2014-Issue 27—The passive activity loss rules of Section 469 of the Internal Revenue Code limit the losses that an individual, trust, estate, closely held C corporation, or a personal service corporation can recognize from trade or business activities in which the taxpayer does not "materially participate." Congress enacted the Section 469 passive activity loss rules in 1986 as part of its response to the tax shelter investments of the 1970s and early 1980s, which allowed some taxpayers to generate large passive tax losses that offset their taxable income from other sources.
Now, the Internal Revenue Service is showing a renewed focus on the passive activity loss rules in Section 469, and in particular on the exception to these rules for real estate professionals. The most immediate cause of this focus is the new tax on net investment income. The net investment income tax in Section 1411 imposes an additional 3.8 percent tax on a taxpayer's net investment income in excess of certain thresholds. Section 1411 and the related regulations cross-reference the passive activity rules in Section 469 to identify certain income subject to this new, additional tax.
However, the application of Section 469 within Section 1411 is not the only reason the passive activity loss rules are in the spotlight. A&M's recent experience, and anecdotes that we have heard in the marketplace, indicate that the IRS has become more aggressive in policing more traditional Section 469 issues. Finally, the Tax Court also recently held in favor of the taxpayer in a case concerning Section 469, Aragona Trust v. Commissioner, 142 T.C. No. 9 (March 27, 2014). Aragona Trust held for the first time that a trust can qualify as a real estate professional and that the trust's rental real estate activities are not subject to the Section 469 passive activity loss rules. Given this renewed interest in Section 469, it is important to review how the passive activity loss rules apply to real estate professionals.
Section 469 generally prevents individuals, trusts, estates, closely held C corporations, and personal service corporations from using current losses from passive business activities to offset income from salaries, active business activities, or portfolio investment income. Instead, Section 469 generally suspends passive activity losses until a taxpayer has future passive activity income or ultimately disposes of the passive activity investment.
Although Congress aimed the passive activity loss rules at tax shelter investments, the rules as originally enacted in 1986 posed a significant challenge for all rental real estate investors. The problem was that Section 469(c)(2) defines passive activity to include any rental activity. It is quite common for rental real estate investments to generate tax losses, even if the investment generates a positive cash flow. Thus many rental real estate investors found that their tax losses from these investments were suspended by Section 469, as originally enacted.
The real estate industry responded to this problem quickly, and in 1993 Congress amended Section 469 to exclude certain rental income of real estate professionals from the passive activity loss rules. Specifically, this real estate professional exception allowed certain taxpayers to treat rental real estate investments as active businesses, and use losses from those investments to offset other taxable income.
For the two decades following 1993, the real estate professional exception was significant primarily for individuals with rental real estate investments that were generating tax losses. Recently, however, we have seen several trends that both reduce the amount of losses for which real estate professional status provides a benefit and increase the number of taxpayers to whom this status is relevant.
In recent audits, the IRS has challenged how a real estate professional evaluates losses from rental real estate investments held in partnerships. The Schedule K-1 that real estate investors receive from a partnership separately reports ordinary business losses and net rental real estate losses. Certain taxpayers who qualify as real estate professionals have taken the position that all of the partnership's activities represent an appropriate economic unit for purposes of Section 469, and thus neither the ordinary business losses nor the net rental real estate losses from a real estate partnership were subject to the passive loss limitations.
However, A&M's experience, supported by anecdotes we have heard in the marketplace, is that the IRS has asserted in recent audits that certain real estate professionals must treat ordinary business losses and rental real estate losses from the same partnership as two separate activities, and that a taxpayer's real estate professional status is relevant only to the net rental real estate losses. Depending on a taxpayer's specific facts and circumstances, these arguments may force the taxpayer to suspend the ordinary business loss from its partnership investment under the passive activity loss rules, notwithstanding the taxpayer's status as a real estate professional. Thus, this IRS position has the potential to decrease the amount of losses to which a real estate professional status is relevant.
Although the IRS may be trying to limit the amount of losses to which the real estate professional status is relevant, two recent developments have meant that more taxpayers may benefit from this status. The first development is the 3.8 percent net investment income tax that applies to income from passive activities beginning in 2013. As discussed below, real estate professional status is a way to exclude rental real estate from Section 469. Consequently, this status can allow taxable income from rental real estate to avoid the 3.8 percent net investment income tax, if certain other requirements are also met.
The second development that increases the number of taxpayers who may be interested in real estate professional status is the Aragona Trust case. Historically, the IRS has taken the position that only individuals may qualify for real estate professional status. The Aragona Trust case held for the first time that a trust can also qualify as a real estate professional under the right circumstances.
In light of these recent developments, it is important for all real estate investors to review the requirements to achieve real estate professional status, to understand how real estate professional status interacts with the net investment income tax rules, and to understand the limits of the Aragona Trust decision.
Section 469(a) and (b) provide that any net loss that an individual, estate, trust, closely held C corporation, or personal service corporation recognizes from "passive activities" during a taxable year is disallowed and carried to the next taxable year. Section 469(c)(1) defines a passive activity as the conduct of any trade or business in which the taxpayer does not materially participate. The Internal Revenue Code defines material participation in Section 469(h) to mean "regular, continuous, and substantial" involvement in an activity's operations. Section 469(c)(2) and (c)(4) say that, unless the taxpayer qualifies as a real estate professional, passive activity includes any rental activity — even where the taxpayer materially participates in the rental activity.
The taxpayer performs more than 750 hours of services during the taxable year in real property trades or businesses in which the taxpayer materially participates.
Real property trades or businesses are not limited to rental real estate. They also include real property development, construction, acquisition, conversion, rental, operation, management, leasing, or brokerage trade or business. Significantly, for activities that a taxpayer undertakes as an employee to count toward the 750-hour threshold in Section 469(c)(7)(B)(ii), the taxpayer must own at least five percent of his or her employer.
Even if a taxpayer qualifies as a real estate professional, Section 469 suspends the taxpayer's losses unless he or she also materially participates in the activity that gave rise to the loss. The Code provides some relief, however, because Section 469(c)(7) allows a taxpayer to elect to treat all rental real estate activities as one activity for purposes of Section 469. Treasury Regulations Section 1.469-5T(a) provides detailed rules to determine whether an individual taxpayer has materially participated in an activity; these rules focus on the number of hours that an individual spent participating in various activities. Treasury Regulations Section 1.469-5T(g) states that the regulations for material participation by trusts and estates have been reserved.
The taxpayer materially participates in that business.
See Preamble to T.D. 9644 (Nov. 26, 2013); Instructions to Form 8960 (2013).
Second, Treasury Regulations Section 1.1411-4(g)(7) provides a safe harbor for a real estate professional that participates in a rental real estate activity either for more than 500 hours during a tax year or more than 500 hours during any five of the 10 preceding tax years. The definition of real estate professional in Treasury Regulations Section 1.1411-4(g)(7) specifically cross-references the definition of real estate professional in Section 469.
Thus, under Section 1411 and the related regulations, real estate professional status may now provide a significant tax advantage for taxpayers with rental real estate investments that consistently generate taxable income.
The Aragona Trust case held that a trust qualified as a real estate professional based on the activities of its trustees. Aragona Trustconsidered a complex residuary trust that conducted rental real estate and other real estate activities directly and through various subsidiaries. Three of the trust's six trustees worked full-time in a wholly owned subsidiary of the trust that managed most of the trust's rental real-estate properties. On its income tax returns, the trust treated all of its rental real estate activities as non-passive, and used losses from these activities to offset other trust income.
The Aragona Trust did not materially participate in real property trades or businesses.
The Tax Court rejected both of these arguments. First, the Tax Court held that real estate professional status is not limited to individuals, and that a trust could qualify for this status. The Tax Court also rejected the IRS's argument that the Aragona Trust did not materially participate in the trust's real property businesses. The Tax Court held that all of the time that trustees who were also employees of the trust's wholly owned management company spent working on the trust's real estate operations should be attributed to the trust when determining whether the trust materially participated in those activities. Finally, the Tax Court also held that when the time that trustees spent as employees is also considered, it was clear that the trust materially participated in its real estate activities.
Aragona Trust is significant for holding that a trust can qualify as a real estate professional, and that a trustee's time spent working as an employee of the trust should be considered when determining whether the trust itself materially participated in a real estate activity.Aragona Trust is equally significant for the issues that it did not address. In particular, Aragona Trust does not provide any guidance about how to determine whether a trust meets the requirements in Section 469(c)(7)(B) that the trust perform more than 750 hours of services during the year on real property businesses and spend more than half its personal services on real estate businesses.
The court specifically noted that the IRS did not assert this argument and thus, within the arguments raised in the Aragona Trust case, the trust qualified as a real estate professional. Finally, the Aragona Trust opinion also does not address all of the potential ramifications of the trust's business activities on its status as a trust. Instead, the Aragona Trust opinion notes in footnote 11 that the IRS did not argue that the trust's business activities should cause the trust to be treated as a business trust that is taxed as a corporation under Treasury Regulations Section 301.7701-4(b). See Aragona Trust, 142 T.C. No. 9.
With the caveat that it did not address arguments that the IRS did not assert, Aragona Trust held that the trust's rental real estate activities were not passive activities within the meaning of Section 469.
In general, the renewed IRS focus on Section 469 should remind taxpayers of the importance of maintaining contemporaneous documentation of the time that they spend in various business activities. Aragona Trust reminds us that, although the passive activity rules in general and material participation in particular are fact-intensive analyses, a taxpayer with the right facts and supporting documentation can still prevail.
More specifically, the new developments and renewed interest from the IRS in the application of the Section 469 passive activity loss rules pose both opportunities and threats for real estate professionals. For individuals who can qualify, making the election to have real estate professional status is something that they should consider and discuss with their tax advisors. The opportunity to benefit from this status for investments that generate either taxable income or taxable losses means that real estate professional status can provide a benefit to more real estate investors.
Additionally, taxpayers that invest in real estate through partnerships should pay close attention to how partnerships report their activities. In particular, taxpayers should ensure that a partnership reports income and expenses on the appropriate sections of the form. Given the IRS's focus on the difference between a partnership's ordinary losses and its rental real estate losses, the manner in which a partnership reports an item can have a significant effect on an investor's tax liability.
Finally, taxpayers should be careful regarding the conclusions they draw from Aragona Trust. The Tax Court opinion in Aragona Trustdoes not address how a trust measures whether it spends half its personal services on real estate activities or whether the trust has spent at least 750 hours on real estate activities. Satisfying the taxpayer's burden of proof for these measurements could be complex if the IRS were to assert this argument in a future challenge to a trust. In addition, a footnote in Aragona Trust acknowledges the possibility that, if a trust has sufficient business activities, the trust could be treated as a business trust that is taxed as a corporation.
Under Treasury Regulations Section 301.7701-4(b), a business trust may be treated as a corporation or a partnership for federal income tax purposes. Obviously, trusts that conduct business operations should be careful to avoid being treated as corporations for federal income tax purposes. If the IRS were successful in arguing that a trust's business activities should be taxable as a corporation, there would be two levels of tax on those business activities: one level of tax at the trust and a second level of tax on the beneficiaries. The cost if a trust were to be taxed as a corporation would more than offset any benefit from avoiding the net investment income tax.
One of the few recent taxpayer-favorable decisions could have a significant impact on more than just homebuilders in similar situations.


So what is this "collaboration" business all about, and why are we anxiously working to automate it? If the electronic form of "collaboration" is simply an app wrapped around the process of meeting, then theoretically, every minute we collaborate is one fewer minute being productive.
Unless, of course, Drucker was wrong. Or, alternately, electrons changed the world so much in 49 years that electronic communication can broaden our consciousness today in a way they couldn't when there were only three commercial TV networks in America.
Excuse No. 1: Being online makes it feasible for us to meet about nothing. Quite substantively, nothing at all. Last week, the senior director of product for Clarizen, Angela Bunner, told our Dom Nicastro that, with the right frame of mind, folks who get together for meetings can spontaneously contribute reasons for their being there.
Excuse No. 2: Because you're online, you have no choice now. Wrote contributor Andrew Pope last week, "The modern complex business environment demands collaboration as the new norm. We are continually responding, having to try new things." Thus, the benefit of collaboration is that it compels organizations to come up with a goal for collaboration itself, and that goal will eventually be discovered to have value.
Okay, so I'm in a grumpy mood. Maybe I've sat through too many meetings, you might say.
But if we believe we're embracing Drucker and the collaboration ethic at the same time, we need to recognize we're talking out of two sides of ourselves, and at least one of them isn't very rosy. Part of us would appear to be saying, if we just act like we're engaged and participate in this collaboration thing long enough, eventually we'll reach the point of nirvana where it will all justify itself.
So @Lunch today, let's hear what you think. Is there a real point to collaboration, or was Drucker right after all? Share your thoughts in the comment section, below.


What makes us the best HVAC company in Wheeling?
The best AC repair is one that never happens, but we all recognize that's not reality. HVAC systems break down over time just like anything else, especially if regular air conditioner maintenance has been ignored or neglected for a long time. After the air conditioner is more than 10 years old, it's likely you'll experience an increase in repairs and need for maintenance. It's also not abnormal to hear horror stories about going without air conditioning in the Wheeling heat.
When you call Comfort Masters Service Experts Heating & Air Conditioning, you can be confident in the quality of our service.
We back up all of our work with a written 100% satisfaction guarantee. We've been in business since 1969, and we proudly set the standard for the best customer service in the Wheeling area. You can be confident knowing that your home comfort is our number one task.
We understand no one wants to find out that they must purchase a new air conditioning system. This is why we will first attempt to repair your malfunctioning air conditioner. If your central AC is done and has no life left to deliver, we'll help you find the best replacement system for your home. The most important part of the process is that you are aware of all your options for your air conditioning system, and that your home comfort and safety is kept in mind during the service call. We understand a new air conditioning system is a big investment, so we'll work with you to identify the best selection to meet your needs and budget while keeping the Wheeling environment in mind. You may also benefit from rebates and other cash incentives provided by utility companies, manufacturers, and local and federal governments.
How do you gauge if you should consider an AC repair or an air conditioner replacement? If you're uneasy, the Dallas Guide to Air Conditioner Replacement is an ideal place to begin.
Review your breaker box for a tripped breaker. If the breaker is flipped, try resetting it. You can flip it off and on again even if it doesn't appear to have tripped. Some breakers will trip but the switch doesn't move much, making it appear as though there is a separate problem. Older homes could have fuse boxes, in which case you're looking for a blown fuse.
Examine your thermostat. You want to confirm that there are working batteries in it, it's functioning and that it's set to cool. There is no need call for an AC repair if a couple double AA batteries fix the situation.
Listen for odd noises coming from your air conditioning system. If you notice clicking, call Comfort Masters Service Experts Heating & Air Conditioning straightaway.
Look for ice. If you do see ice on your AC unit in a Wheeling summer, you might have a refrigerant leak. Sometimes you'll notice ice on the lines running from your condenser (the big air conditioning unit outside your home with a fan on top) into your house. Refrigerant leaks should be repaired quickly, or you are in danger of damaging key components of your air conditioning system.
Replace your filter! We all disregard the little chores from time to time. Replacing the air conditioning system's filter is an easy one to forget. Blocked air flow from an excessively dirty filter can severely reduce your system's efficiency and result in extra wear on components, like the blower motor.
Examine your air vents. Your air conditioning system has to breathe, which means maintaining air flow. If you have blocked air flow from your supply and return vents, it's likely you will have an AC repair during Wheeling heatwaves at some point in the future.
Our experts can help with an AC coil leak. A leaking evaporator coil can be easily noticeable, but costly to replace. It's because of air conditioner repairs like this that we advocate for an AC maintenance plan. Preventative maintenance and ongoing tune-ups can help to decrease the odds of more costly repairs down the road. In the event that the leak cannot be sealed and repaired, our HVAC technicians have the capability to replace the faulty component.
Usually if the compressor is shot, you're planning to replace it, not repair it. The compressor in an air conditioner is a critical component and the part itself is one of the costlier pieces of the system. If you have an old unit and the compressor is done, you will possibly want to replace the unit.
There are three categories of AC compressors: single stage compressors, two-stage compressors and variable-speed compressors. The single stage compressors can only operate at one level, which means it will run full force as long as it's on. The two stage compressors provide two different levels, so it can run a little lower on days that have milder temps, which supports efficiency. The most efficient option is the variable capacity compressor which has the power to constantly adjust to meet the preferred temperature of the home.
When the time arrives to get help with your air conditioner, you can depend on the qualified professionals at Comfort Masters Service Experts Heating & Air Conditioning. Give us a call at 847-250-6729 and we'll be happy to answer your questions or schedule an appointment.
Letting your air conditioner run over extended periods of time without being maintained is likely to cause more headaches as time passes. Whether it results in air conditioner service calls or you needing a new air conditioning system, lack of maintenance, is harmful to the efficiency and operation of your system.
When your air conditioner isn't running efficiently, the compressor and fan controls might wear out, or several other significant components may be impacted. When your system cycles on and off a lot there is avoidable stress placed on these internal parts, causing improper operation or premature failure.
From a dead battery to a thermostat sensor that isn't calibrated appropriately, there are many thermostat problems that could occur. If it has been a while since you last switched your thermostat batteries, it may be time to do so in order to avoid any issues with the settings you have in place.
Your air conditioning unit will make a large amount of condensation. Some air conditioners have an electric condensate pump with tubing that can be damaged or clogged with algae or ice. Call one of our friendly service technicians if you think something isn't right with your pump.
Everyone wants relief quickly, especially in a blazing Wheeling heatwave. But it's a fact that the hotter it is outside; the more AC repair calls your local Wheeling HVAC companies gets. There are two actions you can take to get faster service.
Keep an eye on the weather. If you notice in the forecast that it is going to be hot and you know your air conditioner is old and not working as efficiently, call Comfort Masters Service Experts Heating & Air Conditioning and schedule a tune-up as soon as possible. Make sure you discuss your concerns and anything weird you've observed about your air conditioning system. This will help us inspect anything that could cause a catastrophic failure during warmer seasons.
Join one of Comfort Masters Service Experts Heating & Air Conditioning's Service Plans. Not only do you have the extra benefit of receiving regular tune-ups for your air conditioner, which could stop the need for an AC repair completely. If something does occur, you're already top of mind.
If it helps decrease your indoor temps, we can help. Mini-split AC units are good choices for historic homes that do not have the necessary space for ductwork, tough to heat and cool spaces like garages or new additions where the AC system does not currently exist. Comfort Masters Service Experts Heating & Air Conditioning has the experts who can repair, replace, and install ductless mini-split air conditioning systems of any make and model.
In the Wheeling community, we have several newer homes and more are built every day. Occasionally a newer home may still have heating and cooling challenges for specific rooms. We can install a zoning system to help eliminate any problem areas in your home that have hot and cold spots. Some customers prefer to use a mini-split system for this purpose as well. While we find these systems are reliable, it does happen sometimes that a mini-split system wears out and demands repairs just like a central air conditioning system.
When you begin looking for an HVAC repair company, check how many years the company has been in business. A well-established HVAC company will likely have the most qualified HVAC contractors on the team and a larger number of clients who could share testimonials. You should also get recommendations from family and friends in Wheeling.
Look for a written 100% satisfaction guarantee. An air conditioner repair service from Comfort Masters Service Experts Heating & Air Conditioning is backed up in writing, because we're confident you will get the best AC repair service in Wheeling when you rely on our experts.
Consider that whether it's AC repair or replacement, sustaining your home comfort can be an investment. Since we rely heavily on our air conditioning systems to keep our homes nice and cool throughout warm temps, it makes sense to look for quality service and products that we can trust.


Meet the royal mistresses and courtesans who line the walls of the Metropolitan Museum on this tour with a twist. Enjoy a behind-the-canvas look at the women of the Met's most iconic pieces.
Learn about the feisty women in history during a guided tour. Walk through the Metropolitan Museum to discover some of the most influential female lawbreakers of all time.
Explore the iconic New Yorker Hotel with a professional guide, who leads you through decades of history. Hear this landmark's founding story as you marvel at the size and scale of the building.
Go back in time where you'll learn about the scandalous affairs that shaped the art you see today. Walk along with your guide as you explore the MET's exhibits while enjoying the tales that follow.
Play with adorable kittens at a local cattery for an hour of fun and affection. Watch these bundles of fur wrestle with one another, curl up in balls, and nap as you hang out in cat heaven.
Explore 5,000 years of art at a museum that's home to nearly two million pieces. Discover a NYC landmark when you check out the Metropolitan Museum of Art's permanent collection and its special exhibitions.
Raise a glass to the ghost of Thomas Paine and learn about the history of Greenwich's musical pub scene from a New York City theater performer. Follow a real musical theater performer on an interactive pub crawl through the eclectic and artsy community of Greenwich Village.
Hassle-free, prepaid and discounted access to 29 Las Vegas area attractions, allowing you to skip lines and enjoy massive savings.
Experience this new museum's inaugural exhibition titled "Unfinished" that is showcasing unfinished and excellent works. Check out the first art exhibition of the Met Breuer on your guided tour where you can study and observe the unfinished works of the masters.
Built in 1832, the Merchant's House is New York City's only 19th century home preserved virtually intact, inside and out, with the original family furnishings.
Discover the work of Kerry James Marshall on a guided tour of the Met Breuer. Explore the 35-year career of this influential artist as you see more than 70 pieces on display.
I enjoyed the tour until the final twenty minutes of it. We were forced to use a staircase that was packed with people going in both directions to reach the next painting. I was caring for my daughter who had difficulty navigating the steps. As a consequence, we lost the group. Given that there were many people in the museum on Sunday, the failure to recognize that some care should have been given to making sure that all members of the groups were present once we disembarked from the stairwell, caused our family to miss out on what I assume to have been a wonderful conclusion to Shady Ladies at the Met.
The tour was definitely not what I was expecting it to be but in the best way. The tour guide was awesome, I enjoyed how he interacted, and answered all questions. I personally cant wait to go on my next tour!
Since it is mostly women tour, timing for bathroom accommodation should be disclosed in the invitation otherwise remainder of the group waits too long for everyone to finish. Otherwise, content and tour guide is phenomenal - enjoyed very much.
Very interesting tour! Our tour guide was so knowledgeable and enthusiastic. We had a great time.


text:
'use strict';
// This file allows node apps to get the current
// test suite version number programmicatlly
// Glenn Jones

if(require.main === module) {
	// if they want the app
    var app = require('app.js');
}else{
	// if they want a module interface
	var pack = require('./package.json');

	module.exports = {
		'version': pack.version
	}
}

redpajama_set_name: RedPajamaGithub


text:
August 20, 2010 ED Review
Higher Education and the Economy
Jobs Bill
Bullying Summit
Summer Initiative
On August 9, President Obama delivered a major speech on higher education at the University of Texas at Austin. "I want you to know we have been slipping," he said. "In a single generation, we've fallen from 1st place to 12th place in college graduation rates for young adults.... Now, that's unacceptable, but it's not irreversible. We can retake the lead. If we're serious about making sure America's workers—and America itself—succeeds in the 21st century, the single most important step we can take is make sure that every one of our young people has the best education that the world has to offer." (For state, national, and global data on college completion rates, see the College Board's "College Completion" web site.) "Now," he continued, "when I talk about education, people say, well, you know what, right now we're going through this tough time.... So, Mr. President, you should only focus on jobs, on economic issues. And what I've tried to explain to people... is that education is an economic issue. Education is the economic issue of our time. It is an economic issue when the unemployment rate for folks who've never gone to college is almost double what it is for folks who have gone to college. It is an economic issue when almost eight in 10 new jobs will require workforce training or higher education by the end of this decade. And it is an economic issue when we know, beyond shadow of a doubt, that countries that out-educate us today will out-compete us tomorrow."
What is being done? At the K-12 level, the Administration launched the Race to the Top Fund, which is "already seeing powerful results across the county." At the postsecondary education level, the Administration is helping make college more affordable by shifting all federal student loans to Direct Loans and expanding Pell Grants; reinvesting in community colleges, Historically Black Colleges and Universities (HBCUs), and Hispanic-Serving Institutions (HSIs); and focusing on college completion by identifying best models. (A fact sheet outlining the White House's commitment to restoring America's leadership in higher education is posted online.) "When I look at all the young people here today," the President concluded, "I think about the fact that you are entering into the workforce at a difficult time in this country's history.... But I want everybody here to remember, at each and every juncture throughout our history, we've always recognized that essential truth: that the way to move forward, in our own lives and as a nation, is to put education first."
In other higher education news:
Secretary Duncan participated in a conference call with reporters to preview the President's speech and to discuss the impact of the Administration's agenda on the Hispanic community.
Under Secretary of Education Martha Kanter delivered related remarks at the State Higher Education Executive Officers (SHEEO) Higher Education Policy Conference.
The Department recently released the analysis that helped inform its proposed regulation providing a standard for for-profit and occupational postsecondary programs to demonstrate that they prepare students for "gainful employment."
Last week, the President signed into law a bill providing $26 billion to states: $10 billion to support an estimated 160,000 education jobs and $16 billion to help fund Medicaid budgets. The Senate approved the bill, by a vote of 61-39, on August 5. The House of Representatives followed, with a vote of 247-161, on August 10, and the President affixed his signature yet that evening. "With the aid of the jobs bill, these educators will be helping our children learn instead of looking for work," Secretary Duncan stated. "This is absolutely the right thing to do for our children, for our teachers, and for our economy."
Over the last two years, the Department has been able to support 300,000 education jobs through stimulus funding under the American Recovery and Reinvestment Act (ARRA). At this time, seven states have drawn down 100% of previously allocated funding under the State Fiscal Stabilization Fund, while 18 states have drawn down 80% or more. An independent report from the Center on Education Policy found 75% of school districts that received stimulus funds expect to cut teaching positions in the upcoming school year.
The application and guidance for states under the Education Jobs Fund have been sent to governors and made available on the Department's web site, and the Secretary and senior officials spoke with governors, Chief State School Officers, State Board of Education members, state legislators, superintendents, school board members, and union leaders about the release of the application and appropriate uses of funds. The Secretary urged governors to act quickly and to submit their applications as soon as possible—but no later than the statutory deadline of September 9—so money can flow to districts immediately and be used to support jobs this fall. The Department is using a streamlined application and is committed to turning around approvable applications within two weeks. (Note: Submitted state applications are available online.)
Also last week, the Department convened the first-ever National Summit on Bullying. The summit gathered a range of non-governmental organizations, corporate leaders, and state and local officials, as well as the members of the Federal Partners in Bullying Prevention Working Group. "Bullying is undeniable," Secretary Duncan explained, dispelling multiple myths about bullying. "It has a common definition, and a legal definition in many states. Effective prevention programs work to reduce bullying. And bullying is very much an education priority that goes to the heart of school performance and school culture." (Note: The Secretary's remarks are available online.)
Meanwhile, a new web site is a "one-stop" site for parents, educators, and community members seeking federal resources on bullying. The Department's reinvigorated Office for Civil Rights (OCR) has also stepped up enforcement in the last year, vigorously investigating complaints of bullying and harassment. In addition, many federal agencies (Education, Agriculture, Defense, Health and Human Services, Interior, and Justice) have been—and will continue—collaborating to combat bullying.
Over the past year, the Department has stepped up its efforts to address bullying to include a new, $27 million Safe and Supportive Schools grant program, a pilot that will enable states to measure school safety at the building level and to provide federal funds for interventions in those schools with greatest needs. Moreover, the Department's proposed blueprint for reauthorization of the Elementary and Secondary Education Act (ESEA) calls for a dramatic increase in appropriations for the Successful, Safe, and Healthy Students grants program.
On August 6, Secretary Duncan announced the awarding of $115.3 million to 124 school districts to improve the quality of teaching American history. The Teaching American History grant program aims to enhance teachers' understanding of American history through intensive professional development, including study trips to historic sites and mentoring with professional historians and other notable experts. Projects are required to partner with groups that have broad knowledge of American history, such as higher education institutions, libraries, museums, and non-profit historical and humanities organizations.
Then, on August 16, the Secretary announced the awarding of 12 charter school grants, totaling roughly $136 million, to state education agencies in Arkansas, California, Colorado, Georgia, Indiana, Michigan, Missouri, New Hampshire, Rhode Island, South Carolina, Texas, and the District of Columbia to increase public school options. The purpose of the Charter Schools Program is to increase financial support for the start-up and expansion of these public schools, build a national understanding of the charter school model, and increase the number of high-quality charter schools across the U.S. The Administration will invest more than $256 million this year to assist in the planning and implementation of charter schools and dissemination of successful practices.
Finally, on August 19, the Secretary announced the awarding of $28.8 million to 98 districts in 28 states to improve plans addressing all four phases of emergency management: prevention-mitigation, preparedness, response, and recovery.
In 2009, the Department launched a summer literacy series called "Read to the Top!" This series was created to combat summer learning loss in response to President Obama's national volunteer campaign, "United We Serve," which encouraged all Americans to participate in sustained service projects within their communities. This year, building on the structure of "Read to the Top!," the Department launched a summer literacy and enrichment series called "Let's Read. Let's Move." Through activities designed to promote reading and academic achievement, healthy lifestyles, and physical fitness, this series sought to bolster awareness about the high importance of summer learning and highlight the tenets of First Lady Michelle Obama's campaign to combat childhood obesity. Over seven sessions held weekly at the Department between mid-June and early August, Secretary Duncan, Cabinet members, Administration officials, celebrities, and public figures read children's books, discussed being healthy, and participated in games and activities with Washington, D.C.-area children in pre-kindergarten through third-grade.
In a recent letter to Chief State School Officers, Secretary Duncan addresses implementation of the federal School Improvement Grants (SIG) program.
Through September 7, the Department is soliciting comments on the Secretary's priorities for discretionary grant programs. There are 13 proposed priorities (from improving early learning outcomes to improving productivity) that the agency may use as appropriate for discretionary grant competitions in Fiscal Year 2011 and future years. These priorities will allow the Department and, by extension, program participants to focus limited federal resources on areas of greatest education need.
A new report from the National Center for Education Statistics (NCES), within the Institute of Education Sciences (IES), presents findings about teacher mobility and attrition among elementary and secondary school teachers in grades K-12 in the 50 states and the District of Columbia. Among public school teachers with 1-3 years of experience, 77.3% stayed in their base school, 13.7% moved to another school, and 9.1% left teaching in 2008-09. Among private school teachers with 1-3 years of experience, 72.2% stayed in their base school, 7.2% moved to another school, and 20.6% left teaching in 2008-09.
NCES is also initiating a new effort to link national and international assessments so that states can compare their own students' performance against international benchmarks. The linking study, to be conducted in 2011, is intended to enable NCES to "project" state-level scores on the Trends in International Mathematics and Science Study (TIMSS), using core data from the National Assessment of Educational Progress (NAEP). TIMSS measures students' learning in more than 60 countries.
The percentage of U.S. high school graduates meeting all four of ACT's College Readiness Benchmarks increased from 21% in 2006 and 23% last year to 24% this year, even as the "pool" of students taking the ACT continued to expand (up 30% since 2006). Based on the actual performance of successful students in college, these readiness benchmarks specify the minimum scores needed on each ACT subject area test to indicate a student is ready to succeed (a 50% chance of earning a "B" or higher or a 75% chance of earning a "C" or higher) in a typical first-year, credit-bearing college class in that subject area. Lack of college readiness is again most evident in the areas of math and science; just 43% of ACT-tested 2010 graduates are ready for college-level algebra, and only 29% are ready for college-level biology.
"It's one thing for states to get their fiscal houses in order and tighten their belts like families across America. Because families have been doing it, there's no reason that states can't do it, too. But we can't stand by and do nothing while pink slips are given to the men and women who educate our children or keep our communities safe. That doesn't make sense. That's why a significant part of the economic plan that we passed last year provided relief for struggling states—relief that has already prevented hundreds of thousands of layoffs. And that's why we're trying to pass a law that will save hundreds of thousands of more jobs in the coming year. It will help states avoid laying off police officers, firefighters, nurses, and first responders. And it will save the jobs of teachers like the ones who are standing with me today. If we do nothing, these educators won't be returning to the classroom this fall. And that won't just deprive them of a paycheck, it will deprive the children and parents who are counting on them to provide a decent education."
— President Barack Obama (8/10/10), in remarks at a Rose Garden event prior to passage of the Jobs Bill
As part of the Department's Back to School program, Secretary Duncan will be traveling by bus through the Southeast (August 26-27) and the Northeast (August 30-31). The title of the bus tour is "Courage in the Classroom." Senior staff will be blogging from the road.
On August 25, at 2:00 p.m. Eastern Time, the Department is offering a webinar on subrecipient monitoring. This presentation will provide recipients and subrecipients of Department grants an overview of this agency's subrecipient monitoring policies, emphasizing requirements under the Department's own General Administrative Regulations (EDGAR), the Office of Management and Budget's (OMB) A-133 Circular and Compliance Supplement, and new requirements under the ARRA. Agency staff and state-level representatives will spotlight several monitoring best practices in use by grantees that have proven both effective in ensuring compliance and cost-efficient, including using a risk-based monitoring approach, performing financial risk assessments, and using web-based monitoring.
Also, on August 31, also at 2:00 p.m. Eastern Time, the Department is offering another webinar: "ED's OCFO Recaps Cash Management Requirements for Recipients of Grants and Cooperative Agreements."
Please feel free to contact the Office of Communications and Outreach with any questions:
Director, Intergovernmental Affairs—Stacey Jordan, (202) 401-0026, Stacey.Jordan@ed.gov
Program Analyst—Adam Honeysett, (202) 401-3003, Adam.Honeysett@ed.gov
To be added or removed from distribution, or submit comments (we welcome your feedback!), please contact Adam Honeysett. Or, visit http://www2.ed.gov/news/newsletters/edreview/index.html.

redpajama_set_name: RedPajamaCommonCrawl


text:
Bridge to the Bicentennial
Tracey Leibach2015-05-01T13:58:32-04:00April 17, 2015|
Lois Graham and Mary Ellen Rathbun Kolb were the first two women to graduate from Rensselaer, on April 22, 1945. The two women and their classmates (as part of the Class of 1946) completed a war-accelerated program in two and a half years.
Lois Graham
In addition to traditional academic trials, Mary Ellen Rathbun Kolb remembered "there were over 400 men to each woman then. There wasn't a dorm for us so I had to take a room at Russell Sage College…I also remember my dread of climbing all of those stairs on the Approach each day, especially when the mercury was way below zero."
After graduating, Mary Ellen Rathbun Kolb worked for the Chrysler Corporation and married Ed Kolb, Rensselaer Class of 1944. Their daughter, Mary Jane Kolb Stanley, graduated from Rensselaer in 1969 and their son, John Kolb (vice president for information services and technology at Rensselaer), received his degree in 1979.
Mary Ellen Rathbun Kolb
Lois Graham knew that she wanted "a good education and a career in engineering." She became the first woman in the country to receive a Ph.D. in mechanical engineering (at the Illinois Institute of Technology) and subsequently became a professor at IIT. She was the first woman to receive a fellow award from the American Society of Heating, Refrigerating, and Air-Conditioning Engineers, honoring her for contributions as an educator in thermodynamics and cryogenics.
Graham's career spanned nearly 40 years at IIT, where she developed its model program for Women in Science and Engineering and its Minorities in Engineering Program. In recognition of her leadership in engineering education and her lifelong commitment to the advancement of women in the sciences, she was inducted into the Rensselaer Alumni Hall of Fame in 2003.
Mary Ellen Rathbun Kolb: An Oral History
Learn more about Lois Graham
As Rensselaer approaches its 200th year, the Institute is highlighting important milestones of how the world has been transformed by the achievements of Rensselaer people—past and present. Inside Rensselaer is showcasing some of the remarkable achievements and anniversaries throughout the year, including notable milestones and alumni and alumnae accomplishments.


The supplier's goods are delivered in cartons on stacked pallets. After unloading, the cartons are placed manually onto the conveying system that leads to the work stations in the goods-in area. Picking according to the goods-to-man principle is the basis of this retrofit.
Although CERP Rouen chose the automated S-Pemat system in 2000, the goal of the new project is to improve picking of items with a lower turnover rate. The Schaefer Carousel System (SCS) is thus used to replace a large part of the static racks. The combination of the SCS with the Pick to tote work station enables picking of more than 50 % of the items with medium or slow turnover rates.
After the orders are picked and before the goods are assigned to individual customers, the totes are conveyed to the picking stations in the shipping area. At the first picking station, where up to 1,800 totes per hour can be processed, the combined process of adding the address label and the lid is carried out. The next station ensures the totes are securely closed before delivery using a strapping process that hermetically seals the lid to the tote.
Customer orders are transported to the pharmacies via delivery truck and larger amounts of palletized goods are sent to CERP Rouen's subsidiaries at the same time.


Power supply sections typically occupy a large proportion of a design's real estate. Not only do they occupy a majority of space, but they critically impact the performance of the system.
Efforts to improve system level performance often require the improvement of the power system. These improvements, often considered the Figures of Merit ('FOM'), come in the form of smaller circuits, operating at higher efficiency while generating lower system noise, including electromagnetic type noise (EMI), as well as output voltage noise.
Great strides have been achieved in GaN technology, which promises these FOM improvements. A great deal has been published relating to the evolving state-of-the-art for GaN on Si and GaN on SiC, most of it related to switching regulators. There are fewer publications relating to these devices in linear applications, such as LDOs.
Another area which has received little attention is the migration from Silicon power metal oxide field effect transistor (MOSFET) devices to Gallium nitride (GaN) high electron mobility transistor (HEMT) devices. In the 1980's, technology began migrating from Bipolar Junction Transistors, which were the staple for power electronic switches, to MOSFET devices. The Si MOSFET devices offered many improvements, such as simpler drive requirements, lower on-state losses and much faster switching. The migration proved to be more difficult than might have been anticipated. The much faster switching of Si MOSFET devices promised lower switching losses, but there were also difficulties associated with the much higher di/dt the Si MOSFET presented. The leakage inductance of magnetics and relatively inductive printed circuit board planes allowed large voltage spikes which often caused device failures. Over time, engineers learned to design for the increased di/dt and Si MOSFET evolution has supported continuously improving performance. As we now approach the theoretical limits of Si MOSFET performance GaN promises to provide the path forward.
This paper is not about the improvements that GaN HEMT offers, as we have stated that much has been written on this topic. This paper address the migration path and the complexities that might be faced in attempting to migrate current state-of-the-art designs from the existing Si MOSFET devices to the current generation of GaN HEMT devices. This paper addresses both linear regulator technologies and switching regulator technologies, which each have their own migration paths and challenges.
Over the years, we have seen the evolution of power transistors using minority carrier bipolar junction transistor (BJT) devices progress to majority carrier based devices like metal oxide silicon field effect transistors (MOSFETs). The next big see-change seems to point to high electron mobility transistor (HEMT) GaN devices.
This section compares GaN to Silicon at both the material and device level. Only enhancement mode GaN (eGaN) device structures are considered in this paper, since this paper is focused on DC/DC VRMs and linear regulators.
Some of the material properties of Silicon and GaN are listed  in the table below.
GaN is a higher band semiconductor, as its band gap voltage, Eg, is much higher than Si. This results in lower leakage current and higher operating temperature capability. Similarly, the critical field parameter, Ecrit, is much higher in GaN, resulting in higher drain-source breakdown voltage for an eGaN HEMT.
Aside from higher electron mobility, the permittivity and critical field parameters are factors that impact resistance, which is an important parameter driving conduction losses during power conversion.
Electrical characteristics of the transistor are the aspects that affect the electrical performance at the circuit level. Some electrical characteristic ,  performance comparisons are listed in the table and discussed below.
Transistor breakdown occurs when the applied electric field exceeds the material parameter-critical field Ecrit. Since the Ecrit is higher for GaN as shown in table 2, the breakdown voltage, Vbr, tends to be higher for eGaN HEMTs.
The higher breakdown voltages of eGaN HEMT allow an increased margin for overshoot conditions during switching transients.
Drain-to-source leakage current can cause increased power loss. As previously mentioned, eGaN HEMT devices have lower leakage current due to the higher band gap, Eg.
The threshold voltage is the voltage below which the device is off. It is junction temperature dependent. Enhancement mode GaN (eGaN) HEMT devices tend to perform better in this regard. The Vth for the silicon device, for example, drops 38% when the temperature changes from 25 degrees to 125 degrees as compared to an increase of 3% for an eGaN device.
For eGaN HEMT, the nominal gate drive voltage is 5V, while the maximum rating is 6V. This leaves only 1V of margin. This is a tighter requirement compared to Si MOSFETs and requires damping of the gate-drive turn-on control loop.
And more importantly for migration, only a few currently available controllers have gate voltage outputs that are compatible with eGaN HEMT drive requirements.
The on-resistance has a direct impact on the conduction loss. The on-resistance of eGaN HEMT is lower causing less conduction loss, Pcond, and delivering higher conversion efficiency.
eGaN HEMTs can be portrayed as having gate-to-source, gate-to-drain, and gate-to-source capacitance as shown below. The capacitance is an important factor in determining the switching speed of the device and, therefore, the associated switching losses. The speed increases when the capacitance is reduced, as in the case of eGaN.
In addition to lower output capacitance, the gate charge required to turn on eGaN is lower, resulting in faster transition and switching rates. In our experiments of comparing the DRMOS vs eGaN LTC3891 boards, we noted that the driver operating current was 26mA for eGaN HEMT devices and 50mA for Si MOSFET devices, so this is one of the benefits of very low gate charge.
Apart from low gate charge, there is no reverse recovery charge, QRR=0, in eGaN HEMT. Consequently, there is no reverse recovery power loss for eGaN based regulator designs, a significant benefit that increases power conversion efficiency.
eGaN HEMT is inherently more radiation tolerant. For Si MOSFETs to be radiation hardened, the gate oxide needs to be thick and, therefore, trap a lot of charge, resulting in large shifts in parameters such as threshold voltage, which can result in field failures. Therefore, radiation-hardened Si MOSFETs tend to have lower switching frequency, lower efficiency, and larger size.
The size of an eGaN HEMT device is smaller than a Si MOSFET because of the smaller die size. Efficient packaging is also employed using the chip-scale LGA package. This results in a significant reduction in the overall size occupied by the eGaN HEMT on a printed circuit board (PCB). For example, in the table above, the area of an eGaN device is nearly 5 times smaller than a Si device.
Linear regulators are primarily used in applications, at lower operating current levels or those applications where voltage rail noise must be kept to a minimum. Since linear regulators generally present a higher output impedance than a switching regulator, these noise reductions are generally achieve via the lack of the switching ripple and associated spike noise. Improved power supply rejection ratio (PSRR) is also generally a benefit. However, the dynamic load current induced noise is generally higher for the linear regulator due to the higher impedance exhibited.
The significant FOM for the linear regulator include output impedance, dropout voltage (headroom), PSRR, and radiation sensitivity for some applications. Each of these FOM are considered in order to determine which device provides the better performance. Most are driven by the pass device, either Si MOSFET or eGaN HEMT. The requirements of the pass transistor are then considered in order to evaluate the migration path complexities that might be challenging.
The major design elements in linear regulators are the pass element, bandgap voltage reference, and error amplifier. The pass element transistor operates in the linear region.
In the case of a discrete linear regulator, the migration path for an existing design is very simple and there are only a few concerns.
Only N-channel designs can be migrated as there are no P-channel eGaN HEMT devices.
There must be sufficient cooling to account for the higher thermal resistance resulting from the smaller size of the eGaN HEMT device.
Each of the figures of merit are considered  for the discrete linear regulator.
And the output impedance model can now be represented as shown in Figure 4.
These results clearly show that even without increasing the bandwidth, which eGaN HEMT would allow, all three terms have Gfs in the denominator and so all are improved by the migration from Si to eGaN within an existing design. The benefits of the lower output impedance are directly reflected in the system performance. The measurements in figure 5 show greatly reduced clock phase noise using a lower output impedance eGaN HEMT voltage regulator compared with a typical linear regulator.
The control loop bandwidth, GBW, can be significantly increased by replacing the control opamp or in some cases by tailoring the frequency compensation. Either of these would further improve the PSRR.
An example of two regulators, one using a BJT pass device and one use an eGaN HEMT pass device is shown in Figure 6 below.
The eGaN HEMT device output impedance is lower. This means that less external output capacitance is required to maintain stable performance. Such smaller external capacitance requirement can be met easily with smaller size capacitors. This can further reduce the overall physical size of the regulator circuit.
The output impedance seen at the regulator output is low and its frequency response is equivalent to that of a 3.9nH inductance, which is the bare minimum considering the fact that the ESL of a tantalum capacitor is around 3.9nH. This shows that no additional inductance is being added by the eGaN HEMT that needs to be compensated by external capacitors, resulting in smaller overall size of regulator circuit.
Regulators with lower impedance result in the lower noise in the circuits they power. For example, a reduced impedance regulator yields lower noise clocks as shown the Figure 5 above.
As eGaN offers lower RDSon, the dropout voltage performance is improved as a result of replacing the existing Si MOSFET device with an eGaN HEMT device.
AC voltage fluctuations presented at the input to a regulator result in corresponding noise at the output. PSRR is a measure of the ability to reject such input variations.
Since eGaN HEMT offers significantly reduced junction capacitance compared to Si MOSFET, the PSRR performance is directly improved. Again, the control loop bandwidth can be significantly increased by replacing the control opamp or in some cases by tailoring the frequency compensation. Either of these further improve the PSRR.
To sum up linear regulator migration, it is evident that the migration of discrete linear regulators from Si MOSFET to eGaN HEMT is simple, with multiple FOM significantly improved. The considerations are only whether there is adequate cooling for the eGaN device and whether the gate is protected so that the eGaN gate-source voltage limit is never exceeded. In many cases, the control loop bandwidth can easily be increased, allowing additional performance improvement. It is also often possible to reduce the output capacitance, reducing cost and weight while improving reliability of the existing design. In applications where a radiation tolerant MOSFET is used the cost savings can be substantial.
Switching regulator circuits are found in many applications, suited primarily for those at higher operating current levels or those applications where efficiency is paramount and the voltage difference between the input and output is high. Large step-down ratio converters, for example, are often implemented as switching regulators. Since switching regulators generally act as point of load regulators for high speed devices, low output impedance over a wide band of frequencies and faster transient response is desired. Since switching regulators operate by turning the transistors on and off periodically, voltage and current ripple are generated at the input and output and are more noisy than linear regulators.
The significant FOM for the switching regulator include efficiency, transient response, and signal integrity of switch node waveforms. Each of these FOM are considered against the Si or GaN switch device parameters in order to determine which device provides the better performance. The requirements of the switch transistor are then considered in order to evaluate the path of migration and complexities that might inhibit such migration.
The major design elements in switching regulators are the main high side control switch, synchronous low side rectifier switch, gate controller, output inductor and capacitor filters. The switch element transistors operates in the saturation region.
In the case of a discrete switching regulator, the migration is not trivial and there are several concerns when migrating an existing design.
The eGaN HEMT does not have a body diode that is formed in a manner similar to the Si MOSFET's pn junction. However, the eGaN HEMT conducts similarly to the diode but with a higher voltage drop of 2V instead of 1V. This causes higher losses during the reverse conducting dead times. To provide an efficient path for reverse conduction current during the dead time, an external Schottky diode needs to be added. Another important design concern is to configure the gate controller to have as low a dead time as possible. The lower the dead time, the less reverse conduction flow there is, thereby achieving higher conversion efficiency.
The gate-source voltage must be kept below 5V or the eGaN HEMT device will be damaged. Most current gate controllers support higher gate drive voltage upwards of 7V. When migrating a design, such voltages need to be level shifted to 5V. In the migrated design figure below, the reverse biased Zener diode does this function of gate level shifting to 5V.
eGaN HEMT is susceptible to board layout parasitics. Compared with Si MOSFET, eGaN HEMT runs at much higher di/dt and dv/dt rates, making it vulnerable to corresponding Ldi/dt and Cdv/dt spikes. Such overshoots at the gate drive can exceed the recommended 6V of eGaN HEMT, potentially damaging the device, as shown in the Figure 10 below. Also, overshoot voltages incur power loss. Therefore, the PCB board layout needs to be optimized for suitable eGaN performance.
Figure 10: Gate loop and power loop parasitic inductances are highlighted in schematic; The higher speed eGaN devices can create significant ringing on the drain voltage which generates EMI and increases voltage stress.
The key figures of merit are considered for the discrete switching regulator.
The switching regulator power conversion efficiency depends on the dynamic power losses that occur during the transition of transistors from on to off and vice-versa. The dynamic power loss, consists of many components. Switching loss is due to the transient currents. Other losses include: output capacitance loss that is associated with the charging and discharging of intrinsic output capacitance of transistor; gate charge loss is the energy dissipated to charge the gate; reverse conduction loss that occurs in the low side transistor during the dead time; and reverse recovery loss that happens when the body diode transitions from the on-state to off-state.
Where is the gate charge.
By comparing the losses from the table below, we can note that the total loss is lower in eGaN device based switching regulator, provided the conduction loss is controlled.
With the migration to eGaN HEMT, the smaller eGaN HEMT device package results in reduction of regulator's physical size, provided the heat dissipation is handled. Another aspect that could improve the size reduction is simplifying the filter components-inductor and capacitor- by increasing the switching frequency. The eGaN HEMT device output impedance is lower and this means that less external output capacitance is often required to maintain a low impedance and stable performance. This can further reduce the physical size of the regulator circuit and save cost.
Measuring the switch node voltage is the most basic measurement for a power switch. This is typically measured from the drain-to-source of the device.
The fast switching of eGaN reveals many measurement challenges . The switch node waveforms for eGaN vs. Si based regulators are compared in the measurements of the DRMOS and eGaN boards. The eGaN waveform are found to have sharper transitions.
Given the voltage step down specification of 12V to 1V, a Si MOSFET based switching regulator board- Fairchild DR MOS regulator was migrated to EPC eGaN HEMT based. The following measurements were performed on these boards.
The gate drive waveforms for eGaN HEMT based regulators vs. Si MOSFET are compared in the measurements of DRMOS and eGaN LTC3891 test boards. For eGaN HEMT, it is important to verify that the PCB layout parasitic inductance is minimized in order to keep the gate voltage under designated limits. The measurements below show that the gate voltage on the eGaN LTC 3891 regulator is contained below 6V, the maximum allowed gate voltage.
EMI measurements on the Si MOSFET and eGaN HEMT test boards from figure 8 are shown here. The measurements are uncalibrated using either H-field or E-field probes close to the board and placed as noted in the figures. A telescopic antenna approximately 3 feet from the test board is also included for each boards. The telescopic antenna is shown in Figure 13 below.
As shown in the figure 14 above, the emissions are quite different for the eGaN HEMT and Si MOSFET devices, especially at the higher frequency. The eGaN device is expected to have more high frequency signal due to the faster edge speed. The result is that the EMI filtering and screening requirements are likely different for eGaN HEMT and Si MOSFET presenting another challenge for the migration of existing designs.
To summarize, it is clear that the migration of discrete switching regulators from an existing Si MOSFET design to eGaN HEMT is not trivial. The migration is challenging because the majority of the present day controllers have gate drive voltages that exceed eGaN ratings and existing controllers also have long dead times where the reverse conduction of eGaN HEMT is lossy, eroding the efficiency benefits of eGaN HEMT. The EMI filtering requirements and PCB decoupling requirements are also different for the eGaN and Si devices. In general, the design has to be eGaN HEMT specific in order to take full advantages of the eGaN device benefits: higher switching rates, power conversion efficiency and faster transient response.
We have set out to explore the potential for migrating existing linear and switching type Si MOSFET based designs to eGaN HEMT technology. We have shown that existing linear regulator designs can directly benefit from replacing the Si BJT or MOSFET with eGaN HEMT. We have also shown that as part of this migration it is also possible to increase the operating bandwidth of the regulator further improving the performance.
The migration of switching designs from Si MOSFET to eGaN HEMT is complex and we cannot take full advantage of eGaN technology simply by changing the switches from Si to eGaN. For switching regulators, it is generally necessary to design it for eGaN from the start. The eGaN design offers great performance improvements, though this improvement necessitates careful design of the gate drive, dead time, PCB decoupling and EMI filtering to optimize the benefit. Such an optimized eGaN HEMT based switching regulator design will outperform a Si MOSFET based solution in most cases.


A fixed and floating charge granted in 2007 as part of a "deferred purchase price" arrangement was initially stamped with mortgage duty of $5 on the basis that it did not secure any "advances" at the time of its execution.
The Chief Commissioner assessed additional duty on 24 Dec 2010 in respect of "advances" plus capitalised interest totalling $102,600,000, following execution of a variation deed.
On 30 January 2013 Justice Gzell found that the Chief Commissioner was correct to assess the Charge to additional mortgage duty, on the basis that the Variation Deed constituted an "advance" under s 206(a)(iii) of the Duties Act. However mortgage duty should only be imposed in respect of amount totalling $92,006,545, which excluded the capitalised interest.
The taxpayers applied for a review of the Chief Commissioner's decision on 24 December 2010 to assess a fixed and floating charge ("Charge") to additional mortgage duty (of $410,486) based on a further advance of $102,600,000.
The Charge was granted in 2007 and, upon execution, was stamped with duty of $5 on the basis that it did not secure any "advances" at the time of its execution.
The Charge formed part of a "deferred purchase price" arrangement ("DPP Scheme"). In essence, a DPP scheme is one under which a financial institution may subscribe for and sell loan notes for a price. In this case, the Charge secured payment of that price, but payment could be deferred. As the Charge secured the payment of an unpaid purchase price rather than the repayment of a loan, this arrangement fell outside the provision in s 206 of the Duties Act 1997 (NSW) ("Duties Act") defining what, for mortgage duty purposes, was an "advance".
The Charge secured notes issued in 2007 that had a face value of $92,006,545. Interest was capitalised on the value of the notes issued, and as at 1 July 2009, the total amount outstanding which was secured by the Charge was $102,600,000.
Under various Variation Deeds, the taxpayers elected to defer (or extend) the due date for payment of the purchase price on several occasions, including on three occasions after 1 July 2009.
The Chief Commissioner assessed the Charge to additional duty (based on an advance of $102,600,000) on 24 December 2010 ("Assessment") in respect of those deferrals (or extensions), after 1 July 2009, of the date for payment of the purchase price.
Justice Gzell ultimately found that the Chief Commissioner was correct to assess the Charge to additional mortgage duty, however mortgage duty should only be imposed in respect of an amount of advances totalling $92,006,545 (and not $102,600,000 as originally assessed).
Whether the Variation Deed, by deferring (or extending), the due date for payment of the purchase price, amounted to a "forbearance to require the payment of money owing on any account whatever", and hence an "advance", within the meaning of that term in s 206(a)(iii) of the Duties Act.
Did the "amount secured" by the Charge exceed the "amount secured" by it at the time a liability to duty last arose under the Act as a result of the making of that advance, within s 208(2) of the Duties Act?
Was the amount secured by the Charge, for mortgage duty purposes, the face value of the notes ($92,006,545), or the total amount outstanding ($102,600,000)?
Was that advance "made under an agreement, understanding or arrangement" for which the Charge was security within s 213(1) of the Duties Act?
1.Although a forbearance may be non-contractual, it may also be contractual (ie contrary to the taxpayers' submission, Justice Gzell found that a variation of a contract which involves a permanent change in the rights and obligations of the parties may constitute a "forbearance"). Justice Gzell relied on the decision in Tozer Kemsley & Millbourn (A/Asia) Pty Ltd v Point (1961) SR (NSW) 751 as authority for the proposition that a forbearance could be achieved contractually. In this case, the Variation Deed was merely the form in which the forbearance (being the extension of time for payment) was achieved, and hence the Variation Deed constituted an "advance" under s 206(a)(iii) of the Duties Act.
second, when a liability to duty last arose – which was upon execution of the Charge when the liability to duty was $5 based on the amount secured being nil.
The amount secured by the Charge for mortgage duty purposes was the face value of the notes ($92,006,545), and should not have included the further amounts which constituted capitalised interest. In this regard, Justice Gzell relied on the case of Bank of New South Wales v Brown  HCA 1 for the proposition that the character of a debt for interest was not altered when it was capitalised. He found that the obligation of the taxpayers remained to pay $92,006,545 plus interest, and that the capitalised interest did not become an advance once the date for payment was extended.
Justice Gzell found that the Variation Deed was made under "an agreement, understanding or arrangement" for which the Charge was security for the purposes of s 213(1) of the Act. Based on the terms of the security documents, the Charge was security for obligations owed by the taxpayers, which included those obligations arising from the forbearance to require the payment of money owing. Justice Gzell accepted the Chief Commissioner's submission that it is highly unlikely that the secured parties would accept a position of having security over the principal under the notes but acquire no security over any money owed to them in circumstances where the terms of payment had been the subject of a variation made after the original financing had been put in place.
the parties were to address the Court on the issue of costs.


text:
View dates and book
Jack Dee: Off The Telly
Join him for his new stand-up tour (food and beverages not included).
"In these difficult and uncertain times people need hope – a ray of sunshine to brighten their day. And that's very much where I come in" says Jack.
Star of TV sitcoms Bad Move, Lead Balloon and Josh, Jack also hosts the legendary Radio 4 show I'm Sorry I Haven't A Clue. Additional credits include presenting Jack Dee's Helpdesk on BBC Two, C4's The Jack Dee Show, ITV's Jack Dee's Saturday Night, BBC's Jack Dee's Happy Hour and Jack Dee Live At The Apollo. "In fact," explains Jack, "I've probably appeared in every TV show with my name in the title".
Other sidelines include Motivational Speaking, which Jack describes as "basically a total waste of time, talking to losers, but the cash is decent" and then adds "don't print that". It's so hard to tell when he's being serious.
In recognition of his charity work, Jack was denied an OBE in 2015.
May contain adult themes language.
Mon 10 & Tue 11 May 2021
Marlowe members save money and book first (on most shows)
The Alternative Comedy Show
Discover your new favourite comedian at this celebration of comic originality and ideas.
Sandi Toksvig: The National Trevor Tour
Sun 13 Jun 2021
Sandi is back with her one-woman comedy show.
Thinking Drinkers: Pub Quiz
Thu 29 Apr ‐ Sat 1 May 2021
Where drinking meets comedy! The boys are back with a brand-new show.
Mon 10 7:30pm £27
Tue 11 7:30pm £27


Please use this form to request personal information from your file.
As a current or former member of the Ontario College of Teachers or as an applicant for membership, you are entitled to personal information that the College has pertaining to you.
Personal information includes documents that are in the public domain as well as documents that you have supplied to the College such as copies of your application form, employment authorization, birth certificate, change of name certificate and teaching certificate. You may also use this form to request copies of documents other institutions have provided to us on your behalf.
The College will make every effort to respond to your request within 30 days.
the request is frivolous or vexatious, or is otherwise an abuse of process.
If your request for access is partially granted or denied, you will be provided with reasons for the denial or the decision to grant you partial access. Any applicable refund will also be issued.


Our professional sales service provides vendors with complete confidence from day one. From our initial instruction to handing over the keys on completion, we take consummate care of our clients and... their properties throughout the entire sales process. Finding just the right property can seem extremely frustrating at times so we go to great lengths to match buyers with appropriate properties to fit their chosen criteria's as closely as possible.
Aspect is an independent estate agency driven by partners with over 30 years experience of the property industry and all it has to offer. We can help and advise you with every aspect of your property... needs whether you wish to buy, sell, let or rent. We also aid other property professionals in the acquisition of land, developments and buy to let portfolios throughout London and the Home Counties.
INNER ESTATE is a successful, independent owned firm of Estates Agent in 1028 Harrow Road, Kensal Green, London NW10 5NN specializing in Lettings in Residential & Commercial Properties and Property... management. We have local knowledge of Properties in Willesden Green, Kilburn, Kensal Green, Kensal Rise, Dollis Hill and Harlesden.
Putting our experience in all aspects of the property industry we provide a comprehensive service for clients looking to buy, sell and rent their property. We also offer financial services and... conveyance. In addition we offer the services of interior design and home removals. We aim to try and take away all the stresses and strains that are associated with the property industry. Empire Estates are here to provide the 'one stop shop'.
Mile. is delighted to bring to the market this newly refurbished studio apartment set on the second floor in a Victorian building on Chamberlayne Road. Located in the heart of Kensal Rise, this. Over... the last few years Kensal Rise and Queens Park has become one of the trendiest parts of town.


sensablend.com 9 out of 10 based on 300 ratings. 900 user reviews.
MSD Tach Adapter PN 8920 If your tachometer doesn't work correctly after installing an MSD Ignition Control, always try to connect the tach's trigger wire directly to the tach output of the Ignition. If the tach still registers incorrectly, install this Tach Adapter.
If you are triggering an MSD 6 or 7 Series Ignition with its white wire or points terminal, you will need the PN 8910 Tach Adapter. The PN 8910 will correct the operation of most voltage triggered tachometers or fuel injection systems that do not work directly off the tach output terminal of the MSD Ignition Unit.
MSD 8920 Magnetic Pickup Tachometer Adapter. by MSD. 4.2 out of 5 stars 31. $67.27 $ 67. 27. Get it as soon as Mon, Mar 18. FREE Shipping by . ... Autometer Tach Adapter for Distributorless Ignitions (am9117) by Auto Meter. $109.95 $ 109. 95. FREE delivery. Only 14 left in stock order soon.
: msd tach adapter. Skip to main content. From The munity. Try Prime All ... MSD 8910EIS Tachometer Adapter. 5.0 out of 5 stars 1. $58.10 $ 58. 10 $64.56 $ 64. 56. FREE Shipping. Only 1 left in stock order soon. MSD 8910EIS Electronic Ignition System Tach Adapter. $58.10 $ 58. 10.
Tach Adapters. If your tachometer, fuel injection, fuel pump relay or even aftermarket water injection does not work properly after installing an MSD ignition, you may need an MSD Tach Adapter. Home Accessories Tach Adapters Narrow Results. Items 1 5 of 5. Sort By.
Strip the end of the trigger wire for the tachometer, and place a female to female connector to it. Fit new wire from the female female connector, and run the wire directly from the spool through an open point on the firewall. Run enough wire to reach the MSD ignition control box mounted on the firewall in the engine compartment.


text:
Man shot in Ferguson identified as 18 year old, "friend of Michael Brown"
Posted by Alec Cope | Aug 10, 2015 |
An unidentified man lies wounded while being detained by Ferguson police, Aug 10th. Rick Wilking / Reuters
By Alec Cope
A day after the year commemoration of Michael Brown's death, 18-year-old Tyrone Harris Jr. of St. Louis, who was "real close" to Brown, was killed by police the St. Louis Post-Dispatch reports.
His father suspects that there is more going on than what has been released so far.
pic.twitter.com/CoDwsvbEdw
— Search4Swag (@search4swag) August 10, 2015
Head of St. Louis County police Jon Belmar stated that plain-clothed detectives received fire on Sunday evening. The suspect ensued into a chase where the officers shot the man whom had his identity withheld. The police chief went on to describe the condition of the suspect as "unstable".
The man shot was tracked throughout the protest as police believed he was armed. The police have stated this man approached them and fired a stolen 9mm pistol at them randomly.
Belmar then indicated that the 6 – 12 year veteran police officers are on administrative leave and didn't sustain "serious" injuries.
Acting head of the Ferguson Police Department Andre Anderson was speaking to CNN when around 20 shots were fired and in fact recorded during the interview.
VIDEO: Gunshots interrupt CNN interview with #Ferguson police chief (video: @sarasidnerCNN) http://t.co/3kbXJ51VBu pic.twitter.com/VLqrjk7MP9
— Grasswire (@Grasswire) August 10, 2015
St. Louis County police head Belmar, told a news conference the following morning on Monday that a second shooting had erupted in the town of Ferguson. The incident allegedly involves two groups from the West side of Florissant Avenue and had happened just before Harris Jr. were shot by police.
Belmar added that 40 and 50 shots were fired in an exchange between the two groups, and the incident he described as "remarkable" lasted around 45 seconds. He defined the point of distinguishing the shooters from actual protestors, stating "They were criminals. They weren't protesters,".
Release from @stlcountypd regarding violence in Ferguson last night pic.twitter.com/FpUV7jDp6r
— Wesley (@WesleyLowery) August 10, 2015
If you still have questions about last year's shooting don't worry, we've already got you covered with a WRC video below.
The drastic nationwide militarization of police has been justified with the breakdown in social "peace". View the video above for sources and detail but the first Ferguson event in total, was a total problem-reaction-solution. Those at the helm of power allowed a problem to boil until the cusp of explosion, once that occurred the reaction was stimulated with the old methodology of race division; the police state is the solution.
If you are within the area of these events unfolding, please don't participate in any rioting or criminality that may ensue as a result of this tragedy. That is exactly what those at the center of this thing want. What better way to propagate and ensure the continuity of a police state if you get the people to want it themselves?
This video explains the ultimate truth about where we are on this planet, right now. It's something that is appropriate for this situation, and may put things into perspective, you never thought possible. Thank-you for reading.
PreviousPerson shot during Michael Brown anniversary protest in Ferguson
NextUS ex-intelligence chief states ISIS's rise was: "a willful Washington decision"


text:
Quad Cities Location/Directions
Quad Cities Blog
Career Development Programs
Amina Grace Speech and Language Program – Learn more and enroll
i have a Voice Gallery
Superhero Run & Walk – June 3, 2023
Gala – Thank you!
Educator Symposium – See link for details.
Meet Madeline
Please help us welcome Maddie to the Playhouse. She is one of the interns from St Ambrose University spending the spring with us. We asked Maddie to share a little bit about herself to help us and all of you get to know her.
Hi! My name is Madeline Blackbourn, but most people call me Maddie. I am a student at St. Ambrose University where I am majoring in Human Performance & Fitness. I have also been accepted into the SAU Occupational Therapy Graduate Program and will be starting classes this upcoming fall. At St. Ambrose, I am part of the competitive dance team and a member of the club known as STEP, which stands for Service Dog Training and Education Program. I am currently training a service dog named Lassen who is about 8 months old. I am beyond excited to be interning at GiGi's Playhouse this semester and cannot wait to start helping out!
Maddie is bringing her dance team experience to the Playhouse by leading the spring dance program for our school-age friends. She is also tutoring two participants in literacy and helping with the spring GiGiFIT and GiGi's Kitchen programs!
We can't wait for you to meet her!
Texts from GiGi's
GiGi's Playhouse Quad Cities is launching a new way to communicate. We know that sometimes checking email can be overwhelming. We also know that most...
December 2023 Highlights
Every month we take a few minutes to look back at the #bestofall moments from the previous month. This fall Abby was the only participant...
Virtual Tutoring Success
One of COVID's silver linings was the introduction of virtual tutoring. Our national office continues to offer many programs virtually via the GiGi's At Home...
Because of you we can continue to offer FREE purposeful programming at GiGi's Playhouse Quad Cities!
Michaela – Best of All
quadcities@gigisplayhouse.org
Playhouse Business Hours
Please see calendar for details
GiGi's Playhouse Quad Cities is a non-profit, 501(c)(3) organization and is solely funded by donations. IRS identification number 45-2777850


Murray Polner and Thomas E. Woods, Jr., have edited a new collection of writings called "We Who Dared to Say No to War: American Antiwar Writing from 1812 to Now." Read it and weep … and cheer. Weep because we've been lied into wars in very similar ways for two centuries and have had to discover the deception anew each time. Cheer because some people have been there to denounce the lies on the spot every time, and their ranks have steadily grown.
In 1916 Woodrow Wilson was reelected president on the slogan "He Kept Us Out of War," and proceeded to set up an early version of the White House Iraq Group known as the Committee on Public Information whose mission it was to make Americans hate Germans. The lies (including about the content of the Lusitania) were so effective that they shaped the settlement at the end of the first world war, contributing to the rise of Nazism and the second world war. We entered that second war following an unprovoked attack by the Japanese, unless the threats we had sent the Japanese and the economic sanctions we had imposed on them count as provocation, and ignoring the fact that the U.S. Navy had been given, nine days before Pearl Harbor, orders to shoot down any Japanese planes and blow up Japanese boats it encountered.
The lies of the Cold War, and the Gulf of Tonkin, and the mythical babies taken out of incubators prior to the first Gulf War are still familiar to most Americans. What is unfamiliar to most Americans is the history of truth telling that has accompanied all these warmongering lies. If you want to be informed and inspired by this rich heritage, pick up a copy of "We Who Dared to Say No to War." Here we find Daniel Webster and John Randolph opposing the War of 1812, Henry Clay and Abraham Lincoln Denouncing the Mexican War, Stephen Crane and William Jennings Bryan opposing the war on Cuba and the Philippines, Robert M. La Folette and Helen Keller speaking against World War I, and many, many lesser known prophets for peace. And the endless wars against native Americans are not even included.
Henry Wallace and Robert Taft oppose the Cold War, while Wayne Morse and Philip Berrigan oppose the slaughter in Vietnam, along with many other eloquent voices. And the chapter on Iraq and the "War on Terror" is richer than any before it. Numerous other lesser wars might have been included as well, but this collection is a thing of beauty.
"Where is it written in the Constitution," asked Daniel Webster, "in what article or section is it contained, that you may take children from their parents, and parents from their children, and compel them to fight the battles of any war, in which the folly or the wickedness of Government may engage it?"
"[T]aking for true," said Abraham Lincoln, "all the President states as fact, he falls far short of proving his justification; and … would have gone farther with his proof, if it had not been for the small matter, that the truth would not permit him."
"I have agonized over this vote," said Congresswoman Barbara Lee on September 15, 2001, when she stood alone against launching an open-ended war on Afghanistan. "But I came to grips with it in the very painful yet beautiful memorial service today at the National Cathedral. As a member of the clergy so eloquently said, 'As we act, let us not become the evil that we deplore.'"


text:
Q: Is is possible to have some 0-value pixels as NoData while others not in GeoTiff using GDAL? I have a GeoTiff file in byte. It has values ranges from 0 to 101, while 0 is NoData value, and 1 - 101 are real data. I want to recode the actual data to 0 - 100, but also have the NoData pixels remain 0. This means that in the result Tiff file, there are some 0-value pixels are real data and the others are NoData. Is it possible to do this process with GDAL?

A: It's not possible to do exactly what you say in your question.  When looking at a given pixel, GDAL decides if it's NoData by looking at the numeric value.  A given pixel will either be NoData (if it's 0 in your case) or not.  Zero can't be both a "real" value and  a NoData value.
But there are other possibilities, depending on how you want to eventually use the resulting raster.
You could add an additional "mask" band to your raster (with the nearblack utility and its setmask option, for example).  For each pixel, the new mask band would have a value of 0 when it's a NoData value, and a value of 255 for everything else.  Depending on how you're using the data, the value of the mask band at a given pixel would allow you to tell the difference between the NoData zeros and the "real" zeros.

A: No it is not.  The NoDataValue is purely a metadata flag that signals to the interpreter (human, GIS, whatever) that raster pixels with this NoDataValue should be interpreted as NoData.
The internal data structure for tiffs requires that every pixel have a value associated with it. It is not possible to flag certain sets of a value as NoData and certain sets of the same value as "real".

A: You could add a second band indicating real or NoData. Create your NoData band. Answer from csd suggests how to.
Create multi band raster with -separate tag in gdal_merge.py:
gdal_merge.py -separate -o out.tif data.tif nodata.tif

redpajama_set_name: RedPajamaStackExchange


Heres a picture showing a rough difference. The rifle length is installed on an AR-15 so the alignment is approximate. The barrel in the 15.5 is an 18" with the threads removed.
I really like the way that 15.5" looks!!!


In order to be effective in today's workplace, you need to be able to communicate information in a variety of formats, including the often-feared and dreaded oral presentation, delivered for an audience. Learn how to best organize your information, practice and master effective delivery techniques, and conquer your fears and deliver winning presentations. As a participant, you will have the opportunity to deliver a short presentation to a small group of co-participants and receive valuable peer feedback about the presentation content and your delivery technique.