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Energy Post
Daily reports on the European and Global energy transition
Oil, Gas & Coal
Save the EU Emissions Trading Scheme: set a price band
October 21, 2014 by Brigitte Knopf and Ottmar Edenhofer
The Market Stability Reserve proposed by the European Commission will not be sufficient to reform the EU Emission Trading Scheme (ETS). If the ETS is to be saved, EU policymakers must instead take the bold step of establishing a price band for CO2 emission rights, argue Brigitte Knopf of the Potsdam-Institute for Climate Impact Research (PIK) and Ottmar Edenhofer of PIK and the Mercator Research Institute on Global Commons and Climate Change (MCC). They warn that a failure to make the ETS work could wreck the entire EU climate and energy policy.
One of the pillars of European climate policy, the European Emissions Trading System (EU ETS), is currently questioned in its ability to deliver its objectives as the allowance price is persistently low at around 5€/tCO2. In January 2014, the EU Commission put forward a legislative proposal to tackle the problem of the low price. Its proposed Market Stability Reserve (MSR) is designed to adjust the short-term auction supply without affecting the long-term cap by establishing a reserve of non-auctioned allowances. The MSR is based on pre-defined rules on (i) when to feed allowances into the reserve and when to release them (triggers), and (ii) how many allowances to reserve and how many to release. The reserve can be carried over multiple periods, ensuring that the MSR is neutral to the overall cap. The starting year proposed is 2021, but some Member States, e.g. Germany, call for an earlier start in 2017.
The European Council will be discussing the MSR proposal at its meeting on 23 October, in addition to the question of the EU's overall CO2-emission reduction target for 2030. It is expected that the Heads of State will give a positive vote on the MSR proposal. It will then be discussed in the European Parliament.
What is the problem of the EU ETS?
But does the MSR address the current problem of the EU ETS? What is actually the problem and are there alternative solutions?
These questions are addressed in a new policy position paper from the Energy Platform of Euro-CASE (the European Council of Academies of Applied Sciences), which we summarize here.
There is an important point that is often overlooked when the EU ETS is compared to other markets, e.g. the oil market. The difference is that the EU ETS is a market where scarcity is governed by political decisions and not by natural scarcity. Thus expectations of market participants about future political decisions are critical.
Between 2009 and 2013, actual emissions stayed below the annual cap. This means that temporarily the annual cap did not provide incentives for action (see Figure 1). However, the cumulative cap until 2020 is still binding and some scarcity is expected as reflected by the positive allowance price. In this situation – where annual caps are not the constraining factor for emissions – it is uncertain how traders in the market form their expectations. If they expect that the oversupply will be absorbed within the current commitment period (for whatever reasons), then presumably the price will increase. If they expect that the oversupply will be sustained, then the price will likely decline. Additionally, when they do not expect an ambitious cap after 2020, the price might even further decline.
Figure 1: Historical developments of EU ETS annual cap (Cap), annual verified emissions from sources covered by the EU ETS (Emissions), annual offsets surrendered for compliance (Offsets) and average December future prices (CO2 price). Source: adapted from Grosjean et al. (2014).
Indeed, empirical analysis shows that in the current regime demand-side fundamentals (e.g. the economic crisis, renewables, Kyoto credits etc.) only accounted for 10% of the price variation and can thus only very partially explain the weak carbon price signal. Other factors, in particular regulatory and political announcements, were found to be much more influential. They have played a key role in the price decline. As a consequence, any reform of the EU ETS has to deliver a mechanism that focuses on the expectations of market participants.
So what are the future expectations about the EUA price? The low price of futures contracts for the year 2020 (see Figure 2) indicates that traders anticipate only a modest long-term scarcity of emission permits in the market. Neither the Commission's decision for back-loading (removing allowances now to be re-injected later) nor its structural reform proposals seem to have significantly changed long-term expectations.
Figure 2: EUA price for nearest futures contract and for December 2020 futures contract traded on the ICE ECX platform for the time span 2011-2013. Source: ICE Futures Europe.
The problem with the low price
Now one might argue that in a cap-and-trade scheme there is no problem at all with a low price. But indeed, there is. The idea behind a cap and trade system as a system regulating the amount (and not the price) of emission allowances, is the ability to ensure attainment of its cumulative cap at least cost, by optimally incentivizing mitigation efforts, investments, and research and development (R&D) over time. A low price is – in conventional thinking – a sign of a well-functioning market. But in this case, it reflects the expectation of traders that the oversupply will be sustained even beyond the current commitment period. In other words, the EU ETS does not incentivize the search for low-cost mitigation options but reflects mainly the expectations of traders about future political decisions. It has been transformed into a betting shop for the commitment period after 2020.
Three interrelated considerations underpin the key concern of this lack of "dynamic efficiency":
First, modeling studies indicate that the current EU emission allowance (EUA) price of around 5€/tCO2 is too low to induce dynamically efficient mitigation, investment, and R&D decisions. Instead a minimum price of 20€ is required after 2021.
Second, there are significant uncertainties both on the allowance demand side (e.g. future GDP growth) and allowance supply side (e.g. future changes in the cap). This might not only contribute to the current low EUA price, but can distort private sector decisions over mitigation, investment, and R&D, which would be a reason for concern even at a higher price level.
Third, the prospect of low EUA prices might result in EU Member States resorting to national mitigation policies, thus creating an inefficient pattern of regulation across the EU as well as adding to the factors working towards reducing the EUA price.
Introducing a price collar as an alternative reform
The proposed MSR does not address the problem of long-term cost-effectiveness and price uncertainty. The MSR is a quantity-based instrument that addresses the existence of a large allowance surplus, but oversupply does not disappear until 2030, as the Commission shows in its own assessment. Overall, the impact of the MSR on the price is difficult to assess because the rationale behind the mechanism is not transparent and rests on assumptions that are incompatible with inter-temporal price smoothing. If hedging is the rationale behind the MSR, the trigger should change over time.
Also the effect it has might be too slow and the review phase considered for 2026 gives additional uncertainty. For all these reasons, the MSR will have an uncertain impact on investment in R&D as well as on low-carbon investments. The fact that many business associations are mainly indifferent to the MSR is also a sign that market participants do not expect that it will lead to higher prices. Consequently, the MSR is very likely not the best mechanism to cure the current problem of insufficient dynamic efficiency.
But there are alternatives for a reform. The dominant problem is the low credibility of the long-term scarcity, which is reflected in the weak price signal. Given the difficulties of establishing long-term political credibility, the best approach is to directly manage expectations of market participants. Therefore, a better alternative would be to add price-triggers that establish the boundaries of political intervention. This kind of hybrid scheme would allow combining the best of the two different systems: cap-and-trade and taxation. This can be done by introducing a price band or collar to the ETS in form of a lower and upper boundary on the price, both of which increase over time. This would directly address the concern over dynamic efficiency of the EU ETS.Such hybrid instruments that combine a cap-and-trade system with price-based triggers have already been implemented successfully in California and the US RGGI region.
A price collar can immediately deliver a stable and sufficiently high allowance price. In addition, it is a useful way to manage expectations of future prices in line with the long-term cap of the EU ETS. While the floor price is justified in terms of cost-effectiveness, the argument for a price ceiling is different. It is needed because prices can also increase substantially through shocks. When a ceiling is set, this risk is reduced symmetrically, which is important for investors, as for them both directions of the risk (prices that are substantially higher or lower) are important. In addition, a price ceiling prevents costs becoming politically infeasible. A credible price collar would, therefore, directly incentivize investments in innovations that are required for cost-effective long-term decarbonization.
Moreover, while the ETS is working as a kind of lawn-mower over national preferences, a price collar would allow Member States to partially follow their own climate policies, e.g. adopting more ambitious reduction goals, or their own renewable support schemes or efficiency standards, without fear of undermining the ETS – given that the EU ETS is operating at the price floor. In general, this is the advantage of tax systems compared to cap-and-trade systems in multi-level governance settings such as in the EU.
The political feasibility of introducing a price collar
In the end, instead of a narrow reform of the EU ETS, a full-fledged reform addressing several aspects of carbon pricing is required. Besides (i) setting a price collar within the EU ETS, this includes (ii) reducing emissions in the other sectors (for example transport and heat) by also pricing carbon emissions in these sectors or by a sectoral expansion of the EU ETS, (iii) addressing additional market failures through other policy instruments beyond the reach of carbon pricing, and (iv) addressing the possible problem of carbon leakage by expanding the group of countries that participate in the EU ETS or by linking it to policies in other regions, see the example of California and Quebec.
Within this package, the price collar ensures the dynamic efficiency of the emissions trading scheme: it makes clear to the market agents when the regulator will intervene. This would be in sharp contrast to the proposed MSR system in which expectations can be easily destabilized because the regulator does not announce in advance at which price it intends to intervene. Instead, a price collar will make the EU ETS effective.
There might be some opponents who will say the EU ETS will become a tax system. However, it should be clear that this is a political framing which intends to avoid any reasonable reform debate. The political feasibility of implementing a price collar and the wider reform package might be limited.But without such a comprehensive reform of the EU ETS, the idea of a joint EU climate policy might come to an end.
The implications of this are dire. There is not only the danger that the EU ETS might not survive as a functioning instrument of European climate policy, but also that the whole EU climate policy will fail and will return to fragmented climate and energy policies across the region, such as with the carbon floor price in the UK. This could substantially increase the costs of climate policy and the EU would lose its last credibility as an international leader in climate and energy policy. By contrast, a successful reform and a well-functioning ETS would restore the credibility of the EU's climate and energy policy domestically and internationally.
This article is based on a policy paper published by the Euro-CASE Energy Platform in September 2014. Euro-CASE is the European Council of Academies of Applied Sciences, Technologies and Engineering.
Brigitte Knopf is head of the research group 'Energy Strategies Europe and Germany' and deputy head of the Research Domain 'Sustainable Solutions' at the Potsdam Institute for Climate Impact Research (PIK) and has coordinated the Euro-CASE assessment of the EU ETS. She is on Twitter as @BrigitteKnopf
Ottmar Edenhofer, Head of Research Domain 'Sustainable Solutions' and Chief Economist at the Potsdam Institute for Climate Impact Research (PIK), Director of the Mercator Research Institute on Global Commons and Climate Change (MCC) and Chair Economics of Climate Change at Technical University Berlin. He is Chair of the Euro-CASE Energy Platform.
Filed Under: *, Energy, EU Policy Tagged With: electricity market, energy transition, EU energy policy, EU ETS, financing
About Brigitte Knopf
About Ottmar Edenhofer
James Rust says
The EU is chasing a "fool's errand" if they pursue policies to mitigate climate change due to carbon dioxide emissions.
The Obama Administration's Climate Action Policy is based on increased carbon dioxide from burning fossil fuels is causing catastrophic global warming. The seminar that follows shows there is no scientific basis for this belief.
This link is to an October 15, 2014 seminar "The Myth of Carbon Pollution" by retired Princeton Physics Professor William Happer.
http://marshall.org/events/the-myth-of-carbon-pollution/ The seminar is sponsored by the George C. Marshall Institute.
Prof. Happer shows increased carbon dioxide in the atmosphere from burning fossil fuels produces far more benefits than commonly thought and any slight increase in global temperatures are beneficial with increased growing seasons.
The power-point presentation and questions lasts a little over one hour. The time is well spent.
James H. Rust, Professor of nuclear engineering
Emil Dimantchev says
Hi Brigitte,
I find your article quite interesting, as is the whole discussion around the MSR. A price floor has many advantages over a quantity-based instrument, certainly, but there are several problems with your analysis of the MSR. Here are my comments:
You analyze the impact of the MSR by looking at the price for the 2020 allowances contract, and so you are implicitly assuming that the market is rational enough and forward-looking enough to price in the full impact of the MSR on the market in its future contracts. This may be consistent with theoretical economic models, but is inconsistent with real-world market behavior. As in other markets, the forward curve is generally a poor representation of the future – it only represents how market participants view the future today, a view that is heavily based on short-term dynamics. In this respect, the price for a 2020 EUA contract is likely not much more than a reflection of current market dynamics covering the current year and a few years ahead (say up to 2017), adjusted for the cost of carry. As the MSR has been proposed to begin as late as 2021, the short-term horizon of market participants prevents it from being priced in the market.
The Euro-Case Policy position paper which you have cited also analyzes the MSR from a theoretical perspective, as the authors make explicitly clear. The main point of the paper is that a temporary reduction of market supply will not impact the price as the market is assumed in theory to exhibit rational behavior and inter-temporal pricing, assumptions which most likely do not hold. Observed historical market behavior suggests that there is very likely to be a market failure with regards to short-term behavior (so much is often admitted by market participants) and therefore a lack of inter-temporal price smoothing. In the existence of such market failures, the MSR has the potential to support the EUA price, as admitted by the paper. I do agree with the authors that more investigation into the extent of this market failure will be helpful.
All in all, the MSR seems more likely than not to impact and support the carbon price even if the extent to which it does so is not fully certain. Certainty and predictability are indeed the true advantages of a price-based instrument.
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Welsh hospices to receive extra £2.2m funding increase following end-of-life care review
By Iain MacDonald, Reporter 26th January 2022 News WalesBusiness / Funding / Finance, End Of Life Care, Government / Politics, Hospices, News Wales, Palliative Care, Residential Care
Hospices in Wales will receive an extra £2.2m as part of the Welsh Government's end-of-life care review.
Of the funding, £888k will go to the two children's hospices – Ty Hafan and Ty Gobaith – and the remainder will be shared by the adult hospice services across Wales.
This funding is on top of the £13.8m already allocated by the Welsh Government to support the sector and strengthen bereavement support throughout the pandemic.
The announcement is part of phase one of the end-of-life care review. The second phase will look at wider end-of-life care provision from April 2022, overseen by the new programme board for end-of-life care.
Minister for Health and Social Services Eluned Morgan (pictured) said: "Hospices are a critical part of our healthcare service in Wales, providing essential care to more than 20,000 people in Wales affected by terminal illnesses each year, helping to prevent avoidable admissions to hospital. More than 85% of that care is provided in the community.
"This has never been more needed than over the last two years when, throughout the pandemic, hospices have been there to support patients, families and carers through the most difficult of times in the most difficult of circumstances.
"We are committed to strengthening our focus on end-of-life care and we will continue to work closely with the new national programme board to drive actions across government and with stakeholders to improve end-of-life care services for all.
Chief Executive of Tŷ Hafan children's hospice Maria Timon Samra said: "Together with Tŷ Gobaith we have been campaigning for a sustainable funding solution for Wales' children's hospices. We are delighted by the Welsh Government's commitment to act on the recommendations of the hospice funding review, an important first step in achieving this goal.
Andy Goldsmith, Chief Executive of Tŷ Gobaith Children's Hospice, said: "This increased funding is a major first step forward in ensuring the 'Lifeline' that children's hospices provide is available for every child and family that needs us.
"We look forward to continuing to work with the Welsh Government to fund and develop services to meet the growing and changing need for the specialist care and bereavement support that both Tŷ Gobaith and Tŷ Hafan provide in Wales."
Before the pandemic started, approximately two-thirds of hospices' income came from fundraising activities.
The Welsh Government's emergency funding of £13.8m was used to support hospices as they lost income from charitable activities; protect their core services and to strengthen bereavement support.
The end-of-life care review was led by a NHS Collaborative team which analysed information submitted by hospices and held regular meetings to keep them informed of progress.
The additional £2.2m funding provides hospices across Wales with a significant increase to their core funding allocations and offers a level of certainty on which they can plan and deliver future service provision.
Picture (c) Youtube.
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Das Clarke County ist ein County im US-amerikanischen Bundesstaat Iowa. Im Jahr 2010 hatte das County 9286 Einwohner und eine Bevölkerungsdichte von 8,3 Einwohnern pro Quadratkilometer. Bis 2013 erhöhte sich die Einwohnerzahl auf 9325. Der Verwaltungssitz (County Seat) ist Osceola.

Geografie
Das County liegt im Süden von Iowa, ist im Süden etwa 40 km von Missouri entfernt und hat eine Fläche von 1118 Quadratkilometern, wovon zwei Quadratkilometer Wasserfläche sind.

An das Clarke County grenzen folgende Nachbarcountys:

Geschichte

Das Clarke County wurde am 13. Januar 1846 als Originalcounty aus als frei bezeichneten – in Wirklichkeit aber von Indianern besiedelten – Territorium gebildet. Benannt wurde das County nach James Clarke (1812–1850), dem letzten Gouverneur des Iowa-Territoriums (1845–1846).

Die ersten weißen Siedler in dieser Gegend waren 1846 die Mormonen, die, auf ihrem Weg nach Salt Lake City in Utah, etwa 10 km von Osceola entfernt, den Winter verbrachten. Die ersten permanenten Siedler waren wohl Robert Jamison und John Kyte. Ab 1851 begann dann die Besiedlung im größeren Stil. Der erste Jurist war P.J. Goss, der sich für 30 Jahre hier niederließ, bevor er nach Kansas zog.

Das erste Gerichtsgebäude wurde 1854 fertiggestellt und diente als solches bis 1883, als es von einem Unwetter zerstört wurde. Das nächste Gerichtsgebäude, dieses Mal erbaut aus Steinen, wurde 1892 fertiggestellt. Das dritte und noch heute benutzte Gerichtsgebäude wurde 1956 in Betrieb genommen. Die Hawkeye-Mühle nördlich von Osceola war die erste Mühle im County. Die nächste Mühle war dampfgetrieben und eine Kombination von Getreidemühle und Sägewerk.

Die erste Verbesserung der Transportsituation trat 1868 ein, als die Chicago, Burlington & Quincy Railroad ihre Gleise durch das County verlegte. 1881 kam noch die Nord-Süd-Verbindung hinzu, die Iowas Hauptstadt Des Moines und Osceola mit Missouri verband.

1907 waren alle Straßen in Osceola mit Steinen gepflastert, 1910 wurde die erste öffentliche Bibliothek eröffnet und 1911 mit dem Bau des Bluegrass Trail begonnen, heute bekannt als der U.S. Highway 34.

Bevölkerung
Nach der Volkszählung im Jahr 2010 lebten im Clarke County 9286 Menschen in 3690 Haushalten. Die Bevölkerungsdichte betrug 8,3 Einwohner pro Quadratkilometer. In den 3690 Haushalten lebten statistisch je 2,43 Personen.

Ethnisch betrachtet setzte sich die Bevölkerung zusammen aus 94,3 Prozent Weißen, 0,4 Prozent Afroamerikanern, 0,3 Prozent amerikanischen Ureinwohnern, 0,4 Prozent Asiaten sowie aus anderen ethnischen Gruppen; 1,0 Prozent stammten von zwei oder mehr Ethnien ab. Unabhängig von der ethnischen Zugehörigkeit waren 10,0 Prozent der Bevölkerung spanischer oder lateinamerikanischer Abstammung.

25,3 Prozent der Bevölkerung waren unter 18 Jahre alt, 60,0 Prozent waren zwischen 18 und 64 und 16,7 Prozent waren 65 Jahre oder älter. 50,2 Prozent der Bevölkerung war weiblich.

Das jährliche Durchschnittseinkommen eines Haushalts lag bei 42.384 USD. Das Prokopfeinkommen betrug 22.168 USD. 12,0 Prozent der Einwohner lebten unterhalb der Armutsgrenze.

Ortschaften im Clarke County
Citys
 Murray
 Osceola
 Weldon1
 Woodburn

Unincorporated Communities
 Hopeville
 Lacelle

1 – teilweise im Decatur County

Gliederung
Das Clarke County ist in 12 Townships eingeteilt:

Die Stadt Osceola gehört keiner Township an.

Siehe auch
 Liste der Einträge im National Register of Historic Places im Clarke County (Iowa)

Einzelnachweise

Weblinks

 Offizielle Website
 Clarke County Development Corporation
 city-data.com - Clarke County, Iowa

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Mindfulness is a state of living in the moment, where you think about and appreciate and absorb what is happening right now, without worrying about the past or future. It is not helpful for your mental health and wellbeing, but for your hunger and appetite as well. Here are some ways to use mindfulness to help with your appetite.
The first benefit for your hunger and appetite is changing your eating habits. In mindfulness, you learn to live only in the moment. What does this mean for eating? When you eat, you get rid of all outside distractions so that you are only thinking about what you are eating. This means turning off the TV, not using your cell phone, and not listening to music.
You want to be in a quiet, peaceful environment where you really concentrate on what you are eating. Focus on the quality of the food, the smells, tastes, and textures. You learn to enjoy and appreciate food for what it is and how ti fuels your body, instead of just mindlessly eating without ever thinking about it. You are changing your eating habits by developing a mindful eating practice.
Another way mindfulness helps with hunger is by helping you to identify true hunger from other types of hunger. There are many types, including mouth hunger and mind hunger and emotion hunger. True hunger is when your stomach sends you cues that it is time to eat. If you are on a normal eating schedule, you should start getting these hunger pangs around the same time each day. However, if you tend to eat and snack haphazardly, then you might feel constantly hungry because your body doesn't have a good eating routine or signs that you need to eat.
Not only will mindfulness help when it comes to eating and your appetite, but it helps in other ways as well. You learn to appreciate each moment and focus only on how you feel right now. You don't stress yourself out about worries of the future or regrets of the past. Living in the moment is about acknowledging your life right now, and using that to better yourself physically, emotionally, and mentally.
There are so many benefits to mindfulness even beyond helping with your hunger and appetite. But once you have that under control, you can manage your weight and have a healthier lifestyle overall.
Are Nuts The Perfect Weight Loss Snack?
Can You Reverse Diabetes Through Diet?


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Securing Digital Infrastructures
Cybersecurity Priorities for Digital Leaders Navigating Digital Transformation
How to keep your organization safe from evolving cybersecurity threats
Michael Montoya
Published: June 21, 2022 5 min read
The pandemic has forced the economy into digital overdrive. Organizations had to rapidly adopt remote working and online channels in response to lockdowns and accelerate digital transformation agendas to survive. Unfortunately, the global threat landscape continues to escalate at an alarming rate, and rapid digitalization has left organizations vulnerable to cyberattacks.
In recent years, Asia-Pacific has especially been a hotspot for cyberattacks, and as we continue into 2022, it's evident that the problem is becoming more significant. Accelerated by external factors such as the pandemic, and now the Ukraine-Russian crisis, the risk of cyberattacks is on the rise and predicted to cost the world more than US$10.5 trillion annually by 2025.[1] These attacks provide a disturbing glimpse into how costly disruptions can be and potentially disastrous ripple effects on local and global economies.
With threat actors becoming more sophisticated, innovative, and collaborative, cybersecurity responsibilities today extend beyond security professionals—all digital leaders must make cybersecurity a top priority now.
Reimagine Your Leadership, Empower Your IT Infrastructure and Gain Digital Advantage
In this E-book from Equinix, learn how you can rearchitect your infrastructure to gain a competitive advantage. Learn about simple ways to bring together digital infrastructure that encompasses a choice of multiple providers, distributed geographies and hybrid multicloud architectures.
The cybersecurity landscape in Asia-Pacific
In 2021, Asia-Pacific was one of the most attacked regions by cybercriminals, accounting for one in four attacks globally. India, Japan, and Australia were found to be the top three countries suffering from these attacks, and server access and ransomware are among the most popular methods. [2] But countries vulnerable to attacks also include Indonesia, Vietnam, Malaysia, Singapore, and Thailand, demonstrating that no destination is safe.[3]
Last year, we also saw several high-profile breaches across organizations and a rise in attacks on critical infrastructure and supply chains, globally and in Asia-Pacific. Four critical infrastructure organizations in Southeast Asia were targeted, including a water company, power company, communications company, and even a defense organization.[4] One of the potential reasons we see such a high portion of attacks in the region is due to the lack of ability to identify attacks quickly before they escalate. Despite threat actors becoming more sophisticated, an industry report found that 54% of organizations in Asia-Pacific had not updated their cybersecurity strategies in the last 12 months.[5]
If organizations don't act now to update their security, it will only end up costing them. Data breach costs stood at USD 4.24 million in 2021, a 10% rise from 2019's[6] Moreover, innovations and automation across threat actors have helped them improve their ability to gain a foothold and move in operating environments from days to minutes. The months it takes to identify attacks are no longer acceptable, and classic approaches to security can no longer respond to such automation and innovation of cyberattacks. This makes a converged cybersecurity strategy a top priority for today's organizations to build digital advantage while driving greater visibility and control.
How can organizations begin to protect themselves?
Traditionally, network security techniques assumed one defensive layer for access to all services and content within. This method is no longer adequate as a network's perimeter grows more distributed and linked, so a more complex and multi-dimensional approach is required to augment or replace conventional firewalls with a larger zero-trust framework.
Applying a zero-trust security approach has been marketed as a fail-safe defense against unknown and developing threats. It has also become more crucial as the number of cyberattacks grows. Digital leaders can't rely on a single authorization event to authorize trust with more people accessing work remotely.
Instead, they need to establish digital trust based on the principles of least privilege access and continuous authentication. Furthermore, with the advancement of artificial intelligence (AI) and machine learning (ML) capabilities, network users are now "known" by much more than their credentials for access, even learning from user behavior to deny access to users who break from the norm.
Global security expectations and trends for the future
As threat actors are out-innovating and out-automating us, we need to be even more effective than ever to close the gaps in our cybersecurity. We've identified four key trends and agendas for digital leaders to consider:
Cyberattacks will keep growing—As companies continue to embrace cloud services and digital transformation, cyberattacks are inevitable. The question now turns from 'if' to 'when'. Digital leaders will play a more prominent and vital role in helping companies navigate threats and risks as they anticipate what's next.
Breaking silos—Many organizations still manage security in siloed functions, but the more groups we make, the more complex security becomes. You might think that this is an advantage, but threat actors thrive when security becomes complex as they can easily identify gaps in the system. Converging security for greater visibility and control will become a top priority.
Creating awareness and culture of security—Creating a culture of security will become a larger strategic initiative. Security will become everyone's job, and it is crucial to deploy zero-trust environments that integrate all departments for complete digital visibility and control. We also predict and encourage more investment and innovation for the cybersecurity industry to build frictionless solutions for users.
Increased transparency and disclosure—Again, as organizations embrace cloud and hybrid cloud strategies, they put more trust and stress on third parties. Supplier risk has been a long challenge in cybersecurity and will continue. We expect businesses and third parties to strengthen forces to design shared responsibility frameworks and implement solutions that deliver compliance, trust and transparency.
We also need to continue to expand engagement with law enforcement, critical infrastructure providers and the broader community to learn together and get ahead of cyberthreat trends.
Cybersecurity now
No organization, person or infrastructure is immune from cyberattacks. As companies rely more on digital services and infrastructure, the time to prioritize cybersecurity is now. As the world's digital infrastructure company™, Equinix has also gone the extra mile with zero-trust fabric to ensure the security of our services and structures for our customers. Designed with robust security factors, Platform Equinix™ embeds security in all stages of development to deliver protected interconnection to hybrid clouds. Furthermore, Equinix Fabric™ shortens the distance between computing and data, and gives operations full control of its data and security perimeters. The deployments are housed within physically secure facilities and monitored continually with strict access controls.
We are also collaborating with top security firms to provide state-of-the-art security systems and seamless user experiences, heavily investing in personnel, technology, and processes to prevent, detect, and respond to attacks.
It is time to place more mature cybersecurity in critical infrastructure, bring security teams closer together and expand awareness of security so threat actors are less successful in the future. Discover the benefits of bringing data and applications to the Digital Edge. Learn more about how Equinix can help organizations operate securely with data center solutions and managed services.
[1] https://cybersecurityventures.com/cybercrime-damage-costs-10-trillion-by-2025/
[2] https://www.ibm.com/downloads/cas/ADLMYLAZ
[3] https://techwireasia.com/2021/11/cybersecurity-are-challenging-asean-businesses/
[4] https://symantec.broadcom.com/hubfs/Attacks-Against-Critical_Infrastructrure.pdf
[5] https://assets.sophos.com/X24WTUEQ/at/2hnbbjt7k7q55zn7xpxg9gsn/sophos-future-of-cybersecurity-apj-wp.pdf
[6] https://www.ibm.com/security/data-breach
Data breach costs stood at USD 4.24 million in 2021, a 10% rise from 2019's
Michael Montoya Chief Information Security Officer
Safeguarding Your Industry 4.0 Journey with Equinix and Honeywell
Yee May Leong


Pinguem.ru and the PVS-Studio team recently held a contest where programmers were to use PVS-Studio static analyzer for one month to find and fix bugs in the source code of open-source projects. Their efforts have helped make a great many applications a tiny bit safer and more reliable. In this article, we will discuss a few of the most interesting bugs found with the help of PVS-Studio.
The contest was held for the Russian-speaking community from October 23 to November 27, 2017, and was split into two stages. At the first stage, the contestants were to submit as many pull requests to the project authors as possible. The second stage was a bit more challenging: they were asked to find a bug and describe the sequence of steps to reproduce it. Nikolay Shalakin was the one who scored the most points and won the contest. Congratulations, Nikolay!
During the contest, the participants submitted a lot of really useful pull requests, all of which are listed here. As for this article, we invite you to take a look at the most interesting bugs found by the contestants at the second stage.
"len", "abs", "None", "True", "False"
The bug-fix pull request can be found here.
The PVS-Studio team is very grateful to all the participants. You did a tremendous job eliminating bugs in open-source projects, making them better, safer, and more reliable. Perhaps someday we'll have a similar contest for the English-speaking community as well.
All the rest are welcome to download and try PVS-Studio analyzer. It is very easy to use and could help you a lot.


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Worlock - Skinny Puppy - Rabies (Cassette, Album)
22.02.2020 Zololkree 9 Comments
Label: Capitol Records - C4 93007 • Format: Cassette Album • Country: US • Genre: Electronic • Style: Industrial
Hush - Gerry Hoelke Group - Goin Down Home (Vinyl, LP), Smoke Gets In Your Eyes - The Sorrows - Take A Heart (CD), Rosie Gaines - Closer Than Close (Vinyl), Heated Content - Snipah* - Verbal Ammunition (CDr, Album), I Will Not Stop Fighting - Leo Sayer - Leo Sayer (Cassette), Niggaz Cant Hold Me Down - H.O.H. - Livin In A Casket (Cassette, Album), Florida Pines - girlsareshort* - Early North American (CD, Album), Pistols At Dawn - Circuits (2) - Pistols At Dawn (CDr), Dont Hide The Tears - Monday - Monday (CD, Album), Tyrone Shapiro (The Bronx Caballero) - Willie Howard - A Gala Record Revue Starring Willie Howard In, We Are All The Winners - Various - 18 Schlagerklassiker (CD), Jai Toujours Besoin De Toi - Maria Miel - Jai Toujours Besoin De Toi (Vinyl), Cartouche (4) - A Venir (Vinyl, LP, Album)
9 Comments on " Worlock - Skinny Puppy - Rabies (Cassette, Album) "
Vudogar 25.02.2020 at 08:54
Rabies is the fifth studio album by Skinny Puppy. It was released on November 21, through Nettwerk. The album notably features Ministry frontman Al Jourgensen (credited as Alien Jourgensen) who performed electric guitar and vocals on several cahuramelocu.sisvitalicurmalarlomicrerinreds.co: Electro-industrial, industrial metal.
Dousho 03.03.2020 at 07:21
Worlock Skinny Puppy. Produced by Dave Ogilvie & CEvin Key. Album Rabies. Worlock Lyrics. Binge cringe on the fringe Sloppy mincing eye dropping Biopsy cyclops overlooks Optic options.
Taulmaran 26.02.2020 at 09:57
This album was my introduction to Skinny Puppy; i met a girl at church camp as a 7th grader, and she endorsed Rabies wholeheartedly. Later on, a year or so after i had found Bites on cassette and listened to it while reading , other Puppy albums would eclipse Rabies as the soundtrack for sea-change in my life, but Rabies remains a classic industrial album containing seminal tracks such as /5(89).
Gardak 03.03.2020 at 15:47
Jul 18, · Considering the bulk of Skinny Puppy's catalog, this album is definitally, at least in my opinion, a very confused album and for that reason falls into the weaker side of the SP spectrum. The standout tracks for me are RODENT, WORLOCK, RIVERS and CHORALONE. I used to like WORLOCK more than RODENT but recently i may have changed my mind.
Vudozragore 02.03.2020 at 20:00
View credits, reviews, tracks and shop for the Advance, Dolby HX Pro, B NR Cassette release of Rabies on Discogs.3/5(2).
Moogushakar 28.02.2020 at 01:11
Rabies is a solid, sordid album from Skinny Puppy, even if it isn't always the sound of the band operating at their peak. All of the trademark Skinny Puppy elements are in place: Nivek Ogre's snarling vocals, snippets of dialogue from sci-fi and horror movies, and .
Gojora 24.02.2020 at 08:50
Worlock is a single by the band Skinny Puppy from the album Rabies. The song uses a sample of the guitars in " Helter Skelter " by The Beatles, as well as a vocal sample of Charles Manson singing the song. Vocalist Nivek Ogre considered it one of the band's better songs.
Akinodal 27.02.2020 at 00:20
Drawing from the pioneering work of artists like Throbbing Gristle, Cabaret Voltaire, and Suicide, the dark avant-industrial group Skinny Puppy formed in in Vancouver, British Columbia. Originally a duo comprised of former Images in Vogue drummer cEvin Key (born Kevin Crompton) and Nivek Ogre (aka Kevin Ogilvie), Skinny Puppy followed their debut cassette, Back and Forth, with the EP.
Visho 25.02.2020 at 06:10
Released in , Rabies is the fifth album by Skinny Puppy. The album is notable for the involvement of Al Jourgensen of Ministry fame and it's "new sound" aspect: introducing guitars and a harder.
Chicago Send Her Home - Thelma Houston & Jerry Butler - Thelma & Jerry / Two To One (CD)
Give Your Love To Me - Bill Summers & Summers Heat - Jam The Box (Vinyl, LP, Album)
Rush - Useless D.I. - Rush / Stun (File, MP3)
A New England
Lets Get Personal - James Brown - Gravity (Vinyl, LP, Album)
Bagami on Worlock - Skinny Puppy - Rabies (Cassette, Album)


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Wartime Wednesday: Conscientious Objectors
As long as there have been wars, there have been people who objected to them. Some for religious beliefs, others on moral grounds. These folks eventually became known as Conscientious Objectors (COs). Until World War II, the government dealings with COs were ambiguous and inconsistent, but typically harsh.
According to www.livinghistoryfarm.org, the World War I draft law recognized the peace churches {those churches such as Quaker, Brethren, and Mennonite, that historically took a stand against war}, but prosecuted anyone else who objected on the basis of their own beliefs. Five hundred objectors were court-martialed – seventeen received death sentences for refusing to fight. Although none of death sentences was carried out, almost 150 objectors were jailed for life, and others were harassed and beaten.
As the U.S. moved closer to entering World War II, Congress, for the first time in history, recognized "CO Status" as a legitimate moral stand. Under the Selective Training and Service Act of 1940, objectors had two choices — they could go into the military but serve in the medical corps or other non-combat duties, or they were required to do "alternative service" here at home that was "work of national importance."
Of the 34.5 million men who registered for the draft, 72,354 applied for conscientious objector status, 25,000 of whom served in non-combatant roles and 27,000 who were exempted because of their failure to pass the physical exam. There were over 6,000 men who rejected the draft outright and chose to go to jail instead of serving the war effort. And then there were 12,000 men who chose to perform alternative service. Their work was supervised by the Civilian Public Service (CPS) program.
The CPS program called for work camps to be established for assignees to labor in soil conservation or forestry projects. Initially, men dug irrigation ditches, planted ground cover, and built dams and irrigation system. Others served as fire lookouts and smoke jumpers. As the war progressed the program's opportunities expanded to include dairy and farm labor and mental hospital attendants. Others volunteered to be test subjects in scientific experiments administered by the federal government. Known as "Guinea Pig Units" these programs studied the effects of starvation, climate, hydration, disease, and other issues.
One of the most controversial aspects of CPS was that the assignees served without pay. This was a decision undertaken early in the negotiations for CPS by the Selective Service as they feared the program would not be approved if men received a wage. This proved to be an increasing source of frustration for many of the men and their families as the men received no allotment for dependent care either, leaving many of their families in a difficult economic situation.
Many COs struggled with their decision:
"Alone, I did not know any other conscientious objectors in my community. I don't think there were any others. I was a naïve young man, and I thought to myself, 'What if I'm wrong and all these millions of other men are right? What if I'm wrong about conscientious objection?' So in that respect I compromised and agreed to be drafted into the military, as long as I wasn't required to bear arms." (K. Roy Bailey, Schuyler Rural school teacher who later served as a U.S. Army medic in the Pacific theater.)
"At that time, I registered as a conscientious objector...well, my background was Mennonite. We were in a Mennonite community, and it's one of the 'peace churches.' It was our way of saying we don't agree with violence. We would rather got to work for several years doing alternate service. Well, there was some problem with it. And there would be again today. Probably not as much as there was at that time. But it was considered as being non-patriotic. That was not the case, but it was perceived as such. We were very patriotic people." (Anonymous Mennonite).
Labels: Conscientious Objectors, COs, Peace Churches, Selective Training and Service Act of 1940, Wartime Wednesday, WWII
Forensic Friday: Human Memory and Eyewitness Testi...
Mystery Monday: In Harm's Way
Selah Saturday: Beating the Winter Blues
Talkshow Thursday: Heavy Water
Traveling Tuesday: Walter Reed Army Medical Center
Forensic Friday: The Lost are Found
Wartime Wednesday: Lentil Curry
Mystery Monday: The Mystery of Codebreaking
Selah Saturday: Finding God in the Outdoors
Talkshow Thursday: Operation Pastorius
Traveling Tuesday: The Bombing of Fort Stevens
Forensic Friday: Pattern Evidence


I've fed all three of my children baby formula. So far, I've been fortunate to never find the baby formula that I use to nourish my babies on a recall list or pulled from grocery store shelves. Last night, I read an eye opening article. It surprised me and made me more than a little sad about how far some people would go to make a buck.
Earth's Best Organic Soy baby formula has been pulled from the shelves of QFC and Fred Meyers stores in the Seattle area after a parent in Kirkland, Washington found that a label had been peeling away to show a label of a cheaper brand of formula beneath. My first thought was "Oh, factory mistake.". I'm apparently a little naive, though, as Kroger (the owner of QFC and Fred Meyer) pulled the product off the shelf. Their reasoning for pulling was due to a far more insidious reason than my mistake theory: product tampering.
I knew that formula was a high theft item from my days of working in a grocery store. I always figured it was either parents out to feed their kids or scammers selling the stolen property or doing fake returns. I never, ever dreamed that formula would be the subject of black markets or people deliberately putting higher priced product labels on lower priced formula.
A spokeswoman for the company stated that the product has been pulled from al 233 stores in the chain. An investigation to determine how the tampered product made its way to their shelves is underway; while there is a black market for formula, the company takes steps to ensure that their product is legitimate.
Customers who have purchased Earth's Best Organic Soy formula are urged to return it to the store for refund or other product.
Why do you tweet old articles? It's misleading, especially in instances like this. It's July 24 2013, yet this article was written Sept 2012. Not good for formula feeding parents who may now be needlessly worried about what they are feeding their babies.


Each week, the Erb Institute shares a collection of news and updates regarding business sustainability. This month, the Erb Institute blog and social media are focusing on a key aspect to both business and sustainability: supply chain.
"More than 1,000 of the world's largest companies report their greenhouse gas emissions and have emissions-reduction targets for their own operations. Now, they want the thousands of companies that supply them with goods and services to reduce their own emissions.
"The Monterey Bay Aquarium's Seafood Watch program, known best for its red, yellow and green sustainable seafood-rating scheme, is unveiling its first Seafood Slavery Risk Tool on Thursday. It's a database designed to help corporate seafood buyers assess the risk of forced labor, human trafficking and hazardous child labor in the seafood they purchase.
"The closed-loop conversation is often one that focuses on e-waste, fashion and single-use plastics, but LEGO Group and Antwerp-based design furniture brand ecoBirdy are aiming to change that by bringing the concept of circularity and sustainability to the toy front.
"Deforestation is a growing and serious problem, and for Mondelēz International, it makes up the largest part of our carbon footprint. We are committed to addressing this global phenomenon, focusing on areas where we can make the biggest difference, such as palm oil and in our cocoa-growing communities. When it comes to cocoa, our emphasis of late has been on Ghana.


text:
For other uses, see Beelzebub (disambiguation).
"Baalzebub" redirects here. For the spider genus, see Ray spider.
"Beelzebub and them that are with him shoot arrows" from John Bunyan's The Pilgrim's Progress (1678)
Beelzebub as depicted in Collin de Plancy's Dictionnaire Infernal (Paris, 1863)
Beelzebub or Beel-Zebub (/biːˈɛlzᵻbʌb/ bee-EL-zə-bub or /ˈbiːlzᵻbʌb/ BEEL-zə-bub; Hebrew: בַּעַל זְבוּב, Baʿal Zəvûv; Arabic: بعل الذباب, Ba'al adh-l) is a contemporary name for the devil.
In Christian and Biblical sources, Beelzebub is another name for the devil.[1] In Christian demonology, he is one of the seven princes of Hell according to Catholic views on Hell. The Dictionnaire Infernal describes Beelzebub as a demonic fly who is also known as the "Lord of the Flies". The god of the Philistine city of Ekron, a Canaanite god.[2]
1 Hebrew Bible
2 Testament of Solomon
3 Christian Bible
4 Gnostic tradition
5 Christian tradition
5.1 Christian demonology and occult
6 Judaism
The source for the name Beelzebub is in 2 Kings 1:2-3, 6, 16. Ba'al Zəbûb is variously understood to mean "lord of the flies"[3][4][5][6] or "lord of the (heavenly) dwelling".[7][8][9] Originally the name of a Philistine god,[10] Ba'al, meaning "Lord" in Ugaritic, was used in conjunction with a descriptive name of a specific god. The Septuagint renders the name as Baalzebub (βααλζεβούβ) and as Baal muian (βααλ μυιαν, "Baal of flies"), but Symmachus the Ebionite may have reflected a tradition of its offensive ancient name when he rendered it as Beelzeboul.[11]
In regard to the god of Ekron, the belief that zebub may be the original affix to Baal and that it is a substitute for an original zbl which, after the discoveries of Ras Shamra, has been connected with the title of "prince", frequently attributed to Baal in mythological texts. Ba'al Zebub was used in Hebrew as a pun with Ba'al Zebul, where Zebul meant "of the manor," and in a derogatory manner Ba'al Zebub was used to offend the enemies of the Israelites.[citation needed] In addition to this last position, which is not supported by the versions, is the fact that it was long ago suggested that there was a relationship between the Philistine god, and cults of flies - referring to a view of them as pests, feasting on excrement - appearing in the Hellenic world, such as Zeus Apomyios or Myiagros.[citation needed] It is exactly this last connection which is confirmed by the Ugaritic text when we examine how Baal affects the expulsion of the flies which are the patient's sickness.[citation needed] According to Francesco Saracino (1982) this series of elements may be inconclusive as evidence, but the fact that in relationship to Baal Zebub, the two constituent terms are here linked, joined by a function (ndy) that is typical of some divinities attested in the Mediterranean world, is a strong argument in favor of the authenticity of the name of the god of Ekron, and of his possible therapeutic activities, which are implicit in 2 Kings 1:2-3, etc.[12]
In the Testament of Solomon, Beelzebul (not Beelzebub) appears as prince of the demons and says (6.2) that he was formerly a leading heavenly angel who was (6.7) associated with the star Hesperus (which is the normal Greek name for the planet Venus (Αφροδíτη) as evening star). Seemingly, Beelzebul here is simply Lucifer. Beelzebul claims to cause destruction through tyrants, to cause demons to be worshipped among men, to excite priests to lust, to cause jealousies in cities and murders, and to bring on war. The Testament of Solomon is an Old Testament pseudepigraphical work, purportedly written by King Solomon, in which Solomon mostly describes particular demons whom he enslaved to help build the temple, with substantial Christian interpolations.[13][14]
Christian Bible
Beelzebub from Russian icon of Harrowing of Hell
Belzebuth şi naşul săŭ ("Beelzebub and His Nemesis"), cartoon published on the cover of Furnica magazine. On the right, as Beelzebub, carrying a folder marked Finance Ministry, is a defiant Take Ionescu, newly appointed by a Conservative government. His opponent (and predecessor by proxy) is the Liberal chairman Dimitrie Sturdza, who opposes budgetary reform. Petrescu-Găină depicts him as a Christian missionary figure, cross in hand, ready to confront the devil.
In Mark 3:22, the scribes accuse Jesus of driving out demons by the power of Beelzeboul, prince of demons, the name also appearing in the expanded version in Matthew 12:24,27 and Luke 11:15, 18–19. The name also occurs in Matthew 10:25.
Jesus knew their thoughts and said to them, Every kingdom divided against itself will be ruined, and every city or household divided against itself will not stand. If Satan drives out Satan, he is divided against himself. How then can his kingdom stand? And if I drive out demons by Beelzebul, by whom do your people drive them out? So then, they will be your judges. But if I drive out demons by the Spirit of God, then the kingdom of God has come upon you.—Matthew 12:25-28
It is unknown whether Symmachus was correct in identifying these names, because we otherwise know nothing about either of them. Zeboul might derive from a slurred pronunciation of zebûb; from zebel, a word used to mean "dung" in the Targums; or from Hebrew zebûl found in 1 Kings 8:13 in the phrase bêt-zebûl, "lofty house".
In any case, the form Beelzebub was substituted for Beelzeboul in the Syriac translation and Latin Vulgate translation of the gospels, and this substitution was repeated in the King James Version of the Bible, the resulting form Beelzeboul being mostly unknown to Western European and descendant cultures until some more recent translations restored it.
Beelzebub is also identified in the New Testament as the devil, "prince of the demons".[15][16] Biblical scholar Thomas Kelly Cheyne suggested that it might be a derogatory corruption of Ba'al Zəbûl, "Lord of the High Place" (i.e., Heaven) or "High Lord".[17]
In Arabic translations, the name is rendered as Baʿlzabūl (بعلزبول).[18][19]
Gnostic tradition
Texts of the Acts of Pilate (also known as the Gospel of Nicodemus) vary in whether they use Beelzebul or Beelzebub. The name is used by Hades as a secondary name for the Devil, but it may vary with each translation of the text; other versions give the name Beelzebub as Beelzebub, but separates him from the devil.
Christian tradition
Christian demonology and occult
Beelzebub is commonly described as placed high in Hell's hierarchy. According to the stories of the 16th-century occultist Johann Weyer, Beelzebub led a successful revolt against the Devil,[20] is the chief lieutenant of Lucifer, the Emperor of Hell, and presides over the Order of the Fly. Similarly, the 17th-century exorcist Sebastien Michaelis, in his Admirable History (1612), placed Beelzebub among the three most prominent fallen angels, the other two being Lucifer and Leviathan, whereas two 18th-century works identified an unholy trinity consisting of Beelzebub, Lucifer, and Astaroth. John Milton featured Beelzebub seemingly as the second-ranking of the many fallen cherubim in the epic poem Paradise Lost, first published in 1667. Milton wrote of Beelzebub, "than whom, Satan except, none higher sat." Beelzebub is also a character in John Bunyan's The Pilgrim's Progress, first published in 1678.
Sebastien Michaelis associated Beelzebub with the deadly sin of pride. However, according to Peter Binsfeld, Beelzebub was the demon of gluttony, one of the other seven deadly sins, whereas Francis Barrett asserted that Beelzebub was the prince of false gods.
Within religious circles, the accusation of demon possession has been used as both an insult and an attempt to categorise unexplained behavior. Not only had the Pharisees disparagingly accused Jesus of using Beelzebub's demonic powers to heal people (Luke 11:14–26), but others have been labeled possessed for acts of an extreme nature. Down through history, Beelzebub has been held responsible for many cases of demon possession, such as that of Sister Madeleine de Demandolx de la Palud, Aix-en-Provence in 1611, whose relationship with Father Jean-Baptiste Gaufridi led not only to countless traumatic events at the hands of her inquisitors but also to the torture and execution of that "bewitcher of young nuns", Gaufridi himself. Beelzebub was also imagined to be sowing his influence in Salem, Massachusetts: his name came up repeatedly during the Salem witch trials, the last large-scale public expression of witch hysteria in North America or Europe, and afterwards, Rev. Cotton Mather wrote a pamphlet entitled Of Beelzebub and his Plot.[21]
The name Baʿal Zəvûv (Hebrew: בעל זבוב) is found in 2Kings 1:2-3,6,16, where King Ahaziah of Israel, after seriously injuring himself in a fall, sends messengers to inquire of Ba'al Zebûb, the god of the Philistine city of Ekron, to learn if he will recover.
Now Ahaziah fell through the lattice in his upper chamber that was in Samaria, and he became ill; and he sent messengers and said to them, "Go inquire of Baal-zebub, the god of Ekron, whether I will recover from this illness."
— 2Kings 1:2
Elijah the Prophet then condemns Ahaziah to die by God's words because Ahaziah sought counsel from Ba'al Zebûb rather than from God.
But an angel of the Lord spoke to Elijah the Tishbite [saying], "Arise, go up toward the king of Samaria's messengers, and speak to them, [saying], 'Is it because there is no God in Israel, that you go to inquire of Baal-zebub the god of Ekron? Therefore, so has the Lord said, "From the bed upon which you have ascended you will not descend, for you shall die." ' " And Elijah went.
— 2Kings 1:3-4
Rabbinical literature commentary equates Baal Zebub of Ekron as lord of the "fly".[22][23] The word Ba'al Zebûb in rabbinical texts is a mockery of the Ba'al religion, which ancient Hebrews considered to be idol worship.[24]
Jewish scholars have interpreted the title of "Lord of Flies" as the Hebrew way of calling Ba'al a pile of dung and comparing Ba'al followers to flies.[25][26]
Beelzebub, in a 2015 production of St George and the Dragon by the St Albans Mummers
Beelzebufo (pre-historic frog)
Beelzebub Bat
Belial
"Bohemian Rhapsody"
Ishtar Gate
↑ biblegateway.com
↑ Book of Kings, II, i., 2, 3, 6, 16
↑ "Βεελζεβούλ, ὁ indecl. (v.l. Βεελζεβούβ and Βεεζεβούλ W-S. §5, 31, cp. 27 n. 56) Beelzebul, orig. a Philistine deity; the name בַּעַל זְבוּב means Baal (lord) of the flies (4 Km 1:2, 6; Sym. transcribes βεελζεβούβ; Vulgate Beelzebub; TestSol freq. Βεελζεβούλ,-βουέλ).", Arndt, W., Danker, F. W., & Bauer, W. (2000). A Greek-English lexicon of the New Testament and other early Christian literature (3rd ed.) (173). Chicago: University of Chicago Press.
↑ "1. According to 2 Kgs 1:2–6 the name of the Philistine god of Ekron was Lord of the Flies (Heb. ba'al zeaûḇ), from whom Israel's King Ahaziah requested an oracle.", Balz, H. R., & Schneider, G. (1990-). Vol. 1: Exegetical dictionary of the New Testament (211). Grand Rapids, Mich.: Eerdmans.
↑ "The etymology of Beelzebul has proceeded in several directions. The variant reading Beelzebub (Syriac translators and Jerome) reflects a long-standing tradition of equating Beelzebul with the Philistine deity of the city of Ekron mentioned in 2 Kgs 1:2, 3, 6, 16. Baalzebub (Heb ba˓al zĕbûb) seems to mean "lord of flies" (HALAT, 250, but cf. LXXB baal muian theon akkarōn, "Baal-Fly, god of Akkaron"; Ant 9:2, 1 theon muian).", Lewis, "Beelzebul", in Freedman, D. N. (1996). Vol. 1: The Anchor Yale Bible Dictionary (639). New York: Doubleday.
↑ "On the basis zebub, 'flies', the name of the god was interpreted as 'Lord of the flies'; it was assumed that he was a god who could cause or cure diseases.", Herrmann, "Baal Zebub", in Toorn, K. v. d., Becking, B., & Horst, P. W. v. d. (1999). Dictionary of deities and demons in the Bible DDD (2nd extensively rev. ed.) (154). Leiden; Boston; Grand Rapids, Mich.: Brill; Eerdmans.
↑ "It is not as probable that b'l zbl, which can mean "lord of the (heavenly) dwelling" in Ugaritic, was changed to b'l zbb to make the divine name an opprobrius epithet. The reading Beelzebul in Mt. 10:25 would then reflect the right form of the name, a wordplay on "master of the house" (Gk oikodespótēs).", McIntosh, "Baal-Zebub", in Bromiley, G. W. (1988; 2002). Vol. 1: The International Standard Bible Encyclopedia, Revised (381). Wm. B. Eerdmans.
↑ "An alternative suggested by many is to connect zĕbûl with a noun meaning " (exalted) abode."", Lewis, "Beelzebul", in Freedman, D. N. (1996). Vol. 1: The Anchor Yale Bible Dictionary (639). New York: Doubleday.
↑ "In contemporary Semitic speech it may have been understood as 'the master of the house'; if so, this phrase could be used in a double sense in Mt. 10:25b.", Bruce, "Baal-Zebub, Beelzebul", in Wood, D. R. W., & Marshall, I. H. (1996). New Bible dictionary (3rd ed.) (108). Leicester, England; Downers Grove, Ill.: InterVarsity Press.
↑ "For etymological reasons, Baal Zebub must be considered a Semitic god; he is taken over by the Philistine Ekronites and incorporated into their local cult.", Herrmann, "Baal Zebub", in Toorn, K. v. d., Becking, B., & Horst, P. W. v. d. (1999). Dictionary of deities and demons in the Bible DDD (2nd extensively rev. ed.) (154). Leiden; Boston; Grand Rapids, Mich.: Brill; Eerdmans.
↑ Catholic Encyclopedia
↑ Saracino, Francesco. "Ras Ibn Hani 78/20 and Some Old Testament Connections". Vetus Testamentum. Vol. 32, Fasc. 3 (Jul., 1982), pp. 338-343.
↑ "The Testament of Solomon", trans. F. C. Conybeare, Jewish Quarterly Review, October, 1898]
↑ Conybeare, F.C. The Testament of Solomon, The Jewish Quarterly Review, Vol. 11, No. 1, (October ,1898)
↑ "In NT Gk. beelzeboul, beezeboul (Beelzebub in TR and AV) is the prince of the demons (Mt. 12:24, 27; Mk. 3:22; Lk. 11:15, 18f.), identified with Satan (Mt. 12:26; Mk. 3:23, 26; Lk. 11:18).", Bruce, "Baal-Zebub, Beelzebul", Wood, D. R. W., & Marshall, I. H. (1996). New Bible dictionary (3rd ed.) (108). Leicester, England; Downers Grove, Ill.: InterVarsity Press.
↑ "Besides, Matt 12:24; Mark 3:22; Luke 11:15 use the apposition ἄρχων τῶν δαιμονίων 'head of the →Demons'.", Herrmann, "Baal Zebub", in Toorn, K. v. d., Becking, B., & Horst, P. W. v. d. (1999). Dictionary of deities and demons in the Bible DDD (2nd extensively rev. ed.) (154). Leiden; Boston; Grand Rapids, Mich.: Brill; Eerdmans.
↑ Born to Kvetch, Michael Wex, St. Martin's Press, New York, 2005, ISBN 0-312-30741-1
↑ Van Dyck Version, Bible Society of Egypt, 1860, retrieved 2015 Check date values in: |accessdate= (help)<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
↑ Holy Bible, New Arabic Version (كتاب الحياة — Ketab El Hayat), Biblica (formerly International Bible Society), 1982, 1997, retrieved 2015 Check date values in: |accessdate=, |year= (help)<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
↑ Rudwin, Maximilian (1970) [1931]. The Devil in Legend and Literature (2nd ed.). New York: AMS Press. p. 76. ISBN 0-404-05451-X. <templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
↑ Of Beelzebub and his Plot
↑ The Babylonian Talmud, Vol. 1 of 9: Tract Sabbath - Page 186 "made themselves Baal-berith for a god"; by Baal-berith is meant the Zebub (fly) idol of Ekron, and every idolater (at that time) made an image of his idol in miniature in order to keep it constantly at hand and to be able at any time to take it out, .."
↑ Jewish Encyclopedia - Beelzebub
↑ Books.google.com, The Routledge dictionary of gods and goddesses, devils and demons By Manfred Lurker
↑ Easton's Bible Dictionary
↑ Jewishencyclopedia.com
Catholic Encyclopedia: Beelzebub
Jewish Encyclopedia: Beelzebub
Retrieved from "https://infogalactic.com/w/index.php?title=Beelzebub&oldid=722426378"
Wikipedia pages with incorrect protection templates
Abrahamic mythology
Christian terminology
Deities in the Hebrew Bible
Demons in Christianity
Demons in the Apocrypha


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Hall v. Crown Zellerbach Corp.
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Full title:LARRY W. HALL, PLAINTIFF-APPELLANT, v. CROWN ZELLERBACH CORPORATION,…
Court:United States Court of Appeals, Fifth Circuit
Date published: Sep 26, 1983
715 F.2d 983 (5th Cir. 1983)
From Casetext: Smarter Legal Research
United States Court of Appeals, Fifth Circuit
No. 82-3682. Summary Calendar.
September 26, 1983.
S. Michael Cashio, Jr., Kenner, La., for plaintiff-appellant.
R. Bradley Lewis and Richard F. Knight, Bogalusa, La., for defendant-appellee.
Appeal from the United States District Court for the Eastern District of Louisiana.
Before GEE, POLITZ and JOHNSON, Circuit Judges.
Under Louisiana's workmen's compensation statute, an employee of an independent contractor may recover compensation benefits from the principal employer on a job if the employee is injured while performing work which is part of the principal's "trade, business, or occupation." LSA-RS 23:1061 (West 1964). This statutory liability carries with it its own limitation: the principal employer is shielded from tort liability. LSA-RS 23:1032 (West Supp. 1983). Whether a statutory relationship exists is a question of fact to be determined by the totality of the circumstances surrounding each case. Penton v. Crown Zellerbach Corporation, 699 F.2d 737, 741 (5th Cir. 1983), quoting Ortego v. Union Oil Company of California, 667 F.2d 1241 (5th Cir. 1983) (per curiam).
3. § 1061. Principal contractors; liability
Where any person (in this section referred to as principal) undertakes to execute any work, which is a part of his trade, business, or occupation or which he had contracted to perform, and contracts with any person (in this section referred to as contractor) for the execution by or under the contractor of the whole or any part of the work undertaken by the principal, the principal shall be liable to pay to any employee employed in the execution of the work or to his dependent, any compensation under this Chapter which he would have been liable to pay if the employee had been immediately employed by him; and where compensation is claimed from, or proceedings are taken against, the principal, then, in the application of this Chapter reference to the principal shall be substituted for reference to the employer, except that the amount of compensation shall be calculated with reference to the earnings of the employee under the employer by whom he is immediately employed.
Where the principal is liable to pay compensation under this Section, he shall be entitled to indemnity from any person who independently of this Section would have been liable to pay compensation to the employee or his dependent, and shall have a cause of action therefor.
5. § 1032. Exclusiveness of rights and remedies; employer's liability of prosecution under other laws
The rights and remedies herein granted to an employee or his dependent on account of an injury, or compensable sickness or disease for which he is entitled to compensation under this Chapter, shall be exclusive of all other rights and remedies of such employee, his personal representatives, dependents, or relations, against his employer, or any principal or any officer, director, stockholder, partner or employee of such employer or principal, for said injury, or compensable sickness or disease. For purposes of this Section, the word "principal" shall be defined as any person who undertakes to execute any work which is a part of his trade, business or occupation in which he was engaged at the time of the injury, or which he had contracted to perform and contracts with any person for the execution thereof.
In the instant diversity action, Larry Hall, a painter injured in the course of his work, appeals from a jury finding that such a statutory employment relationship precludes his tort claim against Crown Zellerbach Corporation. Hall contends that the evidence was insufficient for the jury to conclude that a statutory relationship existed, and that the court below erred in its instruction to the jury on the statutory employer defense. Unfortunately, Hall's counsel failed properly to preserve these issues for our review. We are therefore forced to consider these questions under the stringent "plain error" standard. Applying this strict test to a murky record, we cannot find that the jury, or the court, committed "plain error," or that a miscarriage of justice would result were the verdict allowed to stand.
In 1976, Crown Zellerbach Corporation (Crown) commenced a four-year, multi-million dollar "modernization" project to expand and upgrade its paper mill in Bogalusa, Louisiana. Most of the work was contracted out; however, Crown used its own employees to perform various tasks connected with the project as well as retaining control by designating itself the general contractor and appointing a special project manager, Robert Martin, to oversee the project.
Part of the modernization program included the installation of two high density tanks and a diffuser washer system. Crown contracted with Kamyr, Inc. to erect those steel structures; the contract called for Kamyr to erect them completely primed but without a finish coat of paint. For budget reasons, the priming was later eliminated from the Crown-Kamyr contract, and the tanks were erected unprimed. Subsequently, Crown contracted with Belle Chasse Contractors, Inc. to prime and paint the tanks in question. Hall, a painter's helper employed by Belle Chasse, was engaged in preparation for priming the steel pursuant to this contract when he was injured.
Hall sought recovery from Crown under Louisiana tort law on theories of negligence and strict liability. At the conclusion of a three-day trial, Crown moved for summary judgment on the ground that LSA-RS 23:1061 rendered it immune from tort liability because it was Hall's "statutory employer." The district court denied the motion and submitted the question of the existence of a statutory employment relationship to the jury, which found for Crown on this determinative issue.
On appeal, Hall asserts that the evidence was insufficient for the jury to reach its conclusion and that the trial court erred in its instruction to the jury on the "statutory employer" defense. However, neither of these issues are properly before us, since Hall's counsel failed to preserve them for appellate review.
Sufficiency of the Evidence
It is the law in this circuit, as generally elsewhere, that the sufficiency of the evidence supporting a jury verdict is not reviewable on appeal, . . . unless a motion for directed verdict was made at the close of all the evidence by the party seeking that review.
Quinn v. Southwest Wood Products, Inc., 597 F.2d 1018, 1024 (5th Cir. 1979). See Coughlin v. Capitol Cement Co., 571 F.2d 290, 297 (5th Cir. 1978), and cases cited therein. As this court has previously explained, the rule is designed to prevent litigants from gambling that the jury will rule in their favor, while reserving the option of challenging the sufficiency of the evidence on appeal should the jury rule against them.
See, e.g., Quinn, 597 F.2d at 1024-25; Coughlin, 571 F.2d at 297; Little v. Bankers Life Casualty Co., 426 F.2d 509, 511 (5th Cir. 1970) ("Similarly, the litigant who has not moved for a directed verdict in the trial court must have been of the view that the evidence made a case for the jury; he should not be permitted on appeal to impute error to the trial judge for sharing that view."). See generally C. Wright A. Miller, Federal Practice and Procedure: Civil § 2536.
When a claimed deficiency in the evidence is called to the attention of the trial judge and of counsel before the jury has commenced deliberation, counsel still may do whatever can be done to mend his case. But if the court and counsel learn of such a claim for the first time after verdict, both are ambushed and nothing can be done except by way of a complete new trial. It is contrary to the spirit of our procedures to permit counsel to be sandbagged by such tactics or the trial court to be so put in error.
Quinn, 597 F.2d at 1025.
This case presents a core example of a fatally belated challenge to the evidence. Plaintiff did not move for a directed verdict at the close of the evidence, nor indeed did plaintiff assert any deficiency in the evidence by way of a motion for relief prior to the jury's commencement of its deliberations. Where plaintiff has thus failed to preserve the issue of sufficiency of the evidence for appellate review,
Also, plaintiff did not move for a judgment notwithstanding the verdict, or for a new trial, after the jury had rendered its verdict.
Compare Quinn, 597 F.2d at 1025-26 (where defendant formally moved for a directed verdict, objecting to the submission of a general interrogatory on specific grounds of evidentiary insufficiency, at a time when the jury had formally retired but before it had been permitted to begin its deliberations, the defendant had preserved the sufficiency of the evidence for appellate review).
"our inquiry is limited to whether there was any evidence to support the jury's verdict, irrespective of its sufficiency, or whether plain error was committed which, if not noticed, would result in a manifest miscarriage of justice.
Coughlin, 571 F.2d at 297, citing American Lease Plans, Inc. v. Houghton Construction Co., 492 F.2d 34, 35 (5th Cir. 1974); Little v. Bankers Life Casualty Co., 426 F.2d at 511 (5th Cir. 1970). See also Patton v. Archer, 590 F.2d 1319, 1323 (5th Cir. 1979); House of Koscot Development Corp. v. American Line Cosmetics, Inc., 468 F.2d 64, 67, 68 nn. 4, 5 (5th Cir. 1972); Ramada Development Co. v. Rauch, 644 F.2d 1097, 1102-03 (5th Cir. 1981).
Prior to reviewing the record for some evidence of a statutory employment relationship, we take a moment to specify what evidence we seek. The standard for determining the existence of a statutory employment relationship was established by this court in Blanchard v. Engine Gas Compressor Services, Inc., 613 F.2d 65, 69 (5th Cir. 1980) ( Blanchard II). In that seminal case we stated:
In Blanchard II, this circuit engaged in an in-depth analysis of Louisiana precedent, endeavoring to harmonize conflicting interpretations of LSA-RS 23:1061 and define a flexible test appropriate to present industrial practices. The Fifth Circuit was forced to undertake this task, properly that of the Louisiana Supreme Court, by the refusal of that court to respond to our certification of the issue to it.
The proper standard, as we see it, is whether the activity done by the injured employee or his actual immediate employer is part of the usual or customary practice of the principal or others in the same operational business.
More specifically, we should first consider whether the particular principal involved in the case customarily does the type of work performed by the contractor and whether the contractor's work is an integral part of the work customarily performed by the principal. If either of these situations exist, then there is a statutory employment relationship, and the inquiry ends there. If, however, the principal does not normally engage in this type of activity, or if it is not normally a part of his practices, then it is necessary to determine if others engaged in businesses similar to that of the principal customarily do this type of work or if it is an integral part of their businesses. If either of these inquiries yields an affirmative answer, then the general custom of the trade will control to make the relationship between the principal in question and his contractors' employees that of statutory employer and employee.
In applying this test, it is proper to consider all facts which would or would not suggest a statutory employment relationship. Whether the work is essential to the business of the principal or others engaged in similar businesses, may be one such fact.
Another fact to consider is whether the principal, or others engaged in like operational activities, normally subcontract out the work or whether they have employees who can, and customarily do, do the work.
613 F.2d at 71 (emphasis added). Cases since Blanchard II in both state and federal courts have affirmed the analysis we performed in that case and further clarified the standard we outlined there. See, e.g., Penton v. Crown Zellerbach Corporation, 699 F.2d 737 (5th Cir. 1983); Williams v. Shell Oil Co., 677 F.2d 506 (5th Cir.), cert. denied, ___ U.S. ___, 103 S.Ct. 570, 74 L.Ed.2d 933 (1982); Darville v. Texaco, 674 F.2d 443 (5th Cir.), cert. denied, ___ U.S. ___, 103 S.Ct. 298, 74 L.Ed.2d 280 (1982); Barrios v. Engine Compressor Services, Inc., 669 F.2d 350 (5th Cir. 1982); Murphy v. Georgia Pacific Corp., 628 F.2d 862 (5th Cir. 1980); see also Melancon v. Tassin Amphibious Equipment Corp., 427 So.2d 932, 935 (La.App. 1983) (approving Blanchard II analysis and test).
This case requires that we examine the precise definition and significance that our post- Blanchard II cases, and those of the Louisiana courts, have given to the issue of whether the work in question is usually performed by the principal's own employees. It is clear that "the determination of whether a principal is the statutory employer of a contractor's employee is not dependent upon the principal's having employees performing the same task." Guinn v. Progress Drilling, Inc., 398 So.2d 128, 130, (La.App. 1981). See Murphy v. Georgia-Pacific Corp., 628 F.2d at 868, n. 12 ("Defendant's . . . emphasis on the fact the Georgia-Pacific employees had the skills necessary to perform the work done by plaintiff when he was injured is misplaced. The construction project must be considered as a whole, . . . otherwise, by hiring `jacks of all trades,' a principal employer would make any activity part of its `trade, business or occupation'." (citations omitted)); Penton, 699 F.2d at 744 ("The argument that Crown employed persons who could have performed appellant's particular task, without more, does little more than muddy the waters."); Williams v. Shell Oil, 677 F.2d at 509, n. 3; Elliott v. Louisiana Power Light Co., 671 F.2d 865, 867 (5th Cir. 1982); Blanchard II at 71 (fact that principal does not have his own employees to do duties is not determinative), citing Barnes v. Sun Oil Co., 362 So.2d 761 (La. 1978).
The cases indicate that while it is not determinative whether the employee performs duties (e.g. painting, welding, etc.) which the principal's employees also perform, it is relevant to a Blanchard II inquiry whether the project on which the employee in question was injured was the sort of project which the principal usually employed his own employees to perform (e.g. new construction or routine repair). As this court put the distinction recently in Penton v. Crown Zellerbach, supra, a case which like this one involved an employee of an independent contractor injured while working on Crown's Bogalusa modernization: "In this connection, focus is directed to the relationship between the independent contractor and the principal employer rather than the specific duties of the injured employee." 699 F.2d at 741. See id. at 744 (relevant issue is "whether the magnitude and type of Crown's update and modification of the Bogalusa plant facility was part of its usual and customary practice"; "full airing of (Crown's) day-to-day operations" needed for resolution of issue); Murphy, 628 F.2d at 867-68 (upholding directed verdict denying existence of statutory relationship where plaintiff injured during major expansion of paper mill and principal's employees had never been used on major new construction); Barrios v. Engine Gas Compressor Services, Inc., 669 F.2d at 354-55 (upholding district court finding of statutory employer relationship where principal's employees "regularly performed the same repairs and maintenance work on compressor engines that plaintiff was doing at time of accident," and "it was essential to [principal] to keep compressors in top working order at all times"); Darville v. Texaco, 674 F.2d at 444-46 (affirming summary judgment finding statutory employment relationship where plaintiff's vacuuming of oil separators necessary to operation of principal's plant; fact that principal always contracted out vacuuming at this plant not enough to raise triable issue of fact).
In the instant case, the evidence as to the existence of a statutory relationship focused almost exclusively on the fact that Crown employed persons who could and did do painting associated with other parts of the modernization project. Robert Martin, formerly project manager of the modernization project, testified that Crown employed a regular crew of "facility mechanics" who put the finishing coat of paint on other elements of the modernization project. Martin also testified that Crown's usual course of proceeding, at its mills other than the Bogalusa mill, was to have Crown employees paint new equipment installed by Crown and do maintenance work. If, however, Crown lacked the manpower for the job, Crown would hire independent contractors.
These employees also did carpentry work, brick work, and concrete work in addition to painting.
The high density tanks, which were new construction installed by Kamyr, would not fall into this category of equipment generally painted by Crown employees.
To repeat, the posture of this case precludes us from reviewing the weight or adequacy of this evidence. Under the applicable "any evidence" standard, we cannot find that the record is totally devoid of any evidence of a statutory relationship.
The Instruction to the Jury
Hall asserts that the trial court erred in its instruction to the jury on the statutory employer defense. Unfortunately, Hall's counsel again failed properly to preserve this issue for our review. Although counsel for plaintiff timely objected to the court's instruction, he did not adequately specify the grounds for his objection.
Counsel objected to the instructions on the ground that "we don't feel that is the state of the law of the statutory defense." Such a general objection does not meet the specificity requirement of Rule 51. See Apperwhite v. Illinois Cent. R. Co., 239 F.2d 306 (8th Cir. 1957) (objection that charge "not the true law" does not meet specificity requirement); see also Gorsalitz v. Olin Mathieson Chemical Corp., 429 F.2d 1033, 1037, 1040 (5th Cir. 1970), cert. denied, 407 U.S. 921, 92 S.Ct. 2463, 32 L.Ed.2d 807 (1972).
We cannot overlook this failure to comply with the requirement of Fed.R.Civ.Proc. 51 that any objection to a jury instruction "state distinctly the . . . grounds of the objection."
Rule 51 promotes judicial economy and integrity by serving a dual purpose. Compliance with the Rule provides an opportunity for the trial judge to correct errors while it eases the burden on appellate courts by reducing the potential number of reviewable court rulings.
McKinnon v. Skil Corp., 638 F.2d 270 (1st Cir. 1981). See Pruett v. Marshall, 283 F.2d 436, 441 (5th Cir. 1960). Plaintiff's objection did not provide adequate guidance for the trial court to revise its instructions since the objection did not indicate what conflict plaintiff saw between the instruction and the applicable law. We are aware that
We note that plaintiff did not specifically object to the trial court's failure to give plaintiff's requested instruction on the statutory employer defense. Thus, we decline to attempt to divine plaintiff's true objection by comparing plaintiff's suggested charge with the one given by the trial court. See C. Wright A. Miller, Federal Practice Procedure: Civil § 2554, text accompanying notes 68-70 (request for instruction need not be objection to charge as given).
[t]he Appellate Court . . . may in its discretion consider grounds of error in spite of a failure to object below where it is apparent on the face of the record that there was plain error or a miscarriage of justice.
Pruett, 283 F.2d at 441, n. 3 (citations omitted). This is not such a case.
See Rauch, 644 F.2d at 1102; Bissett v. Ply-Gem Industries, Inc., 533 F.2d 142 (5th Cir. 1976); Wirtz v. International Harvester Co., 331 F.2d 462 (5th Cir. 1964).
Even if Hall had properly presented this issue for our review, we would find no error in the instruction.
In the review of jury instructions, a challenged instruction should not be considered in isolation but rather as part of an integrated whole. If, viewed in that light, the jury instructions are comprehensive, balanced, fundamentally accurate, and not likely to confuse or mislead the jury, the charge will be deemed adequate. Vezina v. Theriot Marine Service, Inc., 554 F.2d 654 (5th Cir. 1977). See also United States v. Gray, 626 F.2d 494 (5th Cir. 1980); and Crador v. Louisiana Dept. of Highways, 625 F.2d 1227 (5th Cir. 1980); and Hlodan v. Ohio Barge Line, Inc., 611 F.2d 71 (5th Cir. 1980). Scheib v. Williams-McWilliams Co., Inc., 628 F.2d 509 (5th Cir. 1980). The district court's instruction on the statutory employer defense was clear and comprehensive; it carefully tracked the standard enunciated in Blanchard II.
This case does not present a model of proof of the statutory employer defense. Our review is, however, strictly circumscribed by the posture of this appeal. We cannot find plain error on this record.
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Lt. Governor Nancy Wyman - Archive
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GOV. MALLOY, LT. GOV. WYMAN STATEMENTS ON EQUAL PAY DAY
(HARTFORD, CT) - Governor Dannel P. Malloy and Lieutenant Governor Nancy Wyman released the following statements to recognize Equal Pay Day:
"I am proud of the steps we have taken to address the gender wage gap in Connecticut, including raising the minimum wage," said Governor Malloy. "About 6 in 10 minimum wage workers are women. Raising the minimum wage to $10.10 will improve the economic security of women and their families in Connecticut. But this action alone is not enough. It is unacceptable for women, doing the same work, to earn 78 percent of what men earn. Last year, I created a task force headed by the state's labor and economic development agencies to study the gender wage gap in Connecticut. Commissioners Sharon Palmer and Catherine Smith and the other task force members have drawn up a list of achievable recommendations that we believe will help eliminate gender wage discrimination and bring full economic equality in the workplace."
"Raising the minimum wage is a good start for approximately 125,000 Connecticut women who are earning at or just above the minimum wage, but there is much more we need to do to level the playing field for working women," said Lt. Governor Nancy Wyman. " The Gender Wage Gap study highlights how important it is for all of us to address pay inequality-from ending pay secrecy practices in the private sector to teaching women how to negotiate their compensation to encouraging girls in STEM. There must be equal pay for equal work. It is a fundamental economic security issue for Connecticut women, their families, and the country."
In November, the Gender Wage Gap Task Force issued recommendations to close the wage gap including increasing awareness, promoting pay equity in the private sector, supporting working women, promoting education, and continuing to monitor pay equity. Since the release of the report, Lt. Governor Wyman, in collaboration with Permanent Commission on the Status of Women Executive Director Teresa Younger, has hosted a series of roundtables in East Hartford, Norwich, Stamford, Torrington and Waterbury on issues affecting Connecticut women, such as workplace policies, pay equity, and higher education opportunities.
**Download: The Gender Wage Gap in Connecticut: Findings and Recommendations
Twitter: https://twitter.com/@LGWyman
Facebook: https://www.facebook.com/LtGovWyman


Gavin leads the BTO's Land-Use Research team, which currently comprises up to 15 analytical and field research staff, conducting and supervising pure and applied research on terrestrial bird ecology.
Terrestrial bird ecology at a range of spatial scales, from territories to landscapes, via field experiments and analyses of large-scale, long-term datasets. Research at the BTO has considered migration ecology, cause of decline in woodland birds and methods of population trend analysis, but has focused primarily on farmland birds, contributing directly to government policy on the environment. A major three-year project on the demography of farmland birds (1996-1999), involving detailed analyses of extensive data sets held by the BTO and other organizations, helped to identify causes of decline. Subsequent large-scale projects have tested the hypotheses identified using landscape-scale field experiments and have also considered the likely efficacy of management solutions (2001-2007). More recently, research has focused on testing the agri-environment solutions to farmland bird conservation problems and on measuring the effects of current issues in farmland such as the disappearance of set-aside. A parallel research direction is considering bird-habitat modelling, considering both habitat types per se and habitat heterogeneity. Planned future research directions include further work on heterogeneity and habitat interactions, the ecology of predation and the design and testing of agri-environment solutions to the farmland bird conservation problems that still remain.
Member of the Editorial Board of Bird Study. Member of the British Ornithologists' Union's council.


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Maia Nuku, Evelyn A. J. Hall and John A. Friede Associate Curator for Oceanic Art, was born in London and is of English and Maori (Ngai Tai) descent. Her doctoral research focused on early missionary collections of Polynesian gods and their extraordinary materiality, which sparked an interest in drawing out the often eclipsed cosmological aspects of Oceanic art. She followed up her involvement on the major exhibition Pacific Encounters: Art and Divinity in Polynesia 1760–1860 (2006) at the Sainsbury Centre for Visual Arts, with postdoctoral research at Cambridge University's Museum of Archaeology and Anthropology as part of a research team exploring Oceanic collections in major European institutions—Artefacts of Encounter: 1765–1840 and Pacific Presences: Oceanic Art in European Museums.


In order to enroll in the CHBC Preschool Program your child must meet the Michigan Age Requirement. To enroll in the four year-old program your child must be four years-old on or before December 1st. All children must be completely potty trained in order to attend.
A typical daily schedule at Highview Preschool will include, greeting time, circle time, snack time, story time, large motor activities, small group learning activities, and choice time. During "choice" time, the children are encouraged to explore a variety of materials and different activities that will aide in developing a wide range of skills. The following are some of the areas that are available to them during choice time.