subsidiary to Exempt Parent
The Service also ruled on the treatment of various payments
received by M from N. Turning first to the Licensing
Agreement, the Service noted that the payments for the intangible
property rights obtained by N from M qualified as
royalties within the meaning of section 512(b)(2), which
provides an exclusion from UBTI for royalties. In reaching
this conclusion, the Service relied on the first situation described
in Rev. Rul. 81-178, 1981-2 C.B. 135, where the
Service found that the licensing of a section 501(c)(5) labor
organization's trademarks, trade names, service marks, and
copyrights, along with its members' names, photographs,
likenesses, and facsimile signatures, qualified as royalties
under section 512(b)(2). The Service also relied on the line
of cases concluding that payments for the rental of mailing
lists constitute royalties within the meaning of section
512(b)(2). See Sierra Club Inc. v. Commissioner, 86 F.3d
1526 (9th Cir. 1996); Common Cause v. Commissioner, 112
T.C. 332 (1999); Planned Parenthood Federation of America
Inc. v. Commissioner, 77 T.C.M. (CCH) 2227.
The Service specifically did not rule, however, on whether
the royalty payments might still constitute UBTI under section
512(b)(13). Section 512(b)(13) provides that if a controlling
organization receives a specified payment from a
controlled entity, the payment shall be included in UBTI
notwithstanding sections 512(b)(1), (2), and (3) to the degree
such payment reduces the net unrelated income of the controlled
entity. Specified payments are interest, annuities, royalties,
and rents. Section 512(b)(13)(C). "Control" generally
means, for a corporation, ownership, by vote or value, of
more than 50 percent of stock in such corporation. Section
512(b)(13)(D).
The Service also ruled that the payments received by M
pursuant to the directory agreement qualified as royalties
under section 512(b)(2), and indicated that the rental payments
from N to M under the lease would qualify as rent
under section 512(b)(3), which excludes rent from UBTI. As
with the licensing agreement royalty payments, however, the
Service did not rule regarding whether those payments might
still constitute UBTI under section 512(b)(13). The Service
also did not rule on whether the payments by N to M for
administrative services might constitute UBTI. The Service
did note that M had represented that it would report any
compensation received under the advertising agreement as
UBTI.
Stock and Stock Options
Citing the prohibitions on private inurement found in
section 501(c)(3) and reg. section 1.501(c)(3)-1(c)(2) and on
serving private interests found in reg. section 1.501(c)(3)-
1(d)(1)(ii), the Service also reviewed whether the planned
distribution of stock by N to its employees and of stock and
stock options by M to its employees violated those prohibitions.
The Service first noted that since M and N are separate
legal entities, and the stock to be provided by N to its employees
would constitute reasonable compensation for the
services they would render, the provision of such stock by N
was not incompatible or inconsistent with M carrying out its
exempt purposes. The Service took particular note of the fact
that a compensation consultant would be retained by N to
ensure the reasonableness of the total compensation paid by
N to its directors, officers, and employees.
The Service also concluded that M's provision of N stock
or stock options would not violate these prohibitions "so long
as the total compensation to be paid by M to an employee is
reasonable in amount." Relying on M's representation that
this condition would be satisfied, the Service concluded that
the provision by M of such stock or stock options to its
employees would not adversely affect M's tax-exempt status
under section 501(c)(3).
The ruling provides a helpful guide for creating and structuring
financial relationships with a taxable subsidiary. The
discussion of stock and stock options in particular may be
the first instance of the Service ruling on the provision of
stock and stock options of a taxable subsidiary by the exempt
parent to its employees, although the Service has ruled before
on the ramifications of a taxable subsidiary of an exempt
parent providing stock or stock options to the subsidiary's
employees. (See, e.g., PLR 9722032 (Feb. 28, 1997); Doc
97-15432 (9 pages); or 97 TNT 104-34.) The ruling suggests,
however, that the Service has adopted a few positions that do
not appear to be completely consistent with settled law, and
also leaves several important UBTI issues unresolved.
The Service's conclusion that N should be treated as separate
from M for federal tax purposes is clearly correct, and
the detailed description of the creation of N and the financial
relationships between M and N provides helpful information
regarding how to ensure this result. For example, it is useful
to have it confirmed that an exempt parent can have (apparently)
complete control over the selection of the members of
the governing body of the wholly owned subsidiary, and also
have reserved powers over major actions on the part of the
subsidiary, and yet still be able to treat the subsidiary as a
separate entity.
One troubling aspect of the Service's reasoning, however,
is that the Service appears to have considered crucial certain
facts that appear to go beyond what is required by the case
law cited by the Service. It is certainly true that to be treated
as a separate entity, the subsidiary must have a bona fide
business purpose, although carrying on actual business activity
also is sufficient. See Moline Properties, 319 U.S. at
438-39. The Service's reason for apparently relying on the
fact that N will be serving people beyond M's members to
demonstrate that N had a bona fide business purpose is unclear,
however. It seems reasonable to assume that an exempt
organization could form a wholly owned taxable subsidiary
for the purpose of engaging in business activities that benefit
only the exempt organization's members, and still have that
subsidiary qualify as a separate entity for tax purposes. For
example, in PLR 199938041 (June 28, 1999), profiled in this
space in March 2000, the Service appeared to have no difficulty
treating a wholly owned taxable subsidiary as a separate
entity for federal tax purposes even though the entity's role
was to contract with various service providers who provided
services to the exempt parent's members. A better reading of
the Service's reliance on the scope of the beneficiaries of N's
activities may be that providing services to persons other than
M's members helped demonstrate N's bona fide business
purpose but was not determinative. (For PLR 199938041, see
The Exempt Organization Tax Review, March 2000, p. 478;
Doc 1999-30923 (16 original pages); or 1999 TNT 186-26.)
The Service's apparent conclusion that for a subsidiary to
be considered a separate entity it must have both separate
day-to-day management and a majority of board members
who are not officers or employees of the exempt parent, is
even more troubling. The Krivo case, which the Service
apparently relies on for the proposition that a subsidiary
cannot be a "mere instrumentality" if it is to be regarded as
separate for federal tax purposes, imposes no such requirement.
It explicitly provides that stock ownership, and therefore
presumably board control, does not per se resolve the
instrumentality question. See Krivo, 483 F.2d at 1104. More
importantly, the court concluded in that case that even if the
dominant organization shared managerial responsibility for
some of the subservient corporation's operations, this was
not enough to justify disregarding the subsidiary's separate
corporate existence. Id. at 1112. Rather, evidence showing
that the dominant organization had "actual, operative, total
control of the subservient corporation" was required. Id. at
The Service's reliance on Krivo is also misplaced for
another reason. Krivo was not a tax case; rather it involved
the question of whether a creditor could seek payment from
the dominant corporation for the subservient corporation's
debt. A case decided after Krivo explicitly noted that disregarding
an entity for liability purposes is subject to a different,
and apparently lower, standard than disregarding an entity
for federal tax purposes. Avco Delta Corp. Canada Ltd. v.
United States, 540 F.2d 258, 264 (7th Cir. 1976), cert. denied
sub nom. Canadian Parkhill Pipe Stringing Ltd. v. United
States, 429 U.S. 1040 (1977). The Supreme Court has affirmed
that in applying the principles of Moline Properties,
"when a corporation carries on business activity the fact that
the owner retains direction of its affairs down [to] the minutest
detail, provides all of its assets and takes all of its profits can
make no difference tax-wise." National Carbide Corp. v.
Commissioner, 336 U.S. 422, 431-32 (1949).
This conclusion is also consistent with how the Service
treats related organizations in the section 501(c)(3)/501(c)(4)
context, where it has found that overlapping directorates and
personnel do not prevent related organizations from being
treated as separate entities for federal tax purposes as long
as the organizations maintain separate finances and held
themselves out as separate organizations. See, e.g., Ward L.
Thomas & Judith E. Kindell, "Affiliations Among Political,
Lobbying and Educational Organizations," Exempt Organizations
Technical Instruction Program for FY 2000, at 255,
257-60 (Doc 1999-28450 (12 original pages); 1999 TNT
169-30). There are therefore strong legal grounds for asserting
that even if an exempt organization parent's officers, directors,
or employees make up the entire membership of the board
of directors of a taxable subsidiary, and even if the exempt
organization controls the day-to-day activities of the taxable
subsidiary through overlapping officers or other mechanisms,
the subsidiary must be treated as a separate entity for federal
tax purposes as long as the appropriate corporate formalities
are observed and the finances of the subsidiary are kept
separate from those of the parent.
Unrelated Business Taxable Income
The Service's conclusions that various income streams fall
within the section 512(b)(1) and section 512(b)(2) exceptions
to UBTI for dividends and royalties are helpful, if not surprising,
particularly in light of the line of cases concluding
that payments for the use of intangibles such as mailing lists
were royalties within the meaning of section 512(b)(2). The
lack of conclusions with respect to some of the other income
streams is disappointing, however. This is not to fault the
Service, since presumably M intentionally chose not to request
rulings with respect to the other income streams.
With respect to the royalty and rental payments from N
to M, those payments undoubtedly fall within the section
512(b)(13) provision that renders those types of payments
UBTI, in spite of sections 512(b)(1) and 512(b)(2), given that
M will apparently own more than 50 percent of N's stock, by
voting and value, for at least the immediate future.
What is more troubling, however, is the Service's suggestion
that whether the payments by N to M for the provision
of administrative services is UBTI is an open question. Although
the Service may have only been making it clear that
it was not addressing this issue, many related organizations
share such services, on a reimbursement basis, and do not
treat the reimbursements as UBTI. For example, many section
501(c)(3) and 501(c)(4) affiliates routinely share the costs
for such services because it would be highly inefficient to
have, for example, two separate information services departments
or two separate accounting departments. The 501(c)(3)/
501(c)(4) situation may be different because of the related
missions of such affiliates and the constitutional issues that
require that administrative burdens associated with a
501(c)(3) organization creating and maintaining a section
501(c)(4) affiliate be minimal, but it is still the model with
which many exempt organizations are familiar and so use for
their taxable subsidiaries as well. The Service has also appeared
to bless this model, at least in the 501(c)(3)/501(c)(4)
context. See, e.g., Judith E. Kindell & John Francis Reilly,
"Election Year Issues," Exempt Organizations Technical Instruction
Program for FY 2002, at 335, 368-69 (Doc 2001-
25435 (128 original pages); 2001 TNT 193-50.).
If merely being reimbursed for such services results in
UBTI, this issue needs to be clarified as many organizations
undoubtedly do not viewsuch reimbursements in this fashion.
This is particularly true given that it is probably possible to
avoid creating UBTI if the subsidiary pays the employees of
the exempt parent directly for the portion of their time used
by the subsidiary, with the exempt parent reducing the compensation
it pays proportionately, since then the subsidiary
would not be making any direct payments to the exempt
parent. This solution is awkward, significantly increases the
paperwork of both entities, and may cause employee benefit
or other employment-related problems, so it would not be
advisable absent a clear indication that such reimbursements
are in fact UBTI.
If it were not for the need to report all UBTI on Form 990
and Form 990-T, this issue would also be irrelevant. This is
because if the administrative services are truly provided at
cost, the deductions associated with providing such services
will cancel out the income received from the taxable subsidiary
for such services. It therefore seems to be a relatively
useless exercise to require an exempt parent to report such
reimbursements as UBTI, at least when the payments are
designed merely to reimburse the parent for its costs and so
will not result in any net UBTI that would be subject to tax.
Private Inurement and Private Benefit
The stock and stock option conclusions are certainly reasonable,
although again it is helpful to have these conclusions
spelled out, albeit in a nonprecedential ruling. The key issue
is whether the total compensation paid to each employee,
whether at the exempt parent or the taxable subsidiary level,
is reasonable. Given the Service's favorable cite to the taxable
subsidiary's use of a compensation consultant, it is probably
advisable to obtain outside expertise when incorporating such
difficult-to-value items in the compensation of employees of
either the parent or the subsidiary.
It is also useful to see that the Service was apparently
untroubled by the fact that N is only paying M its costs for
office space and administrative services, even though N will
in the near future be owned in part by private individuals (N's
directors, officers, and employees, as well as M's key employees).
The Service may simply have assumed that M's
costs were essentially equal to the fair market value of the
office space and administrative services being provided by
M, given that those costs were primarily or exclusively determined
byM's arm's-length arrangements with third parties,
such as M's landlord and employees. If this was the case, and
the ruling is not clear on this point, it certainly makes determining
the appropriate amounts to pay for such items relatively
easy, as opposed to requiring the entities involved to
determine the fair market value rate for such items based on
market comparables.
The Service may, however, not have commented on this
point for the same reason it left some of the UBTI issues
unresolved — M did not ask for a ruling relating to the
appropriateness of these reimbursement arrangements under
section 501(c)(3). The Service may also not have commented
on this point because the Administrative Services Agreement
and the Lease appeared to be temporary arrangements, expected
to last only as long as it took for N to become sufficiently
established to justify renting its own office space and
hiring its own administrative staff. Given the uncertainty on
this point, probably little weight should be attributed to the
lack of a ruling on this point.
As the number and sophistication of exempt organizations
grows, it is inevitable that they will adopt more complex
corporate structures to manage their tax and liability issues.
This ruling is a good step toward providing exempt organizations
with a better sense of how best to create subsidiaries
while still preserving tax-exempt status and minimizing
UBTI. Although it does not answer every question, and appears
to use a flawed analysis with respect to the issue of the
standard for separate entity treatment although reaching the
correct conclusion in this case, it provides a helpful roadmap
of the relevant legal issues and shows, in part, how to address
them for exempt organizations considering creating taxable
subsidiaries.


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Articles What's the difference between Rafters & Trusses
What's the difference between Rafters & Trusses
November 10, 2020 By ARR
Recently a client asked about how their roof was constructed.
It was explained that his Etobicoke home was originally built over eighty years ago; and that the method involved stick framing the original roof, and that covering the framing were roof boards about one inch thick.
The home had an additional flat roof at the rear, which had been constructed using a boxed truss system and that it had been sheeted over with three-quarter-inch plywood. The addition was only ten years old he noted.
As a recent owner of the home, he was curious to understand what he had. His next questions essentially involved asking me what the merits and details of each construction method were.
I explained that his original house roof was a combination hip and gable design having different pitches and as a result, carpenters of the day would have had to hand-cut and frame the roofline to achieve the complex roof structure.
Trusses were used on the addition in modern times because the supporting structure would be repeated (a series of rectangular frames each identical to the other); which could be raised on the roof saving considerable time over building each "roof frame" by hand.
I further explained that a truss design was used for the flat roof because the designer had intended to create somewhat of an attic beneath the flat roof to accommodate a high degree of thermal insulation in the ceiling, and to permit an air space above.
Although not uncommon to use trusses in residential flat roof construction, most flat roofs are framed using a series of roof joists made of dimensional lumber, and are also typically framed by hand.
The client felt that the explanation was quite interesting. Me, not so much, but later I realized that in our job (as roofers), it is important to be able to identify the structural elements of the roof for such issues as achieving proper ventilation and insulation methods, roof drainage and when having to deal with structural roof repairs.
As a result, perhaps our clients would benefit from understanding some basic information on roof rafters versus roof trusses in order that they could achieve a greater understanding of what they ultimately would be paying for when undertaking major roof work.
What is a rafter?
source: nations home inspections
In the context of roof framing construction a rafter is a structural member made of dimensional lumber such as a (2"x4"),(2"x6"),(2"x8"), etc. Most residential roof framing on sloped roofs today utilize (2"x6") spruce lumber.
On flat roofs which are hand framed,(2"x8"), (2"x10") and (2"x12") roof joists are the most commonly used and the size used is based on the span (width) of the roof, and the distance specified between each individual rafter.
Rafter spacing is usually completed on 16" centers, however roofs which must sustain a heavy load may be spaced at 12" centres. Both roof rafters and roof joists rest on the perimeter framed house walls, on what are known as a doubled top plate. Modern residential exterior walls are typically constructed using (2"x6") lumber. Many older homes were built with (2"x4") walls.
Larger wall framing members (known as wall studs) not only provides greater strength, but permits higher degrees of wall insulation to be installed, in order to meet today's building code requirements.
When framing a roof, there are a few common types of rafters which are used. At the top of the roof there is a member called a ridge beam. The ridge beam is the uppermost point of the roof where rafters are attached.
King rafters are used on gable roofs and the field surface of hip roof designs. They are characterized by having the same degree of pitch cut at the ridge as at the eaves area.
All rafters on a sloping roof have a "birds mouth or bird beak" as it is termed, cut toward the bottom of the rafter; which in effect is a notch cut which allows the rafter to rest on the top plate of the wall. The cut is made using the rise and run (number of pitch degrees), in order to achieve a perfect fit.
On a hip roof design (a four-sided roof characterized as having at least two triangular opposing slopes); hip rafters must be cut to form the sloping corners of the roof, running from the ridge beam to the intersecting outside corners of the top of the exterior walls.
The hip rafters require two complex angular cuts at the top of the rafter, in order that it may be nailed both into the ridge beam and also the king rafter on the adjacent slope. Rafters which must be attached to the hip rafter at their top-most point are referred to as jack rafters, and also require a complex miter cut to enable attachment to the hip rafter which is on a descending corner angle.
To complete such cuts requires the expertise of a skilled framing carpenter. Hip rafters are also constructed with a bird's beak to permit attachment to the outer corners of the tops of the walls.
Essentially any roof which involves a complex roof design or multiple pitches requires stick framing methods, performed by a carpenter.
What is a truss?
Roof trusses are pre-engineered framing structures that can provide a number of advantages. In keeping with modern building methods; most roof trusses are computer engineered and factory built to a specific project's requirements, or on mass; which makes standard pitches and spans available for builders.
Some advantages of using roof trusses include the following:
Can be pre-engineered to accommodate snow load and wind requirements
Can save labour and time in relationship to installation
Lower manufacturing costs versus conventional framing lumber
Can be shipped to site and craned onto building
Can lessen construction time
Can incorporate complex interior ceiling design such as vaults and barrels
Most typically roof trusses are ordered by a builder who supplies drawings to the truss manufacturer. The truss manufacturer then replicates design specifications into their computer which can program material cuts. Shop staff can then factory assemble the trusses and prepare for shipping to site.
Trusses utilize galvanized metal plates which are placed strategically where intersecting frame members adjoin one another.
Unless standard truss designs and sizes can be utilized, the builder must be prepared to wait several weeks for the manufacturing of custom orders to be completed.
Once delivered to the jobsite, trusses can be lifted to the roof where typically two or three framers can stand up the truss sections and secure them to the top plates of the walls. Dimensional lumber is then used to tie/brace the newly erected trusses to one another.
As there are specific names for rafters designed for a particular purpose; trusses also have specific names based on the particular design characteristics of that truss. As an example, certain trusses may have an integral framing member in the shape of a "W" which is termed a "King" truss. Those who are familiar with roof trusses can then specify a particular design of truss by name when describing what they may require.
With modern roof building methods, many homes and buildings are constructed using a combination of roof trusses and conventional framing. As an example; if building a structure is designed with a gable roof; the builder could erect triangular trusses to comprise the main building structure, and then utilize the carpenters to hand frame a series of dormers having a different design and pitch.
In the roofing industry; there are always requirements to repair and replace structural roof and wall damage which can occur as a result of prolonged leaking, mould, fire, and original design flaws. As a result, AVENUE ROAD ROOFING® has experienced, skilled carpenters and team members versed in the requirements of restorative roof work.
The carpentry division at ARR® also constructs beautiful and strong roof decks, ground decks, can slope flat roofs and rebuild porches and structural columns related. Heritage homes that have exterior wood siding that needs repair are another service provided among other building envelope maintenance items.
To learn more about roof-related carpentry, carpentry, roofing, repairs and maintenance contact: www.avenueroadroofing.com or visit us on YOUTUBE™.

redpajama_set_name: RedPajamaCommonCrawl


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Writing tips from authors
Patrick Ness's guide to writing
Laying out a structure
Patrick Ness' guide to writing: Laying out a structure
Author Patrick Ness shares his advice on how to plan your writing – from how long a chapter should be to figuring out the rhythm.
This set of tips is inspired by a 15-year-old writer who emailed me to ask, quite seriously, how long a chapter is supposed to be.
I totally understand the anxiety behind the question, and the fantastically unhelpful answer, of course, is, 'As long as it needs to be.' The wonderful and terrible thing about writing is that you can pretty much do whatever you want, as long as it's serving the story you're telling. It's up to you to figure out what those needs are, however, and that's what makes you a writer.
So why not make it easier on yourself and make a few of those decisions before you start writing? Because, believe it or not, this is writing, too.
So before you start, ask yourself a simple question...
What's going to happen where?
Really, easy as that. I'm not talking details, I'm talking about the general thrust to the story that should already be cooking around your head.
For example, where does the heartbreak occur so that the reconciliation that never happens is as poignant as possible? Literally where. At the front? Halfway through? Where? If you don't know, maybe you're not ready to start yet.
Even simpler, what general chain of events needs to happen (and in what order) for your climax to happen? Not necessarily specifics again, but if someone's held at gunpoint, they're going to need to get a gun somewhere along the way. So where do they get it?
If you've decided beforehand that an accidental death is an important turning point, say, at the first third of your story and you're 90,000 words in and haven't reached it yet, well, there might be some rethinking to do. But deciding where it is ahead of time can be a good step to avoiding that 90,000 word problem in the first place.
Get even a few of these things sorted before you set out, and you're going to be a lot more comfortable settling into your early writing.
Structure vs rhythm
I've said before I don't care to plan in a lot of detail – I set out with a general outline, some key scenes, and an endpoint in hand – so I tend to think of setting out a rhythm to write within rather than a rigid structure. For The Knife of Never Letting Go, momentum was of the utmost importance, so before I started, I decided on a rhythm of short, sharp chapters, averaging about 2500 words each. What that did was force me to accomplish quickly what each chapter needed and saved me from lazy, overstuffed writing (I hope!).
I also set that smaller rhythm of chapters into a larger rhythm of parts, each part having six chapters and its own arc in the story with its own climax (so in Part 1, Todd discovers the silence and has to go on the run; Part 2, he discovers the reason he has to run and just how much danger he's in... and so on). I only had general plans before I started, by the way, and didn't do any detailed plotting until I got to each part. It let the story be loose enough to tell itself on the way, but also gently planned enough so I didn't panic.
A nice by-product of this is that it breaks the book down into workable sections, so I'm not always feeling I'm on top of a huge unwieldy beast. It's easier to feel control over a 17,000 word part than a 100,000 word novel.
Breaking the structure
What's great about structure (or rhythm) is that, without them knowing it, you're encouraging your reader into a pattern, one that they grow happily comfortable with. So how much fun to then break the structure when they're least expecting it?
Now, you have to be careful here. It has to be done right because otherwise they'll be pulled out of the story and blame you (rightly) for it. But in Knife, all the parts play out to the same pattern, except for the last part which is almost twice as long. Why? Because in the writing, it felt like the characters were beyond everything that might save them and out in a world of the unknown. So why not put the reader there as well?
It wasn't a mercenary decision purely to manipulate a reader, but by that point I was confident enough in my story to listen to what it needed. And at that point, what it needed was to break the rules I'd set. Who am I to argue?
Having said all this, this is a garment to wear loosely when you start out. You'll soon get a feeling for what's right for the rhythm of your story, and your instincts will improve very quickly.
Plus, there's no wrong choice, here; it's whatever is right for your story, and you can always change your mind if it's not working. Just listen out for the first cries of the shape your story wants to take. Deciding even a few loose guidelines before you start could save you a lot of grief.
And then in your next book, you can do something completely different.
Read features from Patrick Ness when he was BookTrust's Writer in Residence
On when to read
Compare and despair
On finding time to write
Freedom from tyranny
It talks! How does your book sound?
Getting published: Are you ready?
Getting published: Where to send it?
Getting published: What to submit


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Structural and Spectral Properties of 1,2-dihydroxy-9,10-anthraquinone Dye Sensitizer for Solar Cell Applications
S. Ranjithaa, V. Aroulmojib, T. Mohrb, c, P.M. Anbarasand and G. Rajarajane
aVelalar College of Engineering and Technology, Thindal, Erode-638012, Tamilnadu, India
bMahendra Educational Institutions, Mallasamudram-637503, Tamil Nadu, India
cDepartment of Energy and Drive Systems, University of Applied Sciences, Ulm, Germany
dDepartment of Physics, Periyar University, Salem-636011, Tamil Nadu, India
eSelvam College of Technology, Namakkal-637003, Tamil Nadu, India
Received: November 5, 2013; revised version March 5, 2014; in final form March 10, 2014
The geometries, electronic structures, polarizabilities, and hyperpolarizabilities of natural dye sensitizer alizarin from madder fruit was studied based on density functional theory using the hybrid functional B3LYP. Features of the electronic absorption spectra in the visible and near-UV regions were assigned based on time-dependent density function theory calculations. The calculated results suggest three excited states with the lowest excited energies in 1,2-dihydroxy-9,10-anthraquinone and it was due to photoinduced electron transfer processes. The interfacial electron transfer between semiconductor TiO2 electrode and dye sensitizer 1,2-dihydroxy-9,10-anthraquinone is due to an electron injection process from excited dye to the semiconductor conduction band. The importance of hydroxyl group in geometries, electronic structures and spectral properties were reported.
PACS numbers: 88.40.H-, 31.10.+Z, 71.15.Mb, 31.15.ae


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Tag: UNESCO
Matera~Life in a Cave Home
May 27, 2016 May 27, 2016 timelessitaly
"The narrow path wound its way down and around, passing over the roofs of the houses, if houses they could be called. They were caves, dug unto hardened clay walls of the gully, each with its own facade, some of which were quite handsome, with eighteenth-century ornamentation." Carlo Levi, Christ Stopped at Eboli
Matera is an ancient cave city in Basilicata located just above the instep near the heel of the boot that is Italy. Because of its stark similarity to the holy lands, several films have been made here.
A most unusual city, many people aren't sure what to think of it. Unlike Florence, who experienced the Renaissance and a golden age, Matera experienced nothing of the sort. Life here has been difficult, especially between 1800 up until the 1950's, when the Italian government moved over half of the inhabitants to higher ground and new homes. But in the process, the Materans lost their tight community of neighbors who worked together and shared each other's burdens.
Today, Matera is no longer looked upon as poverty ridden and uncivilized, but is becoming cherished for its primordial ways.
Here, in the Sasso Barisano, the skilled craftsman Eustachio Rizzi and his sons, have attempted to bear witness to a past filled with memories and emotions.
This unique place entitled "C'era una volta," meaning "Once upon a time," uses furnishings and sculptures to portray and illustrate life in the home, in Matera, up until the end of the 60's.
"Once upon a time there was a family in Matera who lived in a cave cut out of rocks. Today the moments, the gestures, the rhythm of everyday life in those times are reborn…"
Troglodyte living is what the people of Matera knew. As an area continuously inhabited since neolithic times, Matera and the Sassi have long ago become ancient grounds, old and barren. Many of the cave dwellings consisted of only one room. Parents and grandparents generally slept in the front, with the children in the back and the animals behind them.
There was no plumbing, no electricity and no telephones. Rainwater was collected in stone basins by underground ceramic pipes. People lived one above the other where palazzi and chapels were mixed among the cave dwellings. Cemeteries were built above church roofs.
The Materans were self-sufficient and worked hard with what little they had available to them. The barren soil around them was devoid of essential nutrients to support much vegetation.
Food was hard to come by. Vito Festo, a man who grew up here in the 1950's, remembered building bird traps that he placed on a parapet as a young boy, but he never caught any. He also remembers walking the family pig with his brother every night before putting it in its stall behind their bed.
The women baked a unique horn-shaped bread in shared ovens that were levened and baked slowly, making large pores so the bread would stay fresh for a week. The cucina povera was very simple and consisted mostly of chickpeas, fava beans, and crushed peppers. One popular dish, Ciallèdd, was made from eggs, the town bread, and flowers that grew in nearby Murgia which were often yellow asphodels.
Community was cherished and vital to the Materans. Everyone knew each other and helped one another.They developed their own dialect, rituals and songs. People lived outside in their vicinato, or courtyard-like tiny piazza. Children played, men gathered to work and talk, and the women shelled peas together.
Matera became a UNESCO World Heritage Site in 1993 and today is becoming a mecca of artists, businesses and upscale restaurants. This past October, the European Commission named Matera as one of its two capitals of European Culture for 2019.
Most places in Italy give an instant sense of wealth with glorious white marble fountains and exquisite iron balconies. Matera leaves a testament to a life of thrift and hardship where nothing is wasted. I find beauty in both.
*A Cave with a View, The New Yorker, by D.T. Max
History Basilicata, Carlo Levi, cave home, Italy, Matera, neolithic, Sassi, Sasso Barisano, troglodyte, UNESCO 25 Comments
August 18, 2015 August 30, 2017 timelessitaly
Matera, cave dwellings piled one on top of the other
During the filming of The Passion of the Christ in Matera, everyone around Jim Caviezel, the actor who played Christ, said they saw fire coming out of the right and left side of his head. A glow surrounded his entire body. To Jim, being struck by lightening felt like a giant clap on his ears while he was doing The Sermon on the Mount scene. Director Mel Gibson stood speechless before asking Jim what happened to his hair.
Matera, the rock city of Basilicata sought after by filmmakers searching for a biblical landscape, looks surprisingly like the Holy lands. It proved to be the perfect setting for Mel Gobson's movie, The Passion of the Christ.
Poster outside of the cave church of Madonna delle Virtu. Inside,'The Last Supper' was filmed in one of the rooms.
I had the opportunity to visit Matera recently, also known as "the second Bethlehem." These peculiar cave churches and settlements carved into rock became a UNESCO World Heritage Site in 1993. It truly is a city of rocks in the midst of a desolate land.
The Rupestrian Complex of Matera includes the Church of Madonna delle Virtu, a twelfth century church completely carved out of the tufa rock. It is considered the best church architecturally decorated in Matera. The central apse contains a large fresco of the crucifixion with the Virgin Mary and St. John the Evangelist dating from the sixteenth century (pictured below). Across from this one is another crucifixion fresco from the fourteenth century (not shown).
The rock city of Matera in Basilicata possesses over 150 Rupestrian (meaning art done on cave walls) churches dug into the soft tufa walls, housing frescoes spanning nearly 1,000 years. The Park of Rupestrian Churches of Matera covers 19,768 acres and contains the best surviving rock-cut settlements in the Mediterranean region. These cave churches, dating from antiquity through the medieval period, were often places of pagan worship before they became established by Christian monks. The entire area of caves have been continuously inhabited since paleolithic times.
Close-up of the 16th c. Crucifixion just inside the entrance
The tall front doors to The Madonna of the Virtu is just off the street. We stepped immediately into the church which was tall and cavernous.
There is another section to the complex which was a monastery during the ninth century and expanded over time. It was inhabited by a small community of nuns from Accon in Palestine. Much later, after being abandoned, the monastery became a storeroom for hay and the production of wine.
"The Passion of the Christ" was filmed in Matera by Mel Gibson in 2004, giving it the name of 'the Jerusalem of Basilicata.' In the movie, the ancient monastery's central room was chosen as the scene for "The Last Supper," and for "The Washing of the Feet."
The monastery began as a small crypt which was enlarged with time.
Throughout the monastery are pieces of modern art placed perfectly within wall niches and on pedestals. An international sculpture exhibit is hosted in the monastery each year.
Beyond the monastery within the same complex is the Church of San Nicola, a 10th century monastic settlement.
Within this archway is a fresco of, right to left, St. Barbara – with auburn hair and dressed in rich imperial robes, St. Nicholas the Greek, and St. Pantaleone, holding a box symbolizing his medical practice. A burial pit lies below.
Close-up (R to L) St. Barbara, St. Nicholas and St. Pantaleone
Below is a 14th century fresco of the Crucifixion with the Madonna on the left and St. John the Evangelist on the right, holding a Gospel roll in his hand. Daffodils, which are commonly found in the area, are pictured on either side of the cross at the bottom.
You can almost see the Crucifixion fresco through the rock hole in the center of the photo below.
Outside of the complex, old cave dwellings can be seen along the ridge of the hillside. In the early part of the 1900's, the poor lived within Matera's caves, many large families who made them into homes where they cohabited with their animals. Conditions grew worse until, in 1952, the government evacuated 15,000 inhabitants and resettled them due to extreme poverty and poor hygienic circumstances.
Across the ravine from the door of Madonna delle Virtu – Paleolithic caves line the top of the hill
Today, Matera is experiencing a rebirth as many of the cave churches, some previously used as stables or filled with garbage, have been cleaned up and restored. The extremely delicate frescoes are slowly disappearing as tourists continue to touch them. But they remain fascinating although a bit eerie. The passing of time has had no bearing inside these rupestrian churches. It is only the whisper of monks in silent prayer that still remain.
Art Crucifixion, Madonna delle Virtu, Matera, Rupestrian church, The Passion of the Christ, The Rupestrian Complex of Madonna delle Virtu, UNESCO 22 Comments
Italy, Always a Good Idea ~ I Return to Bella Italia
April 27, 2015 timelessitaly
"Italy is a dream that keeps returning for the rest of your life." -Anna Akhmatova
Italy is always a good idea. I have often come home from a visit with a feeling of pure saturation. I foolishly think to myself that I have seen all I need to see, that i've tasted all I need to taste, smell, touch. But after a month, I am mentally planning my next adventure to bella Italia. There is no getting over it.
So, I will be returning to Italy this late May for three weeks. I am so excited I can hardly sleep. I walk around the house in a state of disorientation. My mind is already miles away….in the land I love so passionately.
This trip will begin in Venice, where I will meet with two friends. We will head toward the heel of the boot in Puglia and enjoy a stay in an agriturismo complete with cooking classes, tours to wineries, and exciting day trips. This area of Italy is somewhat new to me so i'm anticipating a lot of new adventures and discoveries that I can't wait to share with all of you.
After a stay in Matera, the UNESCO site of the ancient cave dwellings, I will end up in Positano where I hope to relax, enjoy the Mediterranean ambience, and write.
I will be posting some photos as I travel so be sure to stay tuned. E 'il mio grande piacere di portare a voi i migliori d'Italia! (It is my great pleasure to bring to you the best of Italy.)
History Italy, Matera, Positano, Puglia, UNESCO, Venice 36 Comments
Pompeii is Losing its Pomp
May 7, 2013 May 8, 2013 cnels2
Never have any historical sites blown my mind quite like Pompeii and its smaller neighbor Heculaneum. The vast array of ruins spread out before me from a civilization that suddenly ceased to exist is simply unbelievable. Buried under 30 feet of hot ash from the eruption of Mt. Vesuvius in AD 79, they have laid perfectly preserved until excavations began in the 18th century. Much is left to see and investigate, including some still partially imbedded lead pipes once used for the water supply. Elegant tile mosaics, colorful frescoes' and brick walls bring dimension to these ghost cities.
It's obvious that Pompeii was a thriving harbor town in its time. It's obvious that Pompeii was a thriving harbor town in its time. In recent years, walls have crumbled and collapses continue to occur. Because the ancient Roman city is seriously exposed to the elements, it is constantly in a state of emergency. This UNESCO World Heritage site, one of the biggest and most important sites in the world, happens to be located in an area with one of the highest concentrations of organized crime in all of Europe, according to Fabrizio Barca, minister of territorial cohesion for Prime Minister Mario Monte.
The Great Pompeii Project, which began a $137 million effort by the European Union, has been an effort to preserve Pompeii and also make it accessible to the public. It strives to support a culture-driven society against perilous odds. Bureaucracy has been a constant challenge. The result is a lack of strategic planning and the limited personnel of the site's troubled management.
Conservators who attempt to impart a plan of systematic maintenance of the 163 acre site are thwarted by emergent temporary repairs of crumbling walls and water-damaged frescoes.
Pillars of another time…remains of a prestigious Villa
Fortunately, many of the artifacts found in Pompeii are safely tucked away in Naples Archaeological Museum to be seen and enjoyed by the public. However, Pompeii offers the best look anywhere at what life in Rome must have been like around 2,000 years ago, providing archaeologists volumes about daily Roman life.
Lemon Orchards in the midst of ruins
Walking through Pompeii is like taking a stroll through the ancient past. It's easy to imagine the hustle and bustle, chariots clattering down the stone streets, people grouped together in conversation, shopkeepers, foreigners, sailors and city administrators, all mingling to create a famous commercial port town…..the crossroads of many civilizations.
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History chariots, European Union, Frescoes, Mt. Vesuvius, Naples Archaeological Museum, Pompeii, ruins, The Great Pompeii Project, tile mosaics, UNESCO Leave a comment
Positano's Classy Ristorante La Sponda
Squid Ink Pasta ~ My First Experience


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UK: Footage shows the River Severn bursts its banks in Worcester as residents brace for more flooding
9 January 2023, 1:21 pm
The footage was filmed on January 9.
Reuters Videos
Israel refills the Sea of Galilee, supplying Jordan on the way
STORY: Israel is saving its main freshwater reservoir from the effects of climate changeThe Sea of Galilee was being lost to droughtsSo Israel built a chain of desalination plants along its Meditteranean coast They turn seawater into freshwater, to refill the lake when water levels get low(Yoav Barkay, Manager of the national water carrier)"With this environment of climate changes, you don't know what to expect next year and the year afterward. We are standing now in the late January and with very little rainfalls during this winter in Israel, arid winter basically with no rainfall. And we are no longer depending on rain basically for water supply because we know to manage the system and take the extra water, the extra water we produce artificially with desalination plants, and bring it to fill the natural lake if needed."The new system will also allow Israel to double the amount of water it sells to JordanWater was a major component in the 1994 peace treaty between the two nations
Strong quake shakes southern Philippines, classes suspended
A strong, shallow earthquake shook a mountainous region in the southeastern Philippines on Wednesday, but there were no immediate reports of major damage or injuries, officials said. The 6.1 magnitude quake, which was triggered by a local fault, struck about 14 kilometers (8.7 miles) northeast of New Bataan town in the coastal province of Davao de Oro at a depth of 11 kilometers (6.8 miles), the Philippine Institute of Volcanology and Seismology said. Davao de Oro Gov. Dorothy Gonzaga suspended classes and most government work in the province on Thursday to allow inspections of buildings for possible damage.
What to expect as 'green comet' hurtles towards close encounter with Earth
Object will be close enough to see – and could offer Nasa important information about the solar system
Poisoner who killed eagles fined in poaching clampdown
Poacher used a banned substance to kill the bird near Dierona village in the Limassol district
Scam warning for homes fitted with solar panels
Households with solar panels are at increased risk of being scammed as new figures show a sharp rise in fraudsters tempting victims with energy-saving deals.
'600-Pound' Ocean Sunfish Rescued by Volunteers After Getting Stuck in Nantucket Harbor
A 600-pound ocean sunfish, also known as a Mola mola, was rescued by a team of volunteers in Nantucket, Massachusetts, after the fish became cold stunned and stuck in a harbor on November 18.Video recorded by Rain Harbison shows the ocean sunfish, one of the largest bony fish in the ocean, being lowered into open water with the assistance of a truck."Because the sun and tide were dropping, we didn't have time to do a boat rescue," Harbison told Storyful.After being alerted about the cold-stunned fish in the harbor, Harbison and her team members at the Marina Mammal Alliance Nantucket worked together to ensure the safety of the creature.Harbison contacted an expert on ocean sunfish, who advised that it "could live out of water for 15 minutes tops, but if we poured seawater in its gills we could add a little time to that."Local news reported that heavy ocean sunfish required four people to load it onto the truck."I used my watering cans, from my gardening business, to hydrate it with sea water [while we drove] it through the town and to the open ocean," Harbison said. "We got it into the ocean less than 12 minutes after we hauled it out." Credit: Rain Harbison via Storyful
New rules mean residents will have to book before visiting Essex recycling centres
From Monday, March 13 residents visiting all Essex County Council (ECC) recycling centres will need to book in advance
Injured Fawn Rescued in Ukraine After Falling Into Frozen Lake
An injured fawn was rescued by firefighters after it fell into an ice-covered lake in the Ukrainian village of Bovkun, south of Kyiv, on Monday, January 30, officials said.This footage of the rescue was released by the State Emergency Service (SES) of Ukraine, which said the deer was likely to have been fleeing from a predator when it tumbled off a cliff and into the reservoir.The rescuers used a rope, a ladder, and a lifebuoy to bring the fawn safely back to shore.The animal, exhausted after its ordeal, was warmed up in a blanket and transferred to a veterinary clinic, the SES said. Credit: SES of Ukraine via Storyful
Threat of losing homes to sea taking 'huge toll on mental health' of villagers
Ian Brennan said more than 90 homes in Hemsby are at risk of going into the sea in the next 25 years if nothing is done.
Herald Scotland
Police called in as gamekeepers and conservation body clash over botched deer killing
POLICE have been called into a row over an out-of-season deer cull in the North West Highlands.
Why these houses in a Herefordshire country garden won't be built
A plan to build five homes on a once-popular Herefordshire country garden have been refused for numerous reasons.
'Blue marble': how half a century of climate change has altered the face of the Earth
A new image has been taken of the whole Earth 50 years after the first - revealing noticeable changes to its surface.
Isle of Wight County Press
Photographer snaps green comet over Whitwell - have YOU seen it yet?
Have you seen it yet? Tonight, the green comet will be at its brightest.
The population of western monarch butterflies wintering along the California coast has rebounded for a second year in a row after a precipitous drop in 2020, but the population of orange-and-black insects is still well below what it used to be, researchers announced Tuesday. Volunteers who visited sites in California and Arizona around Thanksgiving tallied more than 330,000 butterflies, the highest number of these insects counted in the last six years. It was a promising rebound after the annual winter count in 2020 recorded fewer than 2,000 butterflies.
Alaska Oil Project's Fate Unclear as Biden Cites Climate Peril
(Bloomberg) -- The Biden administration telegraphed it could support a scaled-back drilling plan at ConocoPhillips's proposed Willow project in northwest Alaska, even as it cited "substantial concerns" with the oil development and warned of further restrictions to limit its impact on wildlife and the climate.Most Read from Bloomberg8,000 Layoffs Don't Exactly Scream Family ValuesNational Archives Releases Records Tied to Trump Classified DocumentsIntel Slashing CEO, Managers' Pay in a Bid to Pre


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Gardner pays price for slamming helmet
By Anthony Castrovince @castrovince
CLEVELAND -- Brett Gardner was glad there were no cameras in the clubhouse on Saturday to capture the ugly state of his bottom lip, which had just received six stitches to close a wound. Unfortunately for Gardner, a camera did capture the mishap that caused the split lip -- a
CLEVELAND -- Brett Gardner was glad there were no cameras in the clubhouse on Saturday to capture the ugly state of his bottom lip, which had just received six stitches to close a wound.
Unfortunately for Gardner, a camera did capture the mishap that caused the split lip -- a batting helmet comebacker that struck Gardner square in the mouth after he had frustratedly thrown it at a dugout wall. By the time the Yankees' 8-4 loss to the Indians at Progressive Field was complete, that video was all over social media.
It's all fun and games until the helmet bounces back and hits you in the face. pic.twitter.com/gy6Lpgrhlf
— FOX Sports: MLB (@MLBONFOX) June 8, 2019
"I just got done telling DJ [LeMahieu] last week that he shouldn't throw his helmet in the dugout," Gardner said. "Obviously, I was frustrated, came in and threw my helmet, and it came back and hit me in the face."
The moment occurred in the sixth inning, after Indians right fielder Jordan Luplow made a terrific five-star catch of Gardner's long fly ball in front of the wall in right-center field. For Gardner, who is now 1-for-his-last-23, getting robbed on that play, which Statcast gave just a 20 percent catch probability, was another frustrating moment in a week full of them.
And then injury was added to insult.
"It is frustration building up," Gardner said. "We gave up the lead there and then I hit a ball like that and it's an out. I told [manager Aaron] Boone if I hadn't done it then, I would have done it after my next at-bat."
Gardner was referring to his eighth-inning groundout, when he hit a ball with a 96.3 mph exit velocity that went right to the second baseman, Jason Kipnis.
"He's just got to keep plugging away with it and making sure when you do get a pitch, a good fastball to hit, you take advantage of those situations," Boone said. "It was good to see him get some good swings off."
Alas, Gardner's helmet toss was an all-too-perfect strike down the middle. Gardner said he's guilty of injuring himself in such a way before, having once bopped himself in the head with a tossed helmet that bounded back and gave him a goose egg. But getting struck in the lip Saturday, he said, didn't hurt that much.
"Not as bad as getting the stitches put in," he said.
Anthony Castrovince has been a reporter for MLB.com since 2004. Read his columns and follow him on Twitter at @Castrovince.


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Home»Category: "Tech" (Page 3)
Browsing: Tech
Intel prepares for war with Apple and ARM
By News March 28, 2021 0
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Unknown number? Google will now tell you which company is calling you and why
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A slow mobile phone can be uncomfortable and irritating, causing actions such as sending a WhatsApp message to take up…


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Goldman Sachs signals partial withdrawal from consumer banking
Goldman Sachs no longer wants to be the bank for everyone.
The famed investment bank spent eight years trying to expand its business beyond corporations and the wealthy. But in recent months, Goldman has signaled a partial withdrawal from those efforts by scrapping plans for a widely available checking account and suspending its personal loan business. A popular savings account and credit card business survive for now.
Last week, the bank revealed that it had racked up $3 billion in losses on its consumer banking franchise since 2020, mostly money set aside to cover potential credit losses in its consumer lending businesses. Banking regulators are reportedly looking into whether the consumer business had adequate safeguards as it grew.
The pullback in consumer banking comes as Goldman tries to refocus on its roots: advising corporations on deals, investments and operations, and serving the wealthy. The company's revenue from investment banking, trading and wealth management accounted for two-thirds of total revenue last year.
"I think it became clear to us in early 2022 that we were doing too much, that it was affecting our execution," David Solomon, Goldman's chairman and chief executive officer, said on a call with analysts when the bank reported its results earlier this month.
Goldman's foray into consumer banking was one of the biggest changes in the company's 154-year history. The investment bank had to legally become a bank holding company in 2008 during the financial crisis to gain access to the Federal Reserve's emergency funding operations. That sparked jokes within the industry that Wall Street titan Goldman Sachs was going to issue something as commonplace as an ATM card.
The jokes came true when Goldman bought the assets of GE Capital and launched its only online savings account that offers above-market interest rates. The savings account became an unexpected success for Goldman, with waiting lists forming after its initial launch both in the US and later in the UK.
The online savings account is not going away and the company views it as an asset, Solomon told investors. The firm now has more than $100 billion in retail deposits, which is a cheap form of capital for the investment bank that historically hasn't had access to such forms of financing.
The personal loan business, launched to much fanfare in 2016 with an extensive advertising campaign under the Marcus brand, has been a source of trouble for the bank. Goldman Sachs executives acknowledged at the time of the launch that the Marcus brand was created to give Goldman, with its guise of being a power broker between Washington and Wall Street, a much friendlier and more accessible edge.
Unsecured personal loans, used largely by customers to consolidate credit card debt, became a burden during the coronavirus pandemic when millions of Americans could no longer pay their bills. The bank set aside billions of dollars to cover potentially bad loans, and unlike other big banks that were able to release those reserves in 2021 and 2022, Goldman largely had to keep adding to its reserves. New accounting standards that have required banks to model potential credit losses more aggressively also contributed to the decision to wind down the personal loan business.
The large losses have drawn the attention of banking regulators, which have also been investigating Goldman's personal lending operations. The Wall Street Journal reported Friday that the Fed is looking into whether the company had adequate safeguards around its personal loan business as it increased lending.
"The Federal Reserve is our primary federal banking regulator and we do not comment on the accuracy or inaccuracy of matters related to discussions with them," a Goldman Sachs spokesperson said.
Investors have long questioned the need for Goldman to venture into consumer lending. The bank kept the consumer banking operation under the umbrella of its wealth management arm in its quarterly results, drawing criticism that Goldman was hiding Marcus's losses from investors.
"We have never understood (Goldman's) desire to expand so far into the consumer given the strength of its 150-year legacy franchise in the capital markets," wrote Mike Mayo, longtime banking industry analyst at Wells Fargo Securities. , in a note to investors.
One area Goldman isn't backing down from is its relatively new credit card business, which the firm calls platform solutions. The firm is the subscriber to Apple Card, the popular credit card deeply integrated into Apple Pay that launched in 2019, as well as a co-branded credit card with General Motors. Goldman and Apple announced in October that they were extending their relationship through the end of the decade. The platform's solutions also include GreenSky, a fintech lender focused on home improvement loans, which the bank bought in 2021.
While the Apple Card and GM Card were great achievements for Goldman, the new business hasn't been without its headaches for the company.
The bank disclosed in August that the Consumer Financial Protection Bureau, the nation's financial watchdog, was investigating its management of credit card accounts, including issues with billing, credit reporting, dispute resolution, and other routine credit card problems.
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Culture/Society / Politics
OPINION: Blatant Propaganda on 'Doc McStuffins'
by Matt Norcross · October 8, 2015
The Disney Channel/Disney Junior program Doc McStuffins has received praise from several critics for its portrayal of its protagonist, an African-American preschool girl pretending to be a doctor. The creator even called it "Cheers for Preschoolers". On October 5, parents and young children were asked to tune in that morning at 9 A.M. for a "special episode". First lady Michelle Obama would talk about her healthy living initiative, perfectly following the agenda of current Disney Junior president Nancy Kanter, a committed leftist – and a former Sesame Workshop employee.
I didn't see the episode, as I am way too old to be watching a program like this given the target audience is preschoolers, but I know propaganda when I see it. When I shared it on my personal Facebook page, a friend of mine commented on it and said for me not to reserve judgement until it actually airs. My father replied to him with this sentence, "$100 says it will be about her BS dietary program, ACA, the environment, or some other progressive mantra." Little did I know my dad's predictions would come true. The show does indeed talk about her dietary program. Again, Disney Junior president Nancy Kanter is a despicable human being for forcing these dumb policies on her network's young preschool audience. As I've said many times, enough is enough with the whoever is working at these networks forcing propaganda on everybody. This is no accident though, since Disney Junior is run by the American Broadcasting Company (which Disney has owned since 1996).
As many of you know, ABC and most of its sister networks are on the verge of collapse. If its new fall lineup and its respective Halloween and Christmas blocks (with the Peanuts and Toy Story specials leading the ratings of those lineups) fail later this year, the entire Disney/ABC Television Group will be doomed for yet another year. ABC president Ben Sherwood, a member of the George Soros-funded Center for Public Integrity, has ruined this once-great network. And now, they're beginning to look desperate. Not only is the ABC network in last place, some of their cable operations are a disaster. ESPN is down 9% in primetime and 5% in the whole 24-hour period. ABC Family has also seen a drastic ratings decline, and is now changing its name to Freeform as a result. Incredibly, the network that will soon be known as Freeform continues to prove how out of touch they are with traditional Americans by refusing to stop production of gratuitous sex-filled garbage like Stitchers, Young & Hungry, and The Fosters. Here's one of the consequences, the Hallmark Channel program Cedar Cove became the #1 program on Saturday nights, and it actually beat ABC Family's The Fosters by a million more viewers. How embarrassing is that? On an episode of latter program, storylines became more far left as they focused more on "racist cops", and that "bigoted" Catholic Church. That tells you everything you need to know about the ABC group of networks. Disgraceful doesn't even begin to cover it.
Tags: ABCDisneyMichelle Obama
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