Tuesday, December 24, 2019

Overpopulation and the Carrying Capacity of the Earth...

Overpopulation and the Carrying Capacity of the Earth As humans start a new millennium, we have close to 4 billion more than we had at the beginning of the last millennium. In the next 50 years we are looking at adding another 3 billion people. Such a rapid increase has placed great strains on the Earth and leads us to ask – how many people can the earth support? The answer is rather obscure, however it seems like we are approaching our limit rather soon. With decreasing aquifers, shortages in food, and increasing pollution, the Earth has reached its limit. Carrying capacity is defined as the maximum population that can be supported by the available resources while still leaving resources for future generations. All living†¦show more content†¦Many countries have seen this rapid growth and see that it is quite detrimental. Most countries that are considered industrialized have curbed their population growths. Most of Europe has either a growth of 0% or it is in the negative numbers. America is also trying to curb i t population growth of 2%. Developing nations are where the population controls are needed. Even among the developing nations there is a divide. One group, exemplified by the Eastern Asian countries have made efforts to keep families small and in return see increased quality of life and falling fertility. The other group of developing nations, mostly comprised of the continent of Africa and the Indian subcontinent, have not addressed the issue of population control. It is these countries that will and in some cases are seeing the effects of overpopulation directly. The indirect effect of these countries, such as migration and social problems will become the problems of countries in Europe and the United States. The main determinant of the Earth’s carrying capacity can be packaged under the term of sustainable resources. Sustainable resources are resources need for life that are being replenished at the same rate or at a higher rate than it is being used. Resources such a freshwater, cropland and grain, air, habitable land, and forests are resources vital for life. Once abundant and seemingly endless, they have become valuable commodities and are no longerShow MoreRelatedOverpopulation Is A Major Challenge That Humans Face Today1199 Words   |  5 Pages Overpopulation is a major challenge that humans face today. The human population is close to 8 billion, and at our current birthrate, we are adding nearly one billion more people every 12 years. Issues such as dependence of natural resources, degradation of the environment, poverty, and unemployment, are root causes of overpopulation. Though opponents of this theory, such as Erle C. Ellis uses archeological records, and the history of human evolution to argue against overpopulation. Robert WalkerRead MoreOverpopulation Is A Foremost Challenge That Humans Face Today1431 Words   |  6 PagesA Debate over Overpopulation Overpopulation is a foremost challenge that humans face today. According to www.Worldometeres.info, the human population is heading to 7.5 billion, and at our current birthrate, we are adding nearly one billion more people every twelve years. Issues such as dependence on natural resources, degradation of the environment, poverty, and unemployment, are root issues caused by overpopulation. Though opponents of this theory, such as Erle C. Ellis, use archaeological recordsRead MoreOverpopulation : We Must Figure It Out For Save The World Essay1645 Words   |  7 Pages Overpopulation: We Must Figure It Out to Save the World It may not be something you think about often, but human population growth is a big issue in our world today and this problem needs to be solved in the future to save our planet. Overpopulation is a condition that will be in effect if the population exceeds the carrying capacity on Earth. The carrying capacity is the peak population that can sustain human life on Earth. It is uncertain what Earth’s carrying capacity is for the human raceRead MoreOverpopulation Is Not The Problem1395 Words   |  6 Pages Overpopulation Overpopulation is a prominent controversial topic among society, in which some believe the exponential growth of humanity is detrimental to its future, whereas others conclude this theory is a myth due to human nature and resources. In Isaac Asimov’s, â€Å"The Case Against Man†, he elucidated the verity of overpopulation, emphasizing that the disproportion of earth’s carrying capacity and its resources will inevitably lead to humanity’s demise. Introducing the notion thatRead MoreThe Problem Of Space Research1329 Words   |  6 Pages The government must continue to fund space research in order to colonize and contain the current overpopulation as well as other global issues on Earth. Space research involves scientific studies launched with specific equipment to outer space, and provides a broad category of research disciplines such as: Earth science, Materials science, Biology, Medicine etc. Many complain of how costly space research is, with missions that have a total cost of up to 1.6 billion dollars, many feel that it’s notRead MoreWhy Overpopulation Is A Major Issue1653 Words   |  7 PagesEveryone knows that overpopulation is a major issue; an issue is only going to increase over the next few decades. Every person should have a general understanding of this problem because it is going to affect everyone on the planet if it has not done so already. Many countries on our planet now are already overpopulated. In many third world countries, parents do not have enough money to feed themselves, let alone food for their own children. It is estimated that over one billion people wake upRead MoreCauses And Effects Of Overpopulation1073 Words   |  5 PagesWhat are the effects of overpopulation? Overpopulation is an undesirable condition where the number of existing people on earth exceeds the carrying capacity of the earth. However, overpopulation has not always been a problem. At the dawn of agriculture, 8000 B.C., the population was approximately 5 million. 8000 years later, 1 A.D., the number of people existing on earth was between 200-300 million. That’s a growth rate under 0,05% per year. A tremendous change occurred with the industrial revolutionRead MoreThe Problem Of Overpopulation And Overpopulation872 Words   |  4 PagesHuman overpopulation. Human population can be defined as the condition whereby, the total count of the human inhabiting a certain area exceeds the carrying capacity of the area Bongaarts, (2011). This brings out an issue of the carrying capacity of the region which alludes to the number of individuals who can inhabit a certain area for a given period. It may also be looked at as the situation whereby the available renewable resources in a certain area can satisfactorily support the current populationRead MoreOverpopulation Essay906 Words   |  4 Pagesrate of population growth remains the same, then earth will run out of the land and resources we consume to maintain our lifestyles. The term overpopulation is normally associated with a specific number that represents a large number of people. However, overpopulation is the phenomenon that occurs whenever the environment can no longer sustain the demands of the species that inhabit it and the carrying capacity is exceeded. The carrying capacity is the amount of species that an environment canRead MoreThe Earth s Inadequate Supply Of Natural Resources1274 Words   |  6 PagesMallory York Environmental Science September 10, 2015 The Earth s inadequate supply of natural resources will only be able to tolerate 2 billion humans by 2100, the bad thing about that is, is that the world already feeds and supports 5.9 billion. The ideal human population, or carrying capacity, for the U.S. is projected to be 200 million, which is way fewer than the current population of the United States. This is a growing problem in not only the United States but also around our world today

Overpopulation and the Carrying Capacity of the Earth...

Overpopulation and the Carrying Capacity of the Earth As humans start a new millennium, we have close to 4 billion more than we had at the beginning of the last millennium. In the next 50 years we are looking at adding another 3 billion people. Such a rapid increase has placed great strains on the Earth and leads us to ask – how many people can the earth support? The answer is rather obscure, however it seems like we are approaching our limit rather soon. With decreasing aquifers, shortages in food, and increasing pollution, the Earth has reached its limit. Carrying capacity is defined as the maximum population that can be supported by the available resources while still leaving resources for future generations. All living†¦show more content†¦Many countries have seen this rapid growth and see that it is quite detrimental. Most countries that are considered industrialized have curbed their population growths. Most of Europe has either a growth of 0% or it is in the negative numbers. America is also trying to curb i t population growth of 2%. Developing nations are where the population controls are needed. Even among the developing nations there is a divide. One group, exemplified by the Eastern Asian countries have made efforts to keep families small and in return see increased quality of life and falling fertility. The other group of developing nations, mostly comprised of the continent of Africa and the Indian subcontinent, have not addressed the issue of population control. It is these countries that will and in some cases are seeing the effects of overpopulation directly. The indirect effect of these countries, such as migration and social problems will become the problems of countries in Europe and the United States. The main determinant of the Earth’s carrying capacity can be packaged under the term of sustainable resources. Sustainable resources are resources need for life that are being replenished at the same rate or at a higher rate than it is being used. Resources such a freshwater, cropland and grain, air, habitable land, and forests are resources vital for life. Once abundant and seemingly endless, they have become valuable commodities and are no longerShow MoreRelatedOverpopulation Is A Major Challenge That Humans Face Today1199 Words   |  5 Pages Overpopulation is a major challenge that humans face today. The human population is close to 8 billion, and at our current birthrate, we are adding nearly one billion more people every 12 years. Issues such as dependence of natural resources, degradation of the environment, poverty, and unemployment, are root causes of overpopulation. Though opponents of this theory, such as Erle C. Ellis uses archeological records, and the history of human evolution to argue against overpopulation. Robert WalkerRead MoreOverpopulation Is A Foremost Challenge That Humans Face Today1431 Words   |  6 PagesA Debate over Overpopulation Overpopulation is a foremost challenge that humans face today. According to www.Worldometeres.info, the human population is heading to 7.5 billion, and at our current birthrate, we are adding nearly one billion more people every twelve years. Issues such as dependence on natural resources, degradation of the environment, poverty, and unemployment, are root issues caused by overpopulation. Though opponents of this theory, such as Erle C. Ellis, use archaeological recordsRead MoreOverpopulation : We Must Figure It Out For Save The World Essay1645 Words   |  7 Pages Overpopulation: We Must Figure It Out to Save the World It may not be something you think about often, but human population growth is a big issue in our world today and this problem needs to be solved in the future to save our planet. Overpopulation is a condition that will be in effect if the population exceeds the carrying capacity on Earth. The carrying capacity is the peak population that can sustain human life on Earth. It is uncertain what Earth’s carrying capacity is for the human raceRead MoreOverpopulation Is Not The Problem1395 Words   |  6 Pages Overpopulation Overpopulation is a prominent controversial topic among society, in which some believe the exponential growth of humanity is detrimental to its future, whereas others conclude this theory is a myth due to human nature and resources. In Isaac Asimov’s, â€Å"The Case Against Man†, he elucidated the verity of overpopulation, emphasizing that the disproportion of earth’s carrying capacity and its resources will inevitably lead to humanity’s demise. Introducing the notion thatRead MoreThe Problem Of Space Research1329 Words   |  6 Pages The government must continue to fund space research in order to colonize and contain the current overpopulation as well as other global issues on Earth. Space research involves scientific studies launched with specific equipment to outer space, and provides a broad category of research disciplines such as: Earth science, Materials science, Biology, Medicine etc. Many complain of how costly space research is, with missions that have a total cost of up to 1.6 billion dollars, many feel that it’s notRead MoreWhy Overpopulation Is A Major Issue1653 Words   |  7 PagesEveryone knows that overpopulation is a major issue; an issue is only going to increase over the next few decades. Every person should have a general understanding of this problem because it is going to affect everyone on the planet if it has not done so already. Many countries on our planet now are already overpopulated. In many third world countries, parents do not have enough money to feed themselves, let alone food for their own children. It is estimated that over one billion people wake upRead MoreCauses And Effects Of Overpopulation1073 Words   |  5 PagesWhat are the effects of overpopulation? Overpopulation is an undesirable condition where the number of existing people on earth exceeds the carrying capacity of the earth. However, overpopulation has not always been a problem. At the dawn of agriculture, 8000 B.C., the population was approximately 5 million. 8000 years later, 1 A.D., the number of people existing on earth was between 200-300 million. That’s a growth rate under 0,05% per year. A tremendous change occurred with the industrial revolutionRead MoreThe Problem Of Overpopulation And Overpopulation872 Words   |  4 PagesHuman overpopulation. Human population can be defined as the condition whereby, the total count of the human inhabiting a certain area exceeds the carrying capacity of the area Bongaarts, (2011). This brings out an issue of the carrying capacity of the region which alludes to the number of individuals who can inhabit a certain area for a given period. It may also be looked at as the situation whereby the available renewable resources in a certain area can satisfactorily support the current populationRead MoreOverpopulation Essay906 Words   |  4 Pagesrate of population growth remains the same, then earth will run out of the land and resources we consume to maintain our lifestyles. The term overpopulation is normally associated with a specific number that represents a large number of people. However, overpopulation is the phenomenon that occurs whenever the environment can no longer sustain the demands of the species that inhabit it and the carrying capacity is exceeded. The carrying capacity is the amount of species that an environment canRead MoreThe Earth s Inadequate Supply Of Natural Resources1274 Words   |  6 PagesMallory York Environmental Science September 10, 2015 The Earth s inadequate supply of natural resources will only be able to tolerate 2 billion humans by 2100, the bad thing about that is, is that the world already feeds and supports 5.9 billion. The ideal human population, or carrying capacity, for the U.S. is projected to be 200 million, which is way fewer than the current population of the United States. This is a growing problem in not only the United States but also around our world today

Overpopulation and the Carrying Capacity of the Earth...

Overpopulation and the Carrying Capacity of the Earth As humans start a new millennium, we have close to 4 billion more than we had at the beginning of the last millennium. In the next 50 years we are looking at adding another 3 billion people. Such a rapid increase has placed great strains on the Earth and leads us to ask – how many people can the earth support? The answer is rather obscure, however it seems like we are approaching our limit rather soon. With decreasing aquifers, shortages in food, and increasing pollution, the Earth has reached its limit. Carrying capacity is defined as the maximum population that can be supported by the available resources while still leaving resources for future generations. All living†¦show more content†¦Many countries have seen this rapid growth and see that it is quite detrimental. Most countries that are considered industrialized have curbed their population growths. Most of Europe has either a growth of 0% or it is in the negative numbers. America is also trying to curb i t population growth of 2%. Developing nations are where the population controls are needed. Even among the developing nations there is a divide. One group, exemplified by the Eastern Asian countries have made efforts to keep families small and in return see increased quality of life and falling fertility. The other group of developing nations, mostly comprised of the continent of Africa and the Indian subcontinent, have not addressed the issue of population control. It is these countries that will and in some cases are seeing the effects of overpopulation directly. The indirect effect of these countries, such as migration and social problems will become the problems of countries in Europe and the United States. The main determinant of the Earth’s carrying capacity can be packaged under the term of sustainable resources. Sustainable resources are resources need for life that are being replenished at the same rate or at a higher rate than it is being used. Resources such a freshwater, cropland and grain, air, habitable land, and forests are resources vital for life. Once abundant and seemingly endless, they have become valuable commodities and are no longerShow MoreRelatedOverpopulation Is A Major Challenge That Humans Face Today1199 Words   |  5 Pages Overpopulation is a major challenge that humans face today. The human population is close to 8 billion, and at our current birthrate, we are adding nearly one billion more people every 12 years. Issues such as dependence of natural resources, degradation of the environment, poverty, and unemployment, are root causes of overpopulation. Though opponents of this theory, such as Erle C. Ellis uses archeological records, and the history of human evolution to argue against overpopulation. Robert WalkerRead MoreOverpopulation Is A Foremost Challenge That Humans Face Today1431 Words   |  6 PagesA Debate over Overpopulation Overpopulation is a foremost challenge that humans face today. According to www.Worldometeres.info, the human population is heading to 7.5 billion, and at our current birthrate, we are adding nearly one billion more people every twelve years. Issues such as dependence on natural resources, degradation of the environment, poverty, and unemployment, are root issues caused by overpopulation. Though opponents of this theory, such as Erle C. Ellis, use archaeological recordsRead MoreOverpopulation : We Must Figure It Out For Save The World Essay1645 Words   |  7 Pages Overpopulation: We Must Figure It Out to Save the World It may not be something you think about often, but human population growth is a big issue in our world today and this problem needs to be solved in the future to save our planet. Overpopulation is a condition that will be in effect if the population exceeds the carrying capacity on Earth. The carrying capacity is the peak population that can sustain human life on Earth. It is uncertain what Earth’s carrying capacity is for the human raceRead MoreOverpopulation Is Not The Problem1395 Words   |  6 Pages Overpopulation Overpopulation is a prominent controversial topic among society, in which some believe the exponential growth of humanity is detrimental to its future, whereas others conclude this theory is a myth due to human nature and resources. In Isaac Asimov’s, â€Å"The Case Against Man†, he elucidated the verity of overpopulation, emphasizing that the disproportion of earth’s carrying capacity and its resources will inevitably lead to humanity’s demise. Introducing the notion thatRead MoreThe Problem Of Space Research1329 Words   |  6 Pages The government must continue to fund space research in order to colonize and contain the current overpopulation as well as other global issues on Earth. Space research involves scientific studies launched with specific equipment to outer space, and provides a broad category of research disciplines such as: Earth science, Materials science, Biology, Medicine etc. Many complain of how costly space research is, with missions that have a total cost of up to 1.6 billion dollars, many feel that it’s notRead MoreWhy Overpopulation Is A Major Issue1653 Words   |  7 PagesEveryone knows that overpopulation is a major issue; an issue is only going to increase over the next few decades. Every person should have a general understanding of this problem because it is going to affect everyone on the planet if it has not done so already. Many countries on our planet now are already overpopulated. In many third world countries, parents do not have enough money to feed themselves, let alone food for their own children. It is estimated that over one billion people wake upRead MoreCauses And Effects Of Overpopulation1073 Words   |  5 PagesWhat are the effects of overpopulation? Overpopulation is an undesirable condition where the number of existing people on earth exceeds the carrying capacity of the earth. However, overpopulation has not always been a problem. At the dawn of agriculture, 8000 B.C., the population was approximately 5 million. 8000 years later, 1 A.D., the number of people existing on earth was between 200-300 million. That’s a growth rate under 0,05% per year. A tremendous change occurred with the industrial revolutionRead MoreThe Problem Of Overpopulation And Overpopulation872 Words   |  4 PagesHuman overpopulation. Human population can be defined as the condition whereby, the total count of the human inhabiting a certain area exceeds the carrying capacity of the area Bongaarts, (2011). This brings out an issue of the carrying capacity of the region which alludes to the number of individuals who can inhabit a certain area for a given period. It may also be looked at as the situation whereby the available renewable resources in a certain area can satisfactorily support the current populationRead MoreOverpopulation Essay906 Words   |  4 Pagesrate of population growth remains the same, then earth will run out of the land and resources we consume to maintain our lifestyles. The term overpopulation is normally associated with a specific number that represents a large number of people. However, overpopulation is the phenomenon that occurs whenever the environment can no longer sustain the demands of the species that inhabit it and the carrying capacity is exceeded. The carrying capacity is the amount of species that an environment canRead MoreThe Earth s Inadequate Supply Of Natural Resources1274 Words   |  6 PagesMallory York Environmental Science September 10, 2015 The Earth s inadequate supply of natural resources will only be able to tolerate 2 billion humans by 2100, the bad thing about that is, is that the world already feeds and supports 5.9 billion. The ideal human population, or carrying capacity, for the U.S. is projected to be 200 million, which is way fewer than the current population of the United States. This is a growing problem in not only the United States but also around our world today

Monday, December 16, 2019

The Number One Strategy You Should Be Using for Nursing School Application Essay Samples

The Number One Strategy You Should Be Using for Nursing School Application Essay Samples Nursing School Application Essay Samples A nurse leader has to have a number of leadership styles based on the circumstance. Also few sort of patients will need to get excluded for achieving a valid data. Medical assisting is becoming a quite common career and is in pretty significant demand due to a lot of unique explanations. Grad school is amazing. Students lead busy lives and frequently forget about a coming deadline. Only then the students should search for the medical school with an exceptional pre-med advising program. They should be the volunteers in a medical area that will help in the applying to the medical school. You may also find a variety of discounts on our site which will help you to save some more money for future orders or anything you want to spend them on. If you rush, it is going to show. Construction work sometimes takes a toll on your physique. As more Ame ricans have become older and less folks are becoming nurses, preventive care is going to be quite vital later on. Nurses have various motivations for picking their career, but the majority of them state it is their urge to help others. They are in a position to act as client advocates. If you wish to be admitted to nursing school, you are going to have to compose a why I need to be a nurse essay. Alas, many nursing students become caught up in the excitement of more fast-paced nursing career alternatives and never stop to consider the everyday work. To me, nursing is genuinely the most suitable profession. With the projected impending lack of nurses, nursing remains a favorite career choice. Your why can I would like to be a nurse essay must impress your evaluators and make them realize that you've got the potential to be an amazing nurse. One particular common work at home job is nurse coaching for an insurance provider. For some, opting to turn into a nurse is easy. Since you can see, a number of the factors for becoming a nurse aren't quantitative. The Basics of Nursing School Application Essay Samples It's a critical misconception that can cause unsatisfactory outcomes. To get essay online, you merely will need to fill in the application form and you'll get excellent work on the desired topic. After discovering our website, you will no longer will need to bother friends and family with these kinds of requests. More specific details on customer. The Importance of Nursing School Application Essay Samples For instance, if the school demands a lot of health student research, be sure you show how that interests you. The students who really are eager to apply to the great medical school should remember the subsequent Medical School Interview Tips. For example, one reason I chose medical assisting is since there are a lot of available career opportunities and options out there for career advancement within the health care field. There are many diverse opportunities I'll never be required to settle at work. Now you can get genuine college essay online, one that is going to fit your financial plan and get your work done too. After you receive a work done from us you will return again if you need assistance with another one of your essays. If you are searching for assistance with your essay then we provide a comprehensive writing service given by fully qualified academics in your area of study. In order to be sure you'll have this knowledge on you, here are the 8 steps to follow when writing a college application essay and to make certain that it'll be written well. You would like to utilize your essay for a tool to demonstrate why you need to go to their school, versus simply stating why you would like to go there. They are sometimes surprised to demonstrate admission essay samples. For the exact same in the prolonged essay ee, level grading. Is employed in the lengthy essay writing service healthcarehow. So in case you have an essay assigned that you require help with, you can purchase essay online cheap from us. Highlight the things you wish to put in your essay, summarize your own personal story and incorporate your qualifications. The sort of essay you're looking for will be provided to you within the deadline offered to you. You will have a comparative essay.

Sunday, December 8, 2019

Business level strategy IKEA

Question: Discuss about the Business level strategy IKEA. Answer: Introduction IKEA has been operating in the international furniture industry for quite some time. The organization has used its unique strategies to expand its business into various international markets other than the domestic markets in Sweden. The cost-effective and light business processes of the organization have helped it to expand its business successfully in the international markets. IKEA follows its traditional strategies and policies for establishing and operating its business operations in various countries. This research paper focuses on the analysis of the current organizational chart and possible future organizational chart for the organization based on a number of factors. The organizational chart for IKEA is recommended based on the demand of the products and the style of doing business in the corresponding markets along with a number of other micro and macro environmental factors (Gassmann, 2016). Analysis This section of the report analyzes the organizational charts mentioned in the previous section of the report along with the ways in which these can be implemented in IKEA. The recommended organizational chart keeps a number of modules of the existing organizational model same and extends the overall model to add more innovation and creativity capabilities. Stichting INGKA Foundation This foundation is the current owner of INGKA Holding B.V. and will continue playing that role. This foundation is responsible for holding and reinvesting the shares in the IKEA group. This foundation is also responsible to fund various charities through the Stichting IKEA Foundation (Twarowska, 2015). Stichting IMAS Foundation This foundation is currently managing all the financial assets of Stichting INGKA Foundation and will continue doing the same. The foundation will be responsible for making the critical business decisions regarding the financial asset investments and management (Vahlne, 2017). Stichting IKEA Foundation This foundation is the humanitarian counterpart of the Stichting INGKA Foundation and will continue to play the same role. It will be responsible for managing and running the corporate social responsibilities of the entire IKEA group of companies. This foundation will add more number of corporate social responsibilities to its objectives and will ensue that the business image of IKEA is maintained in the societies of operation (Pham, 2016). INGKA Holding B.V. This is the parent company of the IKEA group of companies and will continue to play that role. This is responsible for taking the critical business decisions for IKEA along with the innovation and creativity decisions for the products. This contains both the IKEA group of companies and international group of innovation and creativity as part of its management scope. International group of innovation and creativity This group will be responsible for all the creative and innovative initiative taken in any of the IKEA group of companies. The parent company, INGKA Holdings B.V. will manage the activities of the international group of innovation and creativity. All the innovative and creative suggestions and initiatives will be run through the members of this group before they are pitched to the higher management and the board of directors of the organization (Gummesson, 2014). This group will also be supported by a board of international managers who will be responsible for putting in their opinions and efforts in making the design and manufacturing process of the products innovative and creative. This board of international managers will contain the Swedish managers along with the regional managers working in various retail stores in different countries (Trevisan, 2016). This group also will consist of all the regional research and development teams. These regional RD teams will be responsible for analyzing various factors present in the corresponding markets of operation in order to anticipate the changes in the demand of the customers and the trends in the corresponding markets. The regional RD groups from various countries will be responsible for gathering all the relevant information for the products sold by the organization and the reaction of the customers to those products. This in turn will allow the management of IKEA to understand the ongoing changes in the demand of the products and the trends in the corresponding markets. This group will also contain all the regional marketing teams of IKEA as part of it. These marketing teams will also gather quantitative and qualitative data regarding the performance of the products sold by the organization in the corresponding markets. This in turn will allow the management of IKEA to determine the possible weaknesses of the products along with possible gaps in the manufacturing and design process of the organization. The activities of this group will allow the management of IKEA to introduce more innovation and creativity in the business model of the organization. All of these regional RD and marketing teams will have corresponding managers to manage the employees in the teams (Gassmann, 2015). IKEA group of companies As mentioned earlier, the IKEA group of companies will be managed by the parent company INGKA Holding B.V. which is responsible for taking critical business decisions along with resource management. Each of the companies in the IKEA group will consists of multiple organizational modules, which are mentioned in this section (Soltanizadeh, 2016). International design and manufacturing group Each of the IKEA group of companies will contain this group consisting the international managers and regional groups. The international managers in this group will contain all the Swedish managers of IKEA who will be responsible for taking the critical business decisions on the design and manufacturing process changes for the products sold by the organization. The regional design and manufacturing groups from the retail stores of different countries will pitch in possible changes for the manufacturing and design processes of the products. This group will be responsible for innovating the manufacturing and design process of the products according to the demand for the products and trends in the corresponding markets. International retail group This group will be responsible for the policies and strategies for the retail stores of the organization in different countries and the products sold in those retail stores. The international retail group will consist of the Swedish mangers along with the regional retail group, which in turn consists of the regional managers and employees working in the corresponding stores. The international retail group will allow IKEA to have innovative and creative ways of selling the products in the retail stores across the globe (Friesl, 2017). International customer relationship management group This group will be responsible for the improvement of the customer relationship management strategies implemented by IKEA in various markets. This group will consist of the Swedish managers along with the regional customer relationship management groups, which in turn will contain the regional managers and the customer relationship professionals. This group is responsible for ensuring the high efficiency and accuracy in the customer relation activities, so that the issues and queries of the customers are resolved efficiently (Grant, 2016). International supply chain management group The international supply chain management group will consist of the international managers along with the regional SCM groups. This group ensures that the supply chain activities in various countries are managed efficiently. This group also ensures that the supply chain management activities in the organization are based on various innovative and creative solutions in order to increase the efficiency. Summary statement The recommended organizational chart in this report focuses on keeping a few of the modules intact from the current implementation and extend it to add new modules and features. The new organizational chart will contain all the IKEA group of companies along with the international group of innovation and creativity in the INGKA Holding B.V. parent organization. Each of these companies under the IKEA group will contain international groups for design and manufacture, supply chain management, customer relationship management and retail groups. These international groups will in turn include the regional managers and employees as part of the regional groups and will ensure that the corresponding business processes are based on various innovative and creative solutions (Verbeke 2013). References Friesl, M., Larty, J., Jacobs, C. (2017). Putting strategy into actionThe role of artefacts for business format replication.European Management Review. Gassmann, O., Frankenberger, K., Csik, M. (2016). Innovation Strategy: From new Products to Business Model Innovation. InBusiness Innovation: Das St. Galler Modell(pp. 81-104). Springer Fachmedien Wiesbaden. Gassmann, O., Frankenberger, K., Csik, M. (2015). 7 Innovation Strategy: From new Products to Business Model Innovation1.Business Innovation: Das St. Galler Modell, 81. Grant, R. M. (2016).Contemporary strategy analysis: Text and cases edition. John Wiley Sons. Gummesson, E., Kuusela, H., Nrvnen, E. (2014). Reinventing marketing strategy by recasting supplier/customer roles.Journal of Service Management,25(2), 228-240. Pham, T., Pham, D. K., Pham, A. (2016).From Business Strategy to Information Technology Roadmap: A Practical Guide for Executives and Board Members. CRC Press. Soltanizadeh, S., Soltanizadeh, S., Abdul Rasid, S. Z., Abdul Rasid, S. Z., Mottaghi Golshan, N., Mottaghi Golshan, N., ... Wan Ismail, W. K. (2016). Business strategy, enterprise risk management and organizational performance.Management Research Review,39(9), 1016-1033. Trevisan, E. (2016).The Irrational Consumer: Applying Behavioural Economics to Your Business Strategy. Routledge. Twarowska, K., K?kol, M. (2013). International Business Strategy-reasons and forms of expansion into foreign markets. InManagement, knowledge and learning International conference(pp. p1005-1011). Vahlne, J. E., Jonsson, A. (2017). Ambidexterity as a dynamic capability in the globalization of the multinational business enterprise (MBE): Case studies of AB Volvo and IKEA.International Business Review,26(1), 57-70. Verbeke, A. (2013).International business strategy. Cambridge University Press.

Sunday, December 1, 2019

The Matrix free essay sample

# 8211 ; The Red Pill Essay, Research Paper The film? The Matrix? is filled with philosophical ideas and inquiries. The biggest and most of import inquiry of them all is: ? Which one, the ruddy or the blue pill? ? Given the picks, the ruddy pill would be the most appealing. If the ruddy pill is chosen it will open eyes to a new world ; it will give life a new significance ; and it will give a better apprehension of the universe to the 1 who consumes it. When it comes right down to it, to cognize or non to cognize, that is the implicit in philosophical inquiry. Before the pill, world was merely a image that was painted for the well being of those who lived within it ; nevertheless, after the pill, that image loses it? s camouflage and reveals it? s true design. ? If person explained that everything? seen before was an semblance and that now? world? was really clearer? , how could it be true? Possibly that is best answered by Morpheus in his reply to Neo? s inquiry: ? Why do my eyes hurt? ? , when he replies: ? You? ve neer used them before. We will write a custom essay sample on The Matrix or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page ? In other words, world is right at that place for all to see, its merely that cipher seems to desire to open their eyes and expression. It seems that as people get older, the walls of world narrow, and people believe less and less ; nevertheless, when in childhood, anything is possible, and kids do non close the door on any thought. This is best seen at the terminal of The Matrix when the immature male child sees Neo take off into the air and the female parent tells her boy? Don? T be silly, honey. Men wear? t fly. ? Alternatively, people are happy being the captives of the cave, so to talk. Bing able to get away from the darkness would broaden boundaries and alter the regulations. It would open up doors that were otherwise closed, and let for greater escapade. In taking the ruddy pill, the bars are lifted and psyches are set free to see the new world. In sing a new world, a new significance of life is besides exposed. Throughout clip, people have been in hunt of the significance of life, and all have come up short. Conceivably, this is due to the fact that? The Matrix is the universe that has been pulled over your eyes to blind you from the truth. ? It is impossible to cognize the true significance of life, when one doesn? t truly cognize what life is. As Morpheus says: ? ? there? s a difference between cognizing the way and walking the path. ? In pre-red pill clip, the significance of life is merely a dream, no one truly knows why they exist or what their intent is, they merely think they know. Having the truth exposed, allows for the perceiver to see the design, to see the significance of being. You merely hold to? ? allow it travel, ? fright, uncertainty, and incredulity. Free your head? ? , and allow truth be your usher. Looking in from the exterior, all those within the matrix have but one significance, to power the automaton s ; nevertheless, being on the exterior, a new and much greater significance is uncovered: the significance of endurance. Bing on the exterior is like being portion of an sole nine, ? If you are non one of us, you are one of them. ? The pick is robot or human, and human sort is the minority. Bing a human means that you are contending for the right to be, and contending for the right to be is the significance of life. By cognizing the significance of life, one can besides develop a better apprehension of the universe around them. In developing an apprehension, a pragmatism is brought away with an new and more complex truth. ? What is existent? How do you specify existent? If you? re speaking about what you can experience, what you can smell, what you can savor and see, so existent is merely electrical signals interpreted by your brain. ? Morpheus says? merely? like it is non a large trade, but to understand what causes senses, after being nescient to it for so long, makes it much more than simple. Possibly ignorance is excessively strong, possibly? What you know you can? t explain, but you feel it. You? ve felt it your full life, that there? s something incorrect with the universe. You wear? T know what it is, but it? s at that place, like a sliver in your head, driving you mad. ? If the Good Brahman had been given the chance to take the ruddy pill, he would hold received an apprehension to all th e things that he knew, but couldn? T explain, and were disturbing his head so much. No longer would he? ? live in clip, and? non cognize what clip is? ? ; alternatively, he would populate his life, and cognize why. How great would it be to cognize why things happen, and how things work in the universe? Knowledge is a powerful thing, and people spend all their lives seeking to achieve and retain it. Knowledge and truth are the two most sought after stuffs in the universe. Equally long as one is in the matrix, they will go on to seek for them. By taking the ruddy pill, the possibility of happening those stuffs is present. Bing given such great possibilities, who would even believe? why oh why didn? T I take the blue pill? ? Certain there are greater duties involved, but who could turn down the chance to cognize the truth about world, life, and the universe. The ruddy pill is the lone manner to travel. Possibly? ? ignorance is bliss. ? for some people, but the huge bulk of people would wish to cognize the replies to life? s most asked inquiries, and being outside the matrix is the lone manner to acquire them. BibliographyPlato, The Allegory of the Cave. Keanu Reeves ( as Neo ) , The Matrix, 1999. Laurence Fishburne ( as Morpheus ) , The Matrix, 1999. Unknown ( Mother at terminal of film ) , The Matrix, 1999. Laurence Fishburne ( as Morpheus ) , The Matrix, 1999. Laurence Fishburne ( as Morpheus ) , The Matrix, 1999. Laurence Fishburne ( as Morpheus ) , The Matrix, 1999. Laurence Fishburne ( as Morpheus ) , The Matrix, 1999. Laurence Fishburne ( as Morpheus ) , The Matrix, 1999. Laurence Fishburne ( as Morpheus ) , The Matrix, 1999. Voltaire, Story of a Good Brahman. Joe Pantoliano ( as Cypher ) , The Matrix, 1999. Joe Pantoliano ( as Cypher ) , The Matrix, 1999.

Tuesday, November 26, 2019

How to Write an Outstanding MBA Essay

How to Write an Outstanding MBA Essay The majority of graduate business programs require every applicant to provide at least one accomplished MBA essay as an integral part of the application process. The representatives of the admission boards make use of the essays, together with other application elements, in order to determine whether or not a potential student is a perfect fit for a particular business school. A professionally researched and properly accomplished MBA essays are a great opportunity for you to increase your chances of acceptance as well as to stand out against the background of the other applicants. MBA Essay: What? Why? How? ‘How to write an MBA essay?’ A very typical question if you’re a busy college or university student who has neither solid knowledge in a particular field nor excellent writing skills. If you’re among the unlucky guys who are stuck in the middle of nowhere, we have good news for you – writing an MBA essay is not a difficult task at all! All you have to do to come up with a top-notch MBA essay is to follow the instructions provided below: Research. Before writing a paper, it is highly important to do a thorough research in order to collect all the material needed to complete a good MBA essay for any college discipline be it Psychology, Marketing, IT or Engineering. Complete a strong thesis statement. The second step that you, as the MBA essay author, must take is to provide a clear and brief thesis statement that will inform your target audience about the purpose of your MBA paper. Mind that you have to do that within a single sentence. What is more, the thesis statement should be straightforward and concise. Your tutor shouldn’t experience any kind of trouble while reading and comprehending your thesis statement. Divide your paper into parts. Divide your MBA essay into the body paragraphs and make sure to provide headings where appropriate. Craft an outline. When the question is how to write a good MBA essay, always make certain to use simple and clear language. Before you produce an actual text, it is important to build a strong outline. With the help of a solid scheme, you have an opportunity to create a supreme quality MBA essay that will demonstrate that you’ve done some serious work to come up with the quality piece of writing. Plus, a good outline will help you get a better idea of what points you should add to the essay and which ones should be erased. Divide into sections. The introduction, the body, the conclusion are the must-have for the MBA essay project. Never fail to provide them in your piece since these passages turn your MBA essay into the one that deserves an A+ and inform your tutor about the exceptional writing skills that you have. The intro of the MBA essay is used to introduce the topic that you’re going to discuss and provide a quick and detailed overview of the project. At the same time, the conclusive part of the MBA essay indicates how you respond to a particular problem that you’ve highlighted in your introductive segment and the body of the project. Provide school specifics. Without a doubt, you’d like to demonstrate your knowledge of a certain school. This means knowing and mentioning specific classes or a faculty member that you’re interested in the most. Talk about some organizations on campus that hook your attention. Name your goals and in what way the school can help you get closer to them. The key here is to be clear and specific, writing a story of how you can contribute to the diversity of the class. Be yourself. The representatives of the admissions board are searching for the ways to understand more about a potential student and their unique personality. So, make sure you have something to bring to the university community table! Make certain to tell them what kind of impact you can make. When it comes to the editing, ensure the multiple revisions do not diminish your unique personal voice. This is not just an MBA essay, this is your essay! Now you’re officially provided with everything needed to craft a great MBA essay within the specified deadline. To get more details, feel free to get in touch with the trusted custom essay writing service that provides professional writing assistance 24/7.

Friday, November 22, 2019

Miscellaneous Uses of the Spanish Conditional Tense

Miscellaneous Uses of the Spanish Conditional Tense As a general rule, as explained in our introduction to the Spanish conditional tense, the English would is the equivalent of the Spanish conditional. But there are exceptions. The major ones are listed below: Examples of when the conditional tense isnt translated as would To express speculation about the past: Just as the future tense can be used to express speculation about the present, the conditional can be used to express speculation or probability about the past. A variety of translations can be used, depending on the context. Despuà ©s de trabajar, tendrà ­an hambre. After working, they probably were hungry. Another possible translation is After working, they must have been hungry. (A would translation is also possible: After working, they would have been hungry.)  ¿Dà ³nde estuvo Jorge? Estarà ­a en casa. Where was George? He must have been at home. Another possible translation is Where was George? I wonder if he was at home. (A would translation is also possible: He would have been at home.) Where the conditional poder is translated as could: This is a variation on the would rule, for poder, which when conjugated can mean can, can also be translated as to be able. When could means the same as would be able, the conditional is usually used. Si tuviera dinero, podrà ­a ir al cine. If I had money, I could go to the movies. (This is a use of the conditional based on a condition. It also could be translated as If I had the money, I would be able to go to the movies.) Podrà ­an salir maà ±ana. They could leave tomorrow. (Here the condition is unstated. The sentence also could be translated as They would be able to leave tomorrow.)  ¿Podrà ­a tener un lpiz? Could I have a pencil? (Or, would I be able to have a pencil?) Examples of when would isnt translated as the Spanish conditional When it refers to a past repeated action: In such cases, the imperfect is usually used. This use of would in English is usually understood as used to or as the past tense. Whats different in this instance from cases where would is in the conditional tense is that the activity isnt hypothetical. Cuando era nià ±o, à ­bamos al cine. When I was a boy, we would go to the movies. (This is the same as saying we used to go to the movies or we went to the movies. Going to the movies isnt a hypothetical action.) Mi hijo jugaba con cuidado. My son would play carefully. (This is the same as saying, My son used to play carefully.)

Thursday, November 21, 2019

Cell phone health risk Essay Example | Topics and Well Written Essays - 1750 words

Cell phone health risk - Essay Example h the exposure of electromagnetic fields (EMFs) to human and other organisms, which releases microwave energy that goes into the users hands and head (Szmigielski and Sobiczewska, 353). The EMFs are scientifically known to affect and induce biochemical changes in plants. Further, the exposure to the microwave energy released by the cell phones right on the side of the head has raised concern of a possible change of health status for humans. Nevertheless, other studies have indicated that the levels of exposure to the microwaves are relatively low, such that they may not pose serious health risk to the cell phone users. The findings by the United States Government Accountability Office have concluded that the scientific studies undertaken so far have not shown any adverse effect of the exposure to the Radio-Frequency (RF) energy from the use of mobile phone (GAO, 1). Thus, the major question that arises is; does the use of cell phones pose any adverse health risks to the users? The fact that cell phones emits Radio-Frequency (RF) energy, which is a form of electromagnetic radiation that can be absorbed by the tissues close to where the cell phone is placed is not in contention (LaBerge, 30). However, the point of dispute has been the level of the Radio-Frequency (RF) energy that is released, and its potential to influence the health of the user adversely. One theory has however been developed in regard to why the scientific studies undertaken that far have not been able to prove that there is adverse effects on human health associated with the use of cell phones. According to a scientist, Dr. Devra Davis, the major reason why such research has not been able to prove the relationship between mobile phone use and the development of cancer, is because the development of cancer takes an average of 10 years of mobile phone use to show (LaBerge, 30). Furthermore scientists have observed that the amount of the Radio-Frequency (RF) energy released by a cell phone devise

Tuesday, November 19, 2019

Business law Assignment Example | Topics and Well Written Essays - 1000 words

Business law - Assignment Example t, that certain evidence be not presented or considered legal at the trial because it is believed by the defendant that the evidence has been obtained by the illegal means, generally in  violation  of the  Fourth Amendment  (search and seizure), Fifth Amendment  (privilege  against self incrimination). Advice/Conclusion: If the evidence with regard to bribery has been obtained by illegal means in violation of Fourth/Fifth Amendment, there is a case for suppression of subpoena and the judge may hear and decide a motion to suppress. â€Å"At a hearing on a motion to suppress, the judge may receive evidence on any fact related to the motion. Hearsay is admissible. Evidence Rules 11-1101(D)(1) and 11-104(A).† (JEC, Institute of Public Law) Analysis: Its compulsory to take third party insurance in most of the states in US. Innocent victims who are not responsible for accidents would be covered under third party insurance. The driver of the vehicle pays for the medical expenses with his third party insurance. Question – 3: Rebeccas complaint also alleges that in Rebeccas state there is a law forbidding commercial truck drivers from using cell phones while driving and that Coastal Constructions driver was using a cell phone at the time of the accident. What cause of action does this describe? Analysis: Apart from duty of care arising out of contractual obligations, individuals owe duty of care to strangers as well. An individual or group on performing any activity that harm another, either physically, mentally, or economically, ‘negligence in duty of care’ comes into picture. Taking reasonable care to avoid acts or omissions which a person can reasonably foresee would likely to injure others is the underlying point.   When a person is not responsible for the situation that warranted any incident which resulted into injury to others the person is not liable.   This general principle was established in the land mark case of Donoghue v Stevenson.in the

Saturday, November 16, 2019

Personal experiences Essay Example for Free

Personal experiences Essay My life is one that is full of trivialities. Of course every one has been through hard times but I believe my case is on a different level. However, I am proud to say that my determination led me to overcome life’s obstacles. It all started when I was still in grade school. I have always taken a liking to sports. Even as a girl, I am the sporty type. Whenever there are sports fests, you can always count me in. I wanted it to last forever until I was diagnosed with a heart disease called ‘supraventricular tachycardia’. It’s like all my dreams ended when the doctor explained everything to me. My illness prevented me from engaging in any more sporting activities since my heart since will beat too fast causing me to have breath shortness, chest pains, and dizziness. In extreme situations, it may even cause me to lose consciousness. While it is good that my illness is not life threatening, it did prevent me from doing something that I really love, and this is participating in sports. As I can get stubborn sometimes, I insisted to participate in a badminton tournament in Vancouver. Everything seemed okay as I managed to reach the championships without any trouble despite my medical condition. I thought everything would go well until everything went blank. I woke up in the hospital bed and the last thing I remember was my chest throbbing loudly as I am preparing to hit the shuttle cock quickly coming towards me. My parents told me that I fainted during the championship match. I thought my medical condition would not prevent me from doing what I like. Initially, I thought that this would not be a hindrance but now, I am starting to realize that I may be wrong and I will forever be procrastinated in the world of sports. In spite of these trivialities, a small glinting ray of hope remains inside of me. I believe that I would again see myself in a badminton court filled with spectators in a championship match against the best in the district. My life has never been the same after these events. School became difficult. I could not face everything in a steadfast manner just like I used to. Everything was falling apart since I was restricted from doing the things I want to do. I later found myself in a state of depression and anxiety which resulted in me performing poorly in school. My parents got extremely worried but even as I do not want them to worry, I cannot pretend that everything is all right when it is not. Everything in my life is in shambles until that day, that very special day. I, with my mother, went on my regular visit with our family doctor and the doctor reported that my condition is getting better. Then out of nowhere, the doctor uttered, â€Å"I have a colleague who might be able to cure you. † I just replied with a smile but the small glinting ray of hope inside me sparked brighter. If this treatment becomes successful, then my limitations would be gone and I can again participate in sports. Time came for my surgery, I was excited yet anxious. As I lie down on the operating table, I’m thinking, â€Å"After this, I can go and claim that badminton championship title that should have been mine a few years back. † The anaesthetics were injected and I slowly fall in a deep slumber. The next thing I know, I was greeted by my mother in the hospital bed a few hours after the operation. I asked, â€Å"How’d it go? † â€Å"It went fine dear,† my mother responded. â€Å"Can I play badminton again? â€Å"We’ll have to wait for the doctor’s confirmation on that. You just rest for now,† she smiled while exuding a calm aura. The next thing I know, it was like the scene from a few years back. I am in a badminton court filled with spectators. It is the championship match and my opponent is in front of me. I see the shuttle cock coming quickly towards me. This time, I didn’t wake up in the hospital bed. I returned the shuttle cock to the other side of the court just like how a real pro would do it. I emerged victorious and as I hold the trophy, I am thankful that I did not lose hope. Even as I have experienced trivialities that would convince other people to give up, I did not give up all hope until the perfect opportunity came for me. Since then, everything has been in order. I can participate in sports all I want and my studies are now doing well. My next goal is to get a degree in the school that I want all the while participating in sporting competitions. I am proud to say that despite being down at some point, I never lost sight of my goals. Even as health became an issue I still tried to go for it. And even as I have failed the first time, I waited for an opportunity to go at it again.

Thursday, November 14, 2019

Alternative Fuel for Airplane Essay -- Energy, Sustainable Fuel

One of the most significant current discussions in sustainable aviation is alternative fuel for airplane, which is a serious argument; however, big question is that efforts to produce a more sustainable fuel to power aircraft are technically and ethically feasible. This paper going to investigate and show there is no alternative fuel to power aircraft in this time. The fuel using by airplane is fossil fuel, which is Jet A1 by burning this fuel there are impact on the global warming the researcher investigate what is the problem with fossil fuel (Jet A1). As solve the fuel problem there are several alternatives have tested, that some of them are biofuel, Liquid Hydrogen, Fracking for Natural Gas and scher-Tropsch (F-T) fuels from fossil feedstocks. However to fund out the alternative fuel is sustainable .firstly defined term sustainability. There are numerous definitions for the word sustainable. White (2001, p.1) states that sustainability seeks to provide the best outcomes for the human and natural environments both now and into the indefinite future. In addition, Thompson and Sorvig( 2009) in their recent research paper found probably the simplest, widely used definition of sustainability is meeting the needs of today's population with-out diminishing the ability of future populations to meet their needs. The other hand Fresco and Kroonenberg (1992) states that the sustainability of natural ecosystems defined as the dynamic balance between natural inputs and outputs, modified by external events such as climatic change and natural disasters. (Bell and Morse, 2008) the researcher from all research fund out that the sustainability related what is human put the nature has to be try to have balance ever aspect and impact to natu... ...ccessful in aviation industry such as biofuel, Liquid Hydrogen, Fracking for Natural Gas and scher-Tropsch (F-T) fuels from fossil feedstocks. All the fuel has been test and some of the, has been used for long time but the all of the have got impact on environment and social which make unsustainable fuel. At last with those fuels CO2 emissions is not increasing and LH2 approximately putting three times the amount of water in the atmosphere than burning kerosene-type aviation fuel, which is water washes out of the atmosphere a lot faster than carbon dioxide that stays up for years. Fracking presses the water containing the tracking chemicals left underground to fill the spaces in the fractured rocks and may eventually flow into the local ground-water system, making it unsafe for drinking. This research show there is no alternative fuel in this time and technology.

Tuesday, November 12, 2019

Comparing and contrasting lease versus purchase options Essay

It is important to know the difference between lease purchase and lease option. The use of leases can also have an impact on a company’s liquidity profitability ratios (Schroeder, Clark, & Cathey, 2005). First the organization should study the expenses of what it would cost to lease as to what it cost to purchase this can be done with a reduced cash flow evaluation. The study would compare the expense of the alternatives by taking into account the scheduling of payments, tax benefits, and interest rates on any loans, and other financial arrangements. To make an evaluation, the company has to be sure about the financially viable lifespan of equipment, this would also include the salvage value and depreciation of such equipment. Here is a brief description of what debt financing is referred as. Debt financing is when money is borrowed by an organization and has to be repaid back with interest. Debt financing does dilute the ownership of the company. Debt financing can be looked at as either a long-term debt or short-term debt. Two examples of debt financing are the issue of Bonds and a Line of Credit. Line of Credit is a bank loan where a company can draw out funds when times are slow, and money is needed. Bonds can be issued as form of debt financing. Bonds are usually long-term and come with a maturity ranging from seven to 30 years. These bonds are usually underwritten by a bank or securities firm who assist in the sales of these bonds. Equity financing is another method of raising money by selling company stock to outside investors. In return for their interest in buying stock, the shareholder receives ownership interest in the company. An advantage to using debt is that the debt helps to produce and hold greater investment returns for the company’s equity holders. When using debt financing the primary advantage is that it allows the founders to hold ownership and control of the company. The disadvantage to this is that it  requires smaller business to make monthly payments of both principal and interest. The use of capital structure depends on what a company can afford some small companies cannot afford debt financing like larger corporations. I think equity financing is a good way for smaller companies to raise capital because the owner can still hold on to control and raise money at the same time. Reference Schroeder, R.G., Clark, M.W., & Cathey, J.M. (2005). Financial Accounting Theory and Analysis (8th Ed.). Hoboken, New Jersey: John Wiley & Sons.

Saturday, November 9, 2019

Religion Over Culture? Essay

I love Hawai’i. I don’t love Hawai’i just for its everlasting sunshine, unique cuisine, or historical landmarks. My love for Hawai’i runs deep because of the vast diversity we have here. There is no place like Hawai’i—it is the melting pot of all cultural groups and religious affiliations who have found a home in the islands. It’s within this melting pot that the aloha spirit really shines through, really making it the perfect vacation destination. I am the epitome of that melting pot being that I have 14 nationalities. Although I come from many different backgrounds, I firmly believe and try to perpetuate my Hawaiian culture and my Christianity. Truly being a Hawaiian Christian is probably the hardest person to be because of its confliction between the belief in many gods in a Hawaiian sense and its cultural actions to believing in one God as a Christian. But I consider myself a Christian Hawaiian because I have faith in my God and persistence in my culture. As a Hawaiian, I am all about perpetuation. Our culture had been almost lost once so I believe in keeping it alive forevermore. Some may argue that to be â€Å"Hawaiian† you must be of Hawaiian birth, speak ‘Å lelo Hawai‘i[1], or be a Hawaiian practitioner just as the kÃ… «puna[2] of ancient Hawai’i. If a person is willing to genuinely respect, practice, and perpetuate a culture, it should be enough for them to be considered a part of said culture. In my Hawaiian Language class, it is my responsibility to start oli[3] and pule[4], which is proper protocol at Kamehameha Schools. With this responsibility, I essentially start the class. I say my prayers, but in the language of my people so that I honor both sides. This privilege is one that not all schools can say that they do. For that, I am thankful to have been accepted to a school that allowed me to express both my culture and religion where they can both co-exist in harmony. If I went to a school where I couldn’t express either, I know I would be an entirely different person. It’s this expression of culture and religion that really allowed me to understand not only my values but others as well. With that in mind, to a college community, I can bring to the table my Christian and Hawaiian values. I am a Hawaiian, but with a western mind. I wouldn’t put my religion over my culture or vice versa because both mean a great deal to me as they shaped me to be the person I am today. He Hawai‘i au, mau a mau [5] and a Christian.

Thursday, November 7, 2019

The Nucleus - Definition, Structure, and Function

The Nucleus - Definition, Structure, and Function The cell nucleus​ is a membrane bound structure that contains the cells hereditary information and controls the cells growth and reproduction. It is the command center of a eukaryotic cell and is commonly the most prominent organelle in a cell. The Cell Nucleus You can think of the cell nucleus as a kind of command center containing all the chromosomal and genetic information needed for the reproduction of life. Distinguishing Characteristics The cell nucleus is bound by a double membrane called the nuclear envelope. This membrane separates the contents of the nucleus from the cytoplasm. Like the cell membrane, the nuclear envelope consists of phospholipids that form a lipid bilayer. The envelope helps to maintain the shape of the nucleus and assists in regulating the flow of molecules into and out of the nucleus through nuclear pores.  The nuclear envelope is connected with the endoplasmic reticulum (ER) in such a way that the internal compartment of the nuclear envelope is continuous with the lumen of the ER. The nucleus is the organelle which houses chromosomes. Chromosomes consist of DNA, which contains heredity information and instructions for cell growth, development, and reproduction. When a cell is resting i.e. not dividing, the chromosomes are organized into long entangled structures called chromatin and not into individual chromosomes as we typically think of them. Nucleoplasm Nucleoplasm is the gelatinous substance within the nuclear envelope. Also called karyoplasm, this semi-aqueous material  is similar to cytoplasm and is composed mainly of water with dissolved salts, enzymes, and organic molecules suspended within. The nucleolus and chromosomes are surrounded by nucleoplasm, which functions to cushion and protect the contents of the nucleus. Nucleoplasm also supports the nucleus by helping to maintain its shape. Additionally, nucleoplasm provides a medium by which materials, such as enzymes and nucleotides  (DNA and RNA subunits), can be transported throughout the nucleus. Substances are exchanged between the cytoplasm and nucleoplasm through nuclear pores. The Nucleolus Contained within the nucleus is a dense,  membrane-less structure composed of RNA and proteins called the nucleolus. The nucleolus contains nucleolar organizers, which are parts of chromosomes with the genes for ribosome synthesis on them. The nucleolus helps to synthesize ribosomes by transcribing and assembling ribosomal RNA  subunits. These subunits join together to form a ribosome during protein synthesis. Protein Synthesis The nucleus regulates the synthesis of proteins in the cytoplasm through the use of messenger RNA (mRNA). Messenger RNA is a transcribed DNA segment that serves as a template for protein production. It is produced in the nucleus and travels to the cytoplasm through the nuclear pores of the nuclear envelope. Once in the cytoplasm, ribosomes and another RNA molecule called transfer RNA work together to translate mRNA to produce proteins. Eukaryotic Cell Structures The cell nucleus is only one type of cell organelle. The following cell structures can also be found in a typical animal eukaryotic cell: Centrioles - help to organize the assembly of microtubules.Chromosomes - house cellular DNA.Cilia and Flagella - aid in cellular locomotion.Cell Membrane - protects the integrity of the interior of the cell.Endoplasmic Reticulum - synthesizes carbohydrates and lipids.Golgi Complex - manufactures, stores and ships certain cellular products.Lysosomes - digest cellular macromolecules.Mitochondria - provide energy for the cell.Ribosomes - responsible for protein production.Peroxisomes - detoxify alcohol, form bile acid, and use oxygen to break down fats.

Tuesday, November 5, 2019

A Collection of Famous Quotations About Time

A Collection of Famous Quotations About Time Time and tide await none. The powerful tide of time overpowers everything: kingdoms fall, evil dies, relationships change, seasons wither, and the new sun rises. Here is a collection of famous time quotes. Remember that time is money. -Benjamin FranklinNever leave that till  to-morrow  which you can do  to-day. -Benjamin FranklinDost thou love life? Then do not squander time, for that is the stuff life is made of. -Benjamin FranklinAs though a rose should shut and be a bud again. -John KeatsYears of love have been forgot in the hatred of a minute. -Edgar Allan PoeKeeping time, time, time, In a sort of Runic rhyme, To the tintinnabulation that so musically wells, From the bells, bells, bells. -Edgar Allen Poeï » ¿The worlds a bubble, and the life of man, less than a span. -Francis Bacon Histories make men wise; poets, witty; the mathematics, subtle; natural philosophy, deep; moral, grave; logic and rhetoric, able to contend. -Francis Bacon Sweet childish days that were as long as twenty days are now. -William Wordsworth Can anybody remember when the times were not hard and money not scarce? -Ralph Waldo EmersonLife is not so short but that there is always time enough for courtesy . -Ralph Waldo Emerson For he lives twice who can at once employ, The present well, and even the past enjoy. -Alexander Pope ï » ¿Tis with our judgments as our watches- none go just alike, yet each believes his own. -Alexander Pope ï » ¿To me every hour of the light and dark is a miracle, every cubic inch of space is a miracle. -Walt Whitman

Sunday, November 3, 2019

How will professional organizations play a role in your professional Assignment

How will professional organizations play a role in your professional life as Network System Administrator - Assignment Example IEEE is also involved in accreditation of professional courses in computing and engineering (IEEE, 2014). ACM and IEEE are two professional organizations that have some great impact on the life of a professional network systems administrator. In computer networking, IEEE 802 is a standard that governs local and metropolitan area networks. The standard defines a set of services and protocols that need to be adhered to in day to day networking thus being an indirect effect to the daily life of a network systems administrator. A more direct responsibility of IEEE to network administration is through membership. The memberships assist the relevant professionals with relevant technology updates. Such updates assist the technician in keeping at bay with any technological improvements relevant for proper maintenance and possible upgrade of their work stations. ACM is directly responsible for the advancement of computing profession through delivery of resources to members thus enabling professional development. ACM has a vast library of resources that serves the members with relevant publications, journals, magazines, workshops and forums. Such materials are very essential for an up to date trending with the current technology. For a network administrator, such information will help him minimize the major threats affecting the work environment, as well keep at pace with any emerging trends that might act to boost the efficiency of the systems under their power. The professional organizations are also responsible for assisting the network administrators as well as other similar professionals with a standard code of ethics that acts as a necessary guide in their routine. A clear code of ethics is requisite in any vocation as it guides the users on what to do and what to steer clear of in order to maintain responsible workmanship. The professional organizations are also protective to workers in legislative and other legal

Thursday, October 31, 2019

Privacy Essay Example | Topics and Well Written Essays - 1250 words

Privacy - Essay Example ual’s wish to remain obscured or relatively unnoticed from the public and security which can also be achieved by privacy in reference to the protection of information. Its importance has also been an issue that has been discussed on a large scale with relevance to how important it is for the existence of privacy within the society (Wack, 2010). An invasion of privacy refers to the intrusion of ones personal matters or the revelation of information to the public that an individual would have rather kept secret or away from the public eye. This invasion of privacy is the main opponent that individuals face in the fight to withhold information that they may not want others to know. There are a number of scenarios where privacy is upheld and it does not just deal with an individual on a personal level. There are different types of privacy that ca n be considered according to the particular situation that is being faced at that particular time. The types of privacy include: Personal Privacy – This type of privacy refers to an individual on a personal level where it is one person is involved. This usually has to do with the exposure of a person’s body to others. For example, a person usually prefers to be alone in certain situations such as taking a bath or changing their clothes because they would not like a person to see them in a state of undress (Solove, 2009). This can also be referred to as personal modesty. There is also the issue of privacy in terms of living conditions and relationships with those who may live next to you. This can be seen in the walls and fences that are erected around an individual’s personal property in a bid to maintain their coming and goings private (Wack, 2010). There is also the concept of curtains that are erected on windows to prevent people from being able to see inside a house. Personal privacy has always been in existence since the formation of societies as individuals have always wanted to keep certain aspects of their

Tuesday, October 29, 2019

Summary response paper Essay Example | Topics and Well Written Essays - 500 words - 2

Summary response paper - Essay Example in Durham Regional Hospital where educational events were held for the purposes of instructing the hospital staff on the aims of RRT as well as the criteria for calling a rapid response. Further, the critical care unit (CCU) got trained on ways of assisting floor nurses asses and stabilize patients as well as on the means of communicating with physicians through Situation, Background, Assessment and Recommendation (SBAR) method (Critical Care Nurse, 1). After education and update of policies, the RRT process was implemented and then later evaluation and review of the outcomes of the process. The review results indicated that the Rapid response calls had a significant increase while a decrease in the number of code blue calls. The findings facilitated the creation of action plans with a focus on safety and education. Additionally, according to the findings of the survey, there should be supplies that lead to standardized box placed at the bedside of every RRT call. Consequently, staff and patient satisfaction was on the rise as outcomes improved (Critical Care Nurse, 1). The aim of the program is to advocate and initiate enteral nutrition for critically ill patients within 24 to 48 hours as means of improving outcomes (Critical Care Nurse, 1). Feeding into stomach normally leads to suboptimal enteral intakes due to the feedings being held for gastric residual volumes (GRV) or can also lead to patient intolerance due to ileus. The shared governance committee decided upon the use of an Electromagnetic Placement System (EMPS) to achieve safe enteral access beyond the pylorus. Postpyloric feeding is advantageous since it leads to greater enteral nutrition delivery to patients, as there are minimal interruptions of feeding (Critical Care Nurse, 1). Collaborative efforts also led to the establishment of a training program together with hands – on opportunities for bedside placement of the tube by the nurse. Furthermore, additional online support was availed on the

Sunday, October 27, 2019

Addition to Pain Medication: Causes, Effects and Treatments

Addition to Pain Medication: Causes, Effects and Treatments Pain Medication Addictions Angelia Holland People are going to the doctor when they are nothing wrong with them to get a prescription for pain pills. People are getting more and more addicted to prescription pain pills. When doctors do not prescribe them a prescription because they suspect that are abusing the pills, then they will buy them for someone. These pills will not stop when they have an addiction sometime they abuse it so bad that they overdose because they mix pills together and do not know the outcome will be. However, pain pills misuse is a common thing now then it was in the past. No one decides to get addicted to prescription pain pills. Alienating family and friends, failing at work, and launching a small-time criminal career arent what anyone plans on when they swallow their first pain pill. One in five Americans report misusing a prescription drug at least once in their lifetime, but the overwhelming majority put the pills away with no lasting harm. So how does prescription painkiller abuse progress to full-blown opioid addiction? It typically starts with a visit to the doctor for a backache or to dull pain after surgery, an accident or a sports injury. It ends with addiction. Misuse of prescription painkillers is on the rise, and experts say increasingly, its killing us (Shamus, 2013). Healthcare providers have long wrestled with how best to treat patients who suffer from chronic pain, roughly 116 million in this country. No special training, skill, effort or techniques are required for pain management when using narcotic painkillers. You simply take a pill and soon afterward, the pain you were feeling is reduced or eliminated. The fact that these painkillers work well with little effort makes them the first choice for pain management for many people. Rather than exploring other ways of managing pain, which take effort and may not eliminate pain to the same extent as the painkillers, people reach for the pill bottle each time pain relief is required. The ease of use and effectiveness it brings may lead some to reach for the drugs more often than is safe or necessary. While it may not be the first reason that people take such painkillers, most notice that while they are under the influence of these drugs, they are distanced from their emotional pain. Painful emotions are a part of everyday life for all of us, but often we can manage these feelings on our own or with professional help, such as counseling. However, people in physical pain have often suffered emotional trauma and are more vulnerable to the attractions of a pill that just makes it all go away. Over time, people come to depend on their prescription painkillers to manage their negative emotions. Painkillers can be pleasurable. Opioids, in particular, have a side effect of euphoria. This is similar to the pleasure felt when you have been successful or after intense physical excitement, but it requires no such effort to attain. As people who are in pain have typically suffered an unpleasant experience that caused the pain, the pleasurable effects of these painkillers can seem like a delightful surprise. Seeking repeated experiences of pleasure through the addictive behavior or substance is one of the hallmarks of addiction. People with physical pain are often very tense. Because many painkillers, such as Demerol, induce physical relaxation, they can provide welcome relief from tension while under the influence. After a while, people can come to rely on painkillers that have this effect to provide relief from tension and the added pain that tension causes. Tolerance builds up quickly. Opioids can quickly cause tolerance to occur. As a result, people who regularly take these painkillers find that they need to take higher and higher dosages of the drug they are on in order to get the same effect. In addition to physical tolerance, people develop psychological tolerance as they become desensitized to the effects of the drug. Tolerance is one of the key signs that addiction is developing. Often, people who are becoming addicted to narcotic painkillers believe they need more of the drug because their pain is getting worse. But the worsening is often a result of the painkiller use itself. The ups and downs of a developing addiction because physical behaviors such as overuse of an injured part of the body, poor posture resulting from a lack of sensation when in positions that would otherwise be uncomfortable, and a lack of moderate exercise that would otherwise strengthen the weakened area (Hartney, 2011). Instead of correcting these bad habits, the person will often just take more painkillers, creating a vicious cycle of physical neglect being concealed by the effects of the drugs. As people become addicted to painkillers, they experience withdrawal when the drug wears off. Withdrawal is very unpleasant, and it often feels like an intensifying of the very symptoms the person was trying to escape through taking the painkillers. Pain, digestive problems and feelings of being generally unwell are common. As soon as the drug is taken, the unpleasant withdrawal symptoms disappear, and the person feels relieved of pain, relaxed, and free of tension and emotional distress. Over time, the person will choose to manage withdrawal symptoms through regularly taking more painkillers, sometimes without even realizing the withdrawal symptoms are caused by the drug itself (Hartney, 2011). The physical signs of addiction. Many times, painkiller addicts do not recognize the signs of their addiction until their behavior is pointed out to them. Painkillers can cause slurred speech and depression that they often attribute to other causes. Other physical symptoms of painkiller addiction include the inability to concentrate, lack of coordination and dizziness. Health care providers often recognize the symptoms because of declining blood pressure levels and slow, labored breathing. Narcotic painkillers also produce constipation. In addition to the obvious physical signs that result in unusual behavior, people who are addicted to painkillers begin to exhibit other behaviors inconsistent with their usual habits. Students often begin to find more reasons to stay home from school and start to receive falling grades. Lethargy and reduced energy levels are very common to painkiller addicts and are especially notable when they were previously considered active and enjoyed physical activities. Appearance becomes less important to addicts, and they may begin to have money troubles that lead them to ask for loans and get behind in their bills. As a painkiller addict withdraws from the drugs, the signs of addiction become more apparent. The National Institutes of Health reports that withdrawal from opioid painkillers brings on bone aches, chills, insomnia, diarrhea and vomiting. Involuntary leg movements, restlessness and muscle pain also may be present. People withdrawing from painkillers should be medically supervised during the first few days of treatment because the symptoms can be life threatening. Withdrawal from sedatives and tranquilizers can cause convulsions. Before taking pain medications, do your research Miotto of WebMD explains: â€Å"Weigh Your Risk Factors A history of addiction to prescription medicine or illicit drugs. Addiction to alcohol or tobacco. Family history of addiction. A history of mood disorders (such as depression or bipolar disorder), anxiety disorders (including PTSD), thought disorders (such as schizophrenia), and personality disorders (such as borderline personality disorder). Look at Other Options Physical therapy. Working with a psychologist to learn how to change your pain-related thoughts and behaviors. Alternative approaches such as acupuncture and tai chi. Those methods arent just for people who are at high risk for addiction. Theyre part of an overall pain management strategy that may include, but is not limited to, medications. Use the Medication for Its Proper Purpose If your doctor writes you a prescription that makes your pain more tolerable, and youre using it as directed, thats OK. But if youre using it for some other reason that your doctor doesnt know about, thats a red flag. For example, if you hate your job and youre taking the drug because you find it takes the edge off, thats a sign that you could develop a problem, says Karen Miotto, MD, an addiction psychiatrist at UCLA. Here are four warning signs that you may be misusing your prescription painkiller: Youre not taking the drug as prescribed. Youre taking the medicine for reasons other than why the doctor prescribed it. Your use of the drug has made you miss work or school, neglect your children, or suffer other harmful consequences. You havent been honest (with your doctor, loved ones, or yourself) about your use of the drug. Your doctor should work with you to limit addiction risk. She may ask you about how youre doing, give you a urine test to check for medication, and ask you to bring in all your medications so she can check how many are left and where the prescriptions came from. â€Å"If you feel like youre losing control over your pain medicine use, or if you have questions about whether youre becoming addicted to it, you may want to consult a doctor who specializes in pain medicine. He or she should listen to your concerns without judgment and take a reasoned approach. For instance, if she thinks you need to get off a certain drug, she might look into switching you to another drug with less potential for misuse. If your doctor isnt comfortable handling your situation, consider getting a second opinion from a psychiatrist or addiction specialist,† Miotto says. Pain-relieving drugs can lead to problems other than addiction. Keep opiates locked away so kids, teens, and others in your home cant take them. And be extra-cautious using other prescription and over-the-counter drugs along with opiates. Certain combinations could cause you to become unconscious, stop breathing, and even die (Miotto, 2012). Thousands of Americans rely on prescription painkillers for the relief of pain and discomfort from ailments such as headaches, menstrual cramps, surgery recovery or lingering pain from an injury. Unfortunately however, for many, this reliance on medication can easily and unknowingly turn into physical dependence. The scary fact is that the most commonly prescribed drugs including OxyContin, Vicodin, Methadone, Darvocet, Lortab, Lorcet and Percocet, while offering relief from pain, can also cause individuals bodies to start needing the drugs in order to feel normal, and the result is the new, even more challenging situation of chemical dependency Prescriptions to pain medication can be safe when taken according to the doctors instructions and are carefully monitored. However, it is important to recognize that they can also be very dangerous. Remember that dependency is a disease that can exhibit itself to even the most cautious individual. Therefore, anyone who is prescribed pain medications should take extra precautions to avoid the debilitating effects a dependency can have and watch for the warning signs (Bernstein, 2013) Celeste Vaughan states it correctly when she describes addiction, â€Å"When addiction takes control, Satan has a wide-open gate to enter and set up residence in your brain. He is the great justifier of all actions. He will provide you with excuses for the actions above to make you deny your addiction. The thoughts that you used to control now have a new pilot behind the wheel. And a sneaky one at that. If you do consider getting help, he will get inside your head and tell you all kinds of horrible things. Thinks like†¦No one will understand. Everyone will thing you’re weak. Friends will ever trust you again. Your husband will want a divorce. Your kids will be ashamed of you. And the worst one of all†¦If God truly loves you, he wouldn’t have let you get into this mess in the first place†¦Ã¢â‚¬ ¦.. You are on a journey — possibly the most difficult of your life. Don’t let anyone tell you that addiction is impossible to overcome. I’m p roof it’s completely possible. After all, with God, all things are possible.† The disease of addiction affects over 23 million Americans. It is a disease that has no cure, and that, as a society, we have just begun to understand. Help fight the stigma that an addict faces by learning all you can about this disease and its affects. The physical aspects of opioid dependency improve after detox. But psychological addiction, temptation, and craving can last for years, even a lifetime. The truth is, most people will relapse on their way to full recovery from prescription drug addiction (Johnson, 2012). Staying on the path to health takes patience, loving relationships, and emotional resilience. People in drug abuse recovery need all the help they can get. Fortunately, tools and resources are available to help someone stay straight, and to pick them up if they stumble. â€Å"Consider it pure joy, my brothers and sisters, whenever you face trials of many kinds, because you know that the testing of your faith produces perseverance. Let perseverance finish its work so that you may be mature and complete, not lacking anything.† (James 1:2-4 NIV) References Clifford M.D., of The Waismann Institute. 10/6/2003. Retrieved from http://www.medicinenet.com/script/main/art.asp?articlekey=24572 Hartney, Elizabeth PhD. February 20, 2011. Retrieved from http://addictions.about.com/od/substancedependence/tp/painkillers.htm Johnson, Kimball, MD. August 02, 2012. Maintaining Hope and Health during Drug Abuse Recovery. Retrieved from http://www.webmd.com/mental-health/drug-abuse-recovery-maintaining-hope-and-health?page=2 Miotto, Karen, MD, professor of psychiatry and bio behavioral sciences, UCLA.. 2012. Pain Medication: Are You Addicted? What to know about becoming addicted to pain medications. Retrieved from http://www.webmd.com/pain-management/features/pain-medication-addiction?page=2 Shamus, Kristen Jordan. October 20, 2013. Pain pills can be prescriptions for addiction, death. Retrieved from http://www.usatoday.com/story/news/nation/2013/10/20/painkiller-overdoses-addiction/3107879/ Vaughan, Celeste. November 5, 2012. Biblical Christian help for drug addiction. Retrieved from http://drug.addictionblog.org/biblical-christian-help-for-drug-addiction/

Friday, October 25, 2019

Essay --

Willie Breslau Professor Pollak COML 1109 11/27/13 â€Å"Reluctance† by Robert Frost An extended metaphor of a road, that represents the mans life and journey he has taken, runs throughout Robert Frost’s poem â€Å"Reluctance†. The title and the last line help to break through the metaphor and understand the meaning behind it, as Frost deliberates humans’ hesitation to accept change and the inevitability of a natural end, whether of â€Å"a love or a season†. â€Å"Reluctance,† along with several other Frost poems, focuses on the change of seasons and how the narrator reacts to that change. However, while each narrator of â€Å"Reluctance†, â€Å"Spring Pools†, and â€Å"Nothing Gold can Stay† display different emotions about the seasonal changes they witness, they all display humans hesitation to except change and to hold onto what they have in the present. The sketch that I drew for this poem has a man who looks withered from travel with a long beard and wrinkled skin walking alone on a â€Å"highway†. Behind the narrator, I drew a small globe to represent that he is now returning from his travels around the world and in front of him a small town labeled home. Around the man stands on the highway are trees that have lost most of their leaves and leaves that are being blown on the snow covered ground. Other plants are drawn with fleeting life, as winter seems to be coming if not already here. â€Å"Reluctance’ consists of five stanzas each having six lines. The meter of the poem is tricky. In Frost terms, this poem could be considered to be in loose iambic trimeter, but would be more aptly described as trimeter. One interesting feature of this poems meter is that the last line of each stanza switches from trimeter to dimeter. Each stanza consists of the rhyme sc... ... In all three poems, change is represented as a transition between seasons with the narrator being enthralled by the present and not wanting time to change what they have. In â€Å"Reluctance† the seasons are more than actual seasons as the display a turning point in the narrators where he must decide to embrace change or follow his heart. In â€Å"Spring Pools† and â€Å"Nothing Gold Can Stay† the narrators both emphasize the short-lived beauty of nature because of the change in seasons and want so desperately the delay that change. However, both narrators almost reluctantly come to the conclusion that change can bring more beauty but are worried to lose what they have in the present. Frost’s mastery of poetry, nature, and human behavior are beautifully intertwined in these poems to create powerful messages that will continue to be relevant as mankind struggles to accept change.

Thursday, October 24, 2019

Reardon v. U.S. Essay

Lien on real property created by CERCLA when Environmental Protection Agency (EPA) determines that property owners may be liable for cleanup costs amounts to deprivation of a significant property interest within meaning of the due process clause. Comprehensive Environmental Response, Compensation, and Liability Act of 1980,  § 107(l ), as amended, 42 U.S.C.A.  § 9607(l ); U.S.C.A. Const.Amend. 5. Absence of notice and hearing may be justified by exigent circumstances. U.S.C.A. Const.Amend. 5. 92k251.5 k. Procedural Due Process in General. Most Cited Cases Constitution allows the process due to be tailored to fit realities of the situation. U.S.C.A. Const.Amend. 5. *1510 Lynn Wright, with whom Robin F. Price and Edwards and Angell, New York City, were on supplemental brief, for plaintiffs, appellants. George W. Van Cleve, Deputy Asst. Atty. Gen., with whom Barry Hartman, Asst. Atty. Gen., Washington, D.C., Wayne A. Budd, U.S. Atty., George B. Henderson, II, Asst. U.S. Atty., Boston, Mass., Stephen L. Samuels, Steve C. Gold, Jacques B. Gelin, Attys., Dept. of Justice, Charles Openschowski, Office of Gen. Counsel, E.P.A. and Luis Rodriguez, Asst. Regional Counsel, E.P.A., Washington, D.C., were on supplemental brief, for defendants, appellees. OPINION EN BANC TORRUELLA, Circuit Judge. After removing hazardous substances from property belonging to the Reardons, EPA filed a notice of lien on the property for the amount spent. See 42 U.S.C.  § 9607(l ). The Reardons sued to have the notice of lien removed, arguing that they were not liable for the cleanup costs, that the lien was  overextensive in that it covered parcels not involved in the clean-up, and that the filing of the lien notice without a hearing deprived them of property without due process. The district court, in Reardon v. United States, 731 F.Supp. 558 (D.Mass.1990), decided that it did not have jurisdiction to hear the Reardons’ two statutory claims. It ruled that although jurisdiction existed to hear the constitutional claim, the filing of a lien did not amount to a taking of a significant property interest protected by the due process clause. It therefore denied the Reardons’ motion for a preliminary injunction, and dismissed their complaint. The Reardons appealed and a panel of this court ruled in their favor on statutory grounds. Reardon v. United States, 922 F.2d 28 (1st Cir.1990) (withdrawn). We now consider the appeal en banc. After closely considering applicable law, including most notably the recent case of Connecticut v. Doehr, 501 U.S. 1, 111 S.Ct. 2105, 115 L.Ed.2d 1 (1991), we conclude that the district court correctly decided that it did not have jurisdiction to consider the Reardons’ statutory claims, but we find that the CERCLA lien provisions do violate the fifth amendment due process clause. I. BACKGROUND A. Facts. In 1979, Paul and John Reardon purchased a 16-acre parcel in Norwood, Massachusetts, adjacent to an electric equipment manufacturing plant site *1511 known as the â€Å"Grant Gear† site, and named it â€Å"Kerry Place.† In 1983, the Massachusetts Department of Environmental Quality Engineering, responding to a report of a nearby resident, tested soil samples from both properties and discovered extremely high levels of polychlorinated biphenyls (â€Å"PCBs†) on the Grant Gear site and on Kerry Place where it bordered Grant Gear. EPA then investigated the site. Finding the same high levels of PCBs, it authorized an immediate clean-up of the contaminated areas. Between June 25 and August 1, 1983, EPA removed 518 tons of contaminated soil from the two properties. It then notified the Reardons that it had removed all soil with concentrations of PCBs known to be above the safe limit, but informed them that additional areas of contamination might exist, in whi ch case EPA might undertake additional clean-up work. In 1984, the Reardons subdivided Kerry Place into a number of parcels; they sold five of those parcels and retained ownership of the others. In October 1985, EPA notified the Reardons that, as current owners of Kerry Place, they might be liable under  §Ã‚ § 106  and 107 of the Comprehensive Environmental Response, Compensation, and Liability Act (â€Å"CERCLA†), 42 U.S.C.  §Ã‚ § 9606 & 9607, along with ten other present and prior owners of the properties, for the clean-up costs. In August 1987, EPA again investigated the properties to assess the feasibility of a long-term remedy for any remaining contamination. New testing showed that soil in several areas on Kerry Place was still contaminated with PCBs. In April 1988, EPA informed the Reardons of these results. The Reardons told EPA that they intended to clean up their property themselves. EPA advised the Reardons to coordinate any offsite disposal plans with EPA and to obtain EPA’s approval of a treatment or disposal facility. In January 1989, the Reardons informed EPA that they had completed their own clean-up of Kerry Place, without having attempted coordination with or sought the approval of EPA. On March 23, 1989, EPA filed a notice of lien with the Norfolk County Registry of Deeds pursuant to  § 107(l ) of CERCLA, 42 U.S.C.  § 9607(l ), on all of the Kerry Place parcels still owned by the Reardons. The lien was for an unspecified amount, as it secured payment of â€Å"all costs and damages covered by† 42 U.S.C.  § 9607(l ) for which the Reardons were liable under  § 107(a) of CERCLA, 42 U.S.C.  § 9607(a). Five days later, EPA notified the Reardons that it had filed the notice of lien. On July 12, 1989, EPA informed the Reardons that they could settle EPA’s claims against them for $336,709, but noted that this amount did not limit the Reardons’ potential liability. On September 29, 1989, EPA selected a long-term remedy for the Kerry Place and Grant Gear sites estimated to cost $16,100,000. B. Procedural History. The Reardons filed a complaint and a motion for preliminary injunction in the United States District Court for the District of Massachusetts. They argued that they were entitled to have the notice of lien removed for three reasons. First, the Reardons maintained that they qualified as â€Å"innocent landowners† under  § 107(b) of CERCLA, 42 U.S.C.  § 9607(b), and therefore were not liable for any clean-up costs. Second, 42 U.S.C.  § 9607(l ) provides for a lien on only that property â€Å"subject to or affected by a removal or remedial action,† 42 U.S.C.  § 9607(l )(1)(B); the Reardons claim that since some of their Kerry Place parcels were not â€Å"subject to or affected by† the clean-up, EPA erred in filing a notice of lien covering all of those parcels. Third, they asserted that EPA’s imposition of the lien without a hearing violated the due process clause of  the fifth amendment to the United States Constitution. The district court held that  § 113(h) of CERCLA, 42 U.S.C.  § 9613(h), divested it of jurisdiction to hear the Reardons’ â€Å"innocent landowner† and â€Å"overbroad lien† claims. It found that the same section also purported to divest it of jurisdiction to hear the due process claim, but held that Congress was without power to place such a limitation on its jurisdiction. Turning to the merits of the due process claim, the *1512 district court held that the lien imposed by  § 107(l ) did not amount to a taking of a â€Å"significant property interest† protected by the due process clause. The court therefore denied the motion for a preliminary injunction and dismissed the complaint. The Reardons appealed, and a panel of this court found in their favor. The panel opinion construed  § 9613(h) so as to permit judicial review of the statutory challenges to the lien, and did not reach the due process issue. In response to EPA’s petition for rehearing, however, a majority of the court voted to grant a rehearing en banc. Although the court en banc finds for the plaintiffs, as did the panel, we do so on constitutional rather than statutory grounds. II. JURISDICTION [1] We turn first to the question of jurisdiction. The district court, as we have noted, held that 42 U.S.C.  § 9613(h) purported to divest it of jurisdiction over all three of the Reardons’ claims. We agree that  § 9613(h) bars review of the â€Å"innocent landowner† and â€Å"overbroad lien† claims, prior to the commencement of an enforcement or recovery action, but we conclude that this section does not bar review of the due process claim. Section 9613(h), entitled â€Å"Timing of review,† explicitly limits the jurisdiction of the federal courts to hear certain cases arising under CERCLA. The section states, in part: No federal court shall have jurisdiction under Federal law †¦ to review any challenges to removal or remedial action selected under section 9604 of this title, or to review any order issued under section 9606(a) of this title, in any action except one of the following: [listing 5 enumerated types of actions] 42 U.S.C.  § 9613(h). The five exceptions to the jurisdictional bar are all actions filed by the government or by a private citizen seeking to enforce or recover costs for the enforcement of CERCLA; for this reason, the district court described  § 9613(h) as barring â€Å"judicial review of EPA actions prior to the time that the EPA or a third  party undertakes a legal action to enforce an order or to seek recovery of costs for the cleanup of a hazardous waste site.† Reardon v. United States, 731 F.Supp. at 564 n. 8. As a convenient shorthand, we will say that  § 9613(h) bars â€Å"pre-enforcement review† of certain claims. The district court framed the question of jurisdiction as whether the filing of a lien constituted a â€Å"removal or remedial action selected under section 9604 of this title.† As the district court noted, the terms â€Å"removal† and â€Å"remedial action† are defined terms under the CERCLA statute. 42 U.S.C.  §Ã‚ § 9601(23), (24). Another C ERCLA provision says that these terms â€Å"include enforcement activities related thereto.† 42 U.S.C.  § 9601(25) (emphasis added). The court found that placing a lien on property from which hazardous substances had been removed was a type of enforcement activity. It therefore concluded that any challenge the Reardons could make, whether statutory or constitutional, was a â€Å"challenge[ ] to [a] removal or remedial action† over which Congress intended it not to have jurisdiction unless and until EPA brought an enforcement action. Reardon v. United States, 731 F.Supp. at 569. A. Jurisdiction over the â€Å"innocent landowner† and â€Å"overbroad lien† claims. We agree with the district court that filing a lien notice is a type of â€Å"enforcement activity† related to a removal or remedial action. And we agree that  § 9613(h) bars the federal courts from hearing pre-enforcement challenges to the merits of any particular lien–challenges, for example, to the liability which a lien secures, or to the conformity of that lien to the CERCLA lien provisions. Several considerations l ead to these conclusions. First, we think that the language of the statute, read for its ordinary meaning, supports such an interpretation. Central to the entire CERCLA scheme is a provision that makes certain parties liable for the cost of removal and remedial actions. See 42 U.S.C.  § 9607(a). When the government files a lien on property to secure payment of that liability, it can reasonably be described as seeking to enforce the liability *1513 provision. Thus, the activity of filing liens is, in ordinary language, an â€Å"enforcement activity.† Second, we believe that allowing challenges to the merits of particular liens would defeat some of the purposes of barring pre-enforcement review under  § 9613(h). Congress was no doubt concerned, first and foremost, that clean-up of substances that endanger public health would be delayed if EPA were forced to litigate each detail of its removal  and remedial plans before implementing them. Thus, the Senate Judiciary Committee Report stated that  § 9613(h) barred pre-enforcement review because such review would be a significant obstacle to the implementation of response actions and the use of administrative orders. Pre-enforcement review would lead to considerable delay in providing cleanups, would increase response costs, and would discourage settlement and voluntary cleanups. S.Rep. No. 11, 99th Cong., 1st Sess. 58 (1985). As long as the remedy upon review of a lien was limited to the invalidation or modification of the lien, of course, such review would not directly delay clean-up of hazardous substances. However, we do not believe that avoiding delay was the only purpose of postponing review. As the Fifth Circuit stated in a similar case: Although review in the case at hand would not delay actual cleanup of hazardous wastes, it would force the EPA–against the wishes of Congress–to engage in â€Å"piecemeal† litigation and use its resources to protect its rights to recover from any [potentially responsible party] filing such a[n] action. . . . . . Moreover, the crazy-quilt litigation that could result from allowing [potentially responsible parties] to file declaratory judgment actions prior to the initiation of government cost recovery actions could force the EPA to confront inconsistent results. Voluntary Purchasing Groups, Inc. v. Reilly, 889 F.2d 1380, 1390 (5th Cir.1989). The same practical considerations weigh against allowing pre-enforcement review in this case. And we add to these reasons one more: information needed to decide legal challenges to liens may not be available at the time such challenges are made. To decide, for example, the Reardons’ claim that they are innocent landowners, a court must determine whether the contamination pre-dated their ownership; whether they had any knowledge or reason to know of the contamination; whether they had exercised due care with respect to the hazardous substances; and whether they took precautions to prevent releases by foreseeable acts of third parties. See 42 U.S.C.  § 9607(a), (b)(3), EPA Supplemental Brief, at 16-17 (stressing complexity of resolving innocent landowner claim). Notices of liens are likely to be filed early in the history of a response action–shortly after EPA has begun to spend money on waste removal and the  landowner has been notified of potential responsibility. See 42 U.S.C.  § 9607(l ) (providing for creation and filing of liens). At that point, EPA is likely not yet to know the full extent of the contamination, let alone when that contamination occurred, or whether it is likely that the owner exercised due care or took reasonable precautions. One purpose of  § 9613(h), we believe, is to delay review until enough is known to decide these issues. Third, legislative history supports the view that  § 9613(h) is intended to bar challenges to liability, such as the Reardons seek to make by attacking the lien filing, as well as challenges to the remedy EPA has chosen. During floor debate on this section, Senator Thurmond, Chairman of the Judiciary Committee, which drafted the section, explained: Citizens, including potentially responsible parties, cannot seek review of the response action or their potential liability for a response action –other than in a suit for contribution–unless the suit falls within one of the categories in this section†¦. 132 Cong.Rec. S14929 (daily ed. Oct. 3, 1986) (emphasis added). Senator Stafford, *1514 Chairman of the Conference Committee, stated: â€Å"When the essence of a lawsuit involves the contesting [of] the liability of the plaintiff for cleanup costs, the courts are to apply the provisions of section 113(h), delaying such challenges until the Government has filed a suit.† 132 Cong.Rec. S14898 (daily ed. Oct. 3, 1986) (emphasis added). It is certainly possible that Congress inadvertently rather than purposefully included lien challenges in the judicial review bar. Congress amended the scope of â€Å"removal† and â€Å"remedial† actions to include â€Å"enforcement activities related thereto† primarily to ensure that EPA could â€Å"recover costs for enforcement actions taken against responsible parties.† H.R.Rep. No. 253(I), 99th Cong., 2d Sess. 66-67, reprinted in 1986 U.S.Code Cong. & Admin.News 2835, 2848-49; see H.R.Conf.Rep. No. 962, 99th Cong., 2d Sess. 185, reprinted in 1986 U.S.Code Cong. & Admin.News 3276, 3278 (â€Å"This amendment clarifies and confirms that [enforcement activity] costs are recoverable from responsible parties.†). Perhaps Congress did not realize that other provisions referring to removal and remedial actions–such as the judicial review bar–would also be affected. But even if this were so, we do not see how our conclusion is altered. First, as outlined above, reading the statute to bar review of pre- enforcement challenges to liens is consistent with the language and the purpose of the judicial bar. Second, and more importantly,  Congress amended a definitional section, thus changing the meaning of â€Å"removal† and â€Å"remedial† wherever they appear in CERCLA. We cannot give the definition inconsistent readings within the statute. As the above-quoted legislative history makes clear, the 1986 amendment was certainly intended to allow the government to collect attorney’s fees in cost recovery actions. See United States v. Ottati & Goss, 694 F.Supp. 977, 997 (D.N.H.1988) (allowing attorney’s fees to United States under  § 9607(a)(4)(A)), aff’d in part, vacated in part, 900 F.2d 429 (1st Cir.1990). If liens to ensure the government’s complete recovery of its remedial costs are not â€Å"enforcement activities† related to the removal or remedial action–the view suggested by the dissent–then we do not see how a suit to recover the government’s clean up costs is an â€Å"enforcement activit[y]† either. And if â€Å"enforcement activities† in  § 9601(25) is interpreted to exclude the expenses of cost recovery actions, this would have the effect of denying the government significant amounts of attorney’s fees– which was certainly not the intent of Congress. We therefore conclude, as did the district court, that  § 9613(h) precludes judicial review of the imposition of a lien until EPA commences an enforcement action. [2] B. Jurisdiction over the due process claim. Unlike the district court, however, we do not believe that  § 9613(h) precludes federal court jurisdiction over the Reardons’ due process claim. First, such a challenge does not fit into the literal language of  § 9613(h). That section refers to â€Å"challenges to removal or remedial action selected under section 9604 of this title.† Under our reading, it divests federal courts of jurisdiction over challenges to EPA’s administration of the statute–claims that EPA did not â€Å"select[ ] † the proper â€Å"removal or remedial action,† in light of the standards and constraints established by the CERCLA statutes. The Reardons’ due process claim is not a challenge to the way in which EPA is administering the statute; it does not concern the merits of any particular removal or remedial action. Rather, it is a challenge to the CERCLA statute itself–to a statutory scheme under which the government is authorized to file lien notices without any hearing on the validity of the lien. Second, we read  § 9613(h) in light of the Supreme Court’s oft-repeated pronouncement that â€Å"where Congress intends to preclude judicial review of constitutional  claims its intent to do so must be clear.† Webster v. Doe, 486 U.S. 592, 603, 108 S.Ct. 2047, 2053-54, 100 L.Ed.2d 632 (1988); see Weinberger v. Salfi, 422 U.S. 749, 95 S.Ct. 2457, 45 L.Ed.2d 522 (1975); *1515 Johnson v. Robison, 415 U.S. 361, 94 S.Ct. 1160, 39 L.Ed.2d 389 (1974). [FN1] We do not believe that the statute expresses a clear congressional intent to preclude the type of constitutional claim the Reardons are making–a challenge to several statutory provisions which form part of CERCLA. However, it is important to make clear that we are not holding that all constitutional challenges involving CERCLA fall outside the scope of  § 9613(h). A constitutional challenge to EPA administration of the statute may be subject to  § 9613(h)’s strictures. Such a claim may well be a â€Å"challenge[ ] to removal or remedial action selected under section 9604 of this title,† and may thus fall within  § 9613(h)’s bar. We find only that a constitutional challenge to the CERCLA statute is not covered by  § 9613(h). FN1. Of course,  § 9613(h) is styled as a provision that merely delays review, rather than precludes it–indeed, it is titled â€Å"Timing of review.† However, the only available review of the lien notice is in an enforcement action brought by EPA; and the judgment in that enforcement action will render moot the Reardons’ due-process-based request for injunctive relief against the filing of the lien, since it will decide whether or not the Reardons are liable under CERCLA. Hence, the effect of  § 9613(h) is to preclude review altogether. Third, extending jurisdiction to the Reardons’ due process claim does not necessarily run counter to the purposes underlying  § 9613(h). For example, resolution of the due process issue does not require any information that is not likely to be available until clean-up of a site is finished. Because it is a purely legal issue, its resolution in a pre-enforcement proceeding does not have the potential to force EPA to confront inconsistent results (as would a finding, for example, that a particular spill was caused by an act of God). Of course, if we decide that filing a notice of a CERCLA lien without any pre- enforcement review does violate due process, EPA’s collection efforts will no doubt be hampered. However, we do not lightly assume that Congress intended to ease EPA’s path even at the expense of  violating the Constitution. Fourth, although the two courts that have considered this issue have reached a different conclusion, see Barmet Aluminum Corp. v. Re illy, 927 F.2d 289, 293 (6th Cir.1991); South Macomb Disposal Authority v. U.S.E.P.A., 681 F.Supp. 1244, 1249-51 (E.D.Mich.1988), we are unpersuaded by the reasoning of those cases. Our disagreement commences with the phrasing of the issue to be decided. Both courts frame the question as whether  § 9613(h) â€Å"prohibits constitutional as well as statutory challenges until the time pr[e]scribed by the statute.† South Macomb, 681 F.Supp. at 1249-50; see Barmet, 927 F.2d at 292. We think that this question fails to make the distinction we have noted above, see pp. 1514-1515, supra, between two types of constitutional challenges–challenges to EPA’s administration of CERCLA, and challenges to CERCLA itself. Once we recognize this distinction, the reasoning of these two courts becomes less convincing. First, says the South Macomb court, Reading the language of  § 9613(h) for its everyday meaning supports the notion that this subsection prohibits constitutional as well as statutory challenges until the time pr[e]scribed by the statute. The provision explicitly states that federal courts shall not have jurisdiction to review â€Å"any challenge† except for those enumerated. South Macomb, 681 F.Supp. at 1249- 50. But, the statute does not bar â€Å"any challenge,† without qualification; rather, it delays federal court review of â€Å"any challenges to removal or remedial action selected under section 9604 of this title.† 42 U.S.C.  § 9613(h). Because a due process challenge to the CERCLA lien provisions is not, we believe, a challenge to â€Å"removal or remedial action selected under section 9604 of this title,† we do not find that the â€Å"everyday meaning† of  § 9613(h) divests the federal courts of jurisdiction to hear such a challenge. Both the Barmet and South Macomb courts contend that legislative history–House and Senate Reports, and House Judiciary Committee Hearings– suggests that Congress intended  § 9613(h) to bar all pre-enforcement challenges, including all *1516 constitutional challenges. Upon examination, we find these materials unconvincing as well. The Senate Report states, in part: As several courts have noted, the scheme and purposes of CERCLA would be disrupted by affording review of orders or response actions prior to commencement of a government enforcement or cost recovery action. See, e.g., Lone Pine Steering Committee v. EPA, [600 F.Supp. 1487 (D.N.J.1985) ]. These cases  correctly interpret CERCLA with regard to the unavailability of pre-enforcement review. This amendment [ § 9613(h) ] is to expressly recognize that pre-enforcement review would be a significant obstacle to the implementation of response actions and the use of administrative orders. Pre- enforcement review would lead to considerable delay in providing cleanups, would increase response costs, and would discourage settlements and voluntary cleanups. S.Rep. No. 11, 99th Cong., 1st Sess. 58 (1985). We see nothing in this discussion which would indicate an intent to divest federal courts of jurisdiction to consider a claim that the provisions of CERCLA itself authorize deprivations of property without due process of law. On the contrary, the reference to â€Å"review of orders or response actions† suggests that the writers of the Senate Report focused their concern on the problems that would arise if courts reviewed the merits of particular EPA actions. Both Barmet and South Macomb attach great weight to the Senate Report’s citation â€Å"with approval† of Lone Pine, a case decided before  § 9613(h) was enacted, which they say held that CERCLA did not allow pre- enforcement review even of constitutional challenges. We think there are good reasons to discount this citation. For one thing, the 13-page opinion in Lone Pine contains no discussion of the question whether constitutional challenges to the statute as well as challenges to administrative action are barred; one can only infer that the Lone Pine court held this view from the facts that (1) the plaintiff’s complaint had one constitutional count alongside six statutory counts, and (2) the court dismissed the entire complaint. In fact, Lone Pine cites Aminoil, Inc. v. EPA, 599 F.Supp. 69, 72 (C.D.Cal.1984), the leading case holding that CERCLA did not bar jurisdiction to review constitutional challenges to the statute; and it does so, not to indicate any disagreement with that holding, but simply to agree with its holding that CERCLA does bar pre-enforcement review of administrative orders. See Lone Pine, 600 F.Supp. at 1497. For another thing, the Senate Report does not cite Lone Pine for the proposition that federal courts have no jurisdiction to hear constitutional challenges; rather, it cites it solely as an example of a group of cases, sub silentio holding that review â€Å"of orders or response actions† would disrupt the purposes of CERCLA. We do not see why this should indicate agreement with Lone Pine’s purported holding regarding constitutional challenges,  particularly since cases such as Aminoil would seem to fit just as easily into the group of cases described in the Report. We do not find the House Report any more convincing. The pertinent passage in that Report, according to Barmet and South Macomb, is a statement that â€Å"there is no right of judicial review of the Administrator’s selection and implementation of response actions until after the response action[s] have been completed†¦.† H.R.Rep. No. 253(I), 99th Cong., 2d Sess. 81, reprinted in 1986 U.S.Code Cong. & Admin.News 2835, 2863. See Barmet, 927 F.2d at 293 (quoting this passage); South Macomb, 681 F.Supp. at 1250 (same). This statement says nothing about judicial review of the CERCLA statute itself. South Macomb also cites testimony of EPA and Justice Department officials during hearings on the bill that contained  § 9613(h). In response to a query from Representative Glickman as to whether EPA and the Justice Department â€Å"might accept some form of accelerated [pre-enforcement] review,† Mr. Habicht, the Assistant Attorney General for Land and Natural Resources, replied: Mr. Chairman, briefly, this issue has been litigated under the 1980 statute *1517 quite extensively, and there have been a number of decisions over the last several months that address the fundamental questions of the constitutionality of the procedures set forth in that law. Virtually across the board now the courts are finding that the scheme is constitutional as currently constituted. Superfund Reauthorization: Judicial and Legal Issues, Hearings before the Subcomm. on Admin. Law and Governmental Relations, H. of Rep. Judiciary Comm., 99th Cong., 1st Sess. at 226 (July 17, 1985); see South Macomb, 681 F.Supp. at 1250 (quoting this passage). The South Macomb court comments: â€Å"Our reading of this exchange is that the EPA and the Department of Justice took the position that because the courts had already upheld the constitutionality of CERCLA, constitutional challenges could also await EPA enforcement actions.† Id. We do not find this passage quite so clear. It would appear to be an expression of hope by EPA and the Department of Justice rather than a statement of congressional intent, particularly in light of the fact that Congress passed a provision,  § 9613(h), that by its language does not bar constitutional challenges to the CERCLA statute. Finally, the Supreme Court recently examined a statute with a judicial review provision not unlike the CERCLA section analyzed here. At issue in McNary v. Haitian Refugee Center, Inc., 498 U.S. 479, 111 S.Ct. 888, 112  L.Ed.2d 1005 (1991), was a provision of the Immigration and Nationality Act barring judicial review of a denial of â€Å"Special Agriculture Worker† (â€Å"SAW†) status except in the context of a deportation order. The statute states: â€Å"There shall be no administrative or judicial review of a determination respecting an application for adjustment of status under this section except in accordance with this subsection.† 8 U.S.C.  § 1160(e) (as amended by the Immigration Reform and Control Act of 1986). The Court held that this bar did not preclude review of â€Å"general collateral challenges to unconstitutional practices and policies used by the agency in processing applications.† McNary, 111 S.Ct. at 896. Rather, it only barred review of individual denials of SAW status. Id. The statute in McNary resembles the CERCLA provision at issue here in two respects. First, as here, judicial review of an administrative event is withheld until the agency instigates a second, independent proceeding. More significantly, the immigration statute is phrased so as to bar review of the agency’s determination of SAW status in an individual action–an event comparable to EPA’s selection of a removal or remedial action, which is the focus of the CERCLA bar. Neither statute mentions the availability of review of a constitutional challenge to the statute itself (as here) or to the agency’s execution of the statute (as in McNary ). Insofar as the Immigration and Nationality Act compares to CERCLA, we think that the holding in McNary supports our conclusion here. See also Johnson v. Robinson, 415 U.S. 361, 367, 94 S.Ct. 1160, 1165-66, 39 L.Ed.2d 389 (1974) (holding that similar jurisdictional bar precluded review only of administration of statute, not of challenge to statute itself); cf. Weinberger v. Salfi, 422 U.S. 749, 762, 95 S.Ct. 2457, 2465, 45 L.Ed.2d 522 (1975) (holding that more expansive language barred all challenges related to statute). Thus, we conclude that we have jurisdiction to consider the Reardons’ due process claim: that the CERCLA statutory scheme under which liens may be imposed on property without opportunity for a hearing violates the fifth amendment due process clause. III. THE DUE PROCESS CLAIM [4] The Supreme Court has established a two-part analysis of due process challenges to statutes which, like this one, involve property rather than liberty interests. One must first ask whether the statute authorizes the taking of a â€Å"significant property interest† protected by the fifth  amendment. E.g., Fuentes v. Shevin, 407 U.S. 67, 86, 92 S.Ct. 1983, 1997, 32 L.Ed.2d 556 (1972). If there is no significant property interest involved, the inquiry is at an end. If there is, one proceeds to examine what process is due in the particular circumstances. *1518 E.g., id.; Mathews v. Eldridge, 424 U.S. 319, 335, 96 S.Ct. 893, 903, 47 L.Ed.2d 18 (1976). We shall address each issue in turn. A. The Deprivation. The district court, relying primarily on Spielman- Fond, Inc. v. Hanson’s, Inc., 379 F.Supp. 997 (D.Ariz.1973) (three judge panel), aff’d mem., 417 U.S. 901, 94 S.Ct. 2596, 41 L.Ed.2d 208 (1974), found that the filing of a federal lien under 42 U.S.C.  § 96 07(l ) did not amount to a deprivation of a significant property interest; thus, the court did not reach the second step of the analysis. However, a Supreme Court case decided after the district court had issued its decision (indeed, after oral argument at the en banc rehearing of this appeal) has clarified the law in this area considerably, and has precluded continued reliance on the Court’s summary affirmance in Spielman-Fond. In Connecticut v. Doehr, 501 U.S. 1, 111 S.Ct. 2105, 115 L.Ed.2d 1 (1991), a unanimous Court held that a Connecticut attachment statute violated the due process clause. The Court held that the attachment lien on plaintiff Doehr’s real property deprived him of a significant property interest within the meaning of the due process clause. The Court stated: For a property owner like Doehr, attachment ordinarily clouds title; impairs the ability to sell or otherwise alienate the property; taints any credit rating; reduces the chance of obtaining a home equity loan or additional mortgage; and can even place an existing mortgage in technical default where there is an insecurity clause. Doehr, 501 U.S. at —-, 111 S.Ct. at 2113. It concluded that â€Å"even the temporary or partial impairments to property rights that attachments, liens, and similar encumbrances entail are sufficient to merit due process protection.† Id. (emphasis added). And, in a footnote, it disposed of its summary affirmance in Spielman-Fond by noting that â€Å"[a] summary disposition does not enjoy the full precedential value of a case argued on the merits and disposed of by a written opinion.† Id. at —- n. 4, 111 S.Ct. at 2113 n. 4 (citing Edelman v. Jordan, 415 U.S. 651, 671, 94 S.Ct. 1347, 1359-60, 39 L.Ed.2d 662 (1974)). See also id. at —-, 111 S.Ct. at 2113 (Rehnquist, C.J., concurring) (Spielman-Fond should not be read to mean that the imposition of a lien is not a deprivation of a significant interest in property). Whether the response costs were incurred consistently with the national contingency plan is an issue which may be highly factual, but it is usually a matter of the amount, and not the existence, of liability. More likely to be â€Å"highly factual† is the determination whether certain of the owner’s parcels of land are â€Å"subject to or affected by† EPA’s response action. Similarly, on the issue of the landowner’s liability, EPA admits in its brief that the â€Å"concepts of due care, foreseeability, objective and subjective knowledge, some of which are unique in CERCLA to the innocent landowner defense, are extremely fact-intensive.† EPA Supplementary Brief at 16-17. Second, we must consider what procedural safeguards, if any, CERCLA provides against erroneous filing of a lien. a. The right to a judicial hearing. CERCLA provides no such safeguards. It provides for no pre-deprivation proceedings at all–not even the ex parte â€Å"probable cause† hearing judged insufficient in Doehr. See Doehr at —-, 111 S.Ct. at 2108 (describing Connecticut attachment procedure). Nor does CERCLA provide for an immediate post-deprivation hearing. [FN2] The first hearing the property owner is likely to get is at the enforcement proceeding, or cost recovery action, brought by EPA. This action may be brought several years after the notice of lien is filed; it is limited only by a rather complicated statute of  limitations, see 42 U.S.C.  § 9613(g)(2), which gives EPA three years after a removal action is completed or six years after a remedial action is commenced to bring such a suit. The running of the statute of limitations is entirely within EPA’s control. Since the government may take its own sweet time before suing, and since the removal or remedial action may itself take years to complete, the lien may be in place for a considerable time without an opportunity for a hearing. FN2. The Connecticut statute at issue in Doehr provided â€Å"expeditious† post-attachment review, see 501 U.S. at —-, 111 S.Ct. at 2115, but the Court nonetheless found the statute constitutionally deficient. Even under Doehr, though, post-attachment process is not always inadequate. Doehr notes the factors leading to the Court’s  approval, in Mitchell v. W.T. Grant Co., 416 U.S. 600, 94 S.Ct. 1895 (1974), of a sequestration statute with no pre-deprivation review: â€Å"the plaintiff had a vendor’s lien to protect, the risk of error was minimal because the likelihood of recovery involved uncomplicated matters that lent themselves to documentary proof, and plaintiff was required to put up a bond.† Doehr, 501 U.S. at —-, 111 S.Ct. at 2114. â€Å"[M]ere postponement of judicial enquiry is not a denial of due process if the opportunity given for ultimate judicial determination of liability is adequate.† *1520 Phillips v. Commissioner, 283 U.S. 589, 596, 51 S.Ct. 608, 611, 75 L.Ed. 1289 (1931). But the CERCLA statute of limitations on liens throws the â€Å"ultimate judicial determination† so far into the future as to render it inadequate. Indeed, in this respect the CERCLA scheme resembles the replevin statutes in Fuentes v. Shevin, where the Court held that the debtor may not be â€Å"left in limbo to await a hearing that might or might not ‘eventually’ occur.† Mitchell v. W.T. Grant Co., 416 U.S. at 618, 94 S.Ct. at 1905 (discussing Fuentes v. Shevin ). b. Posting of a Bond. The Court has recognized that requiring the filing party to post a bond may provide the property owner important protection against wrongful filing; in Doehr, four members of the Court suggested that due process always requires a plaintiff’s bond in the context of an attachment. See Doehr, 501 U.S. at  Ã¢â‚¬â€-, 111 S.Ct. at 2116 (plurality). CERCLA does not require EPA to post a bond when filing the notice of federal lien. c. Action for damages. In Doehr, the State of Connecticut argued that the availability of a double damages remedy for suits that are commenced without probable cause was an important protection against misuse of the attachment provisions; however, four members of the Court did not find the availability of such a suit to be an adequate procedural safeguard. Four members of the court explained in detail why an action for damages would never prove adequate: The necessity for at least a prompt postattachment hearing is self-evident because the right to be compensated at the end of the case, if the plaintiff loses, for all provable injuries caused by the attachment is inadequate to redress the harm inflicted, harm that could have been avoided had an early hearing been held. An individual with an immediate need or opportunity to sell a property can neither do so, nor otherwise satisfy that need or recreate the opportunity. The same applies to a parent in need of a home equity loan for a child’s education, an entrepreneur seeking to start a business on the strength of an otherwise strong credit rating, or simply a homeowner who might face the disruption of having a mortgage placed in technical default. Doehr, 501 U.S. at —-, 111 S.Ct. at 2118 (plurality).