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Top 6 at 6 - Climate Change Legal Highlights of the First Six Months of 2015
by J. Wylie Donald
Some might say that the Clean Power Plan is all one needs to talk about in any highlights article on recent climate change legal issues. When final the CPP will expand the scope of the Clean Air Act profoundly, impact the electricity business fundamentally, restrict the coal industry severely and raise electricity rates for consumers by more than just pennies.
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Carbon Dioxide | Climate Change Effects | Florida | Legislation | Regulation | Rising Sea Levels | Supreme Court | Utilities | Year in Review
Tags: Mississippi Power, Mississippi Public Service Commission, Southern Company, Kemper Project, Andrew Weaver, National Post, defamation, Edward Wegman, National Geographic, Miami-Dade, limestone, MATS, Mercury, Michigan v. EPA, Clean Power Plan, lignite, Phil Stoddard, Margate, dunes, MCQBP
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Top 6 at 6: Highlights of the Top Climate Change Legal Stories in the First Half of 2014
Our semi-annual look at the top climate change legal stories is keyed on EPA. You hardly have to have been awake to be aware of the Clean Power Plan and UARG v. EPA. But other things have stirred the pot as well: three reports – two by the Intergovernmental Panel on Climate Change and the other by Standard & Poor's, and two climate change lawsuits – one by Illinois Farmers Insurance Company and the other by Biscayne Bay Water Keeper. 1. The Clean Power Plan - On June 6 EPA issued a 600+ page proposal directed at controlling carbon dioxide emissions from operating power plants. By June 2016 States are required to submit plans for such control (there is also an option for extending the due date if more time is needed). EPA's press release summarizes what is supposed to happen: The Clean Power Plan will be implemented through a state-federal partnership under which states identify a path forward using either current or new electricity production and pollution control policies to meet the goals of the proposed program. The proposal provides guidelines for states to develop plans to meet state-specific goals to reduce carbon pollution and gives them the flexibility to design a program that makes the most sense for their unique situation. States can choose the right mix of generation using diverse fuels, energy efficiency and demand-side management to meet the goals and their own needs. It allows them to work alone to develop individual plans or to work together with other states to develop multi-state plans. Thus, the learning that has gone on over the past several years as embodied in RGGI, AB 32, RPSs and other state initiatives is going to have an opportunity to prove itself. 2. UARG v. EPA - The Supreme Court has now weighed in on climate change three times: Massachusetts v. EPA, Connecticut v. American Electric Power and, this past month, Utility Air Regulatory Group v. EPA. – Readers will remember the D.C. Circuit's 2012 ruling in favor of EPA defeating challenges to the Endangerment Finding, the Tailpipe Rule, the Timing Rule and the Tailoring Rule. UARG was a limited appeal of that decision and accomplished nearly all that EPA required. At the end of June the Supreme Court affirmed EPA's greenhouse gas regulatory program, with the exception of rules focused on a small group of emitters. How small? Before UARG EPA estimated its rules would reach 86% of GHG emissions. After UARG EPA can reach only 83%. In a nutshell, EPA has authority under the Clean Air Act to impose GHG emission regulations on major emitters already subject to regulation. This bodes ill for those seeking to challenge the Clean Power Plan. 3. Climate Science - The science continues to mount demonstrating the effects of climate change. In two more contributions from the Intergovernmental Panel on Climate Change, Working Group II lays out in Climate Change 2014: Impacts, Adaptation, and Vulnerability "how patterns of risks and potential benefits are shifting due to climate change." The report also assesses how "impacts and risks related to climate change can be reduced and managed through adaptation and mitigation." In Climate Change 2014: Mitigation of Climate Change Working Group III "respond[ed] to the request of the world's governments for a comprehensive, objective and policy neutral assessment of the current scientific knowledge on mitigating climate change." The two reports complement Working Group I's report released last year, which concluded: "It is extremely likely that human influence has been the dominant cause of the observed warming since the mid-20th century." 4. Climate Risk - It has been a common theme for this blog that acceptance of climate change will occur not because of science, but because of the responses of business entities that recognize that climate change denial is not in their best interest. But it is also a theme that until there is an actual identified business reason to take an action, businesses will not go out on a limb. Standard & Poor's exemplifies our thinking. In March it issued a short report, Climate Change is a Global Mega-Trend for Sovereign Risk. In the report S&P concludes "the evidence suggests that it is probably safe to expect that for most national economies, other things being equal, climate change will negatively impact national welfare and economic growth potential. Observations corroborating this expectation could lead Standard & Poor's to lower sovereign ratings on the most affected sovereigns." That is, "we see a potential problem but we aren't ready to act just yet." Notwithstanding S&P's failure to move today, this pronouncement does communicate to the buyers of sovereign debt that they had better pay attention to climate change as it may be material to their investment. 5. Illinois Farmers Insurance Co. v. The Metropolitan Water Reclamation District of Greater Chicago - It didn't take Illinois Farmers long (less than 60 days) to drop its lawsuits against dozens of municipalities and other government entities alleging negligent management of stormwater. The central feature was the claim that the government entities were on notice of the effects of climate change and did not incorporate them into their stormwater planning. We presume the entities' sovereign immunity defense persuaded Illinois Farmers to go quietly in the night. But the insurance company has competent lawyers and sovereign immunity surely was no surprise. So, was this the proverbial shot across the bow, putting government, and the entities that serve government – the design and engineering firms – on notice that climate change had better enter into their forecasts or they will be pursued for negligence? Time will tell. 6. U.S. v. Miami-Dade County - Miami-Dade's sewer insfrastructure is falling apart and EPA compelled the city into a consent order under the Clean Water Act to get things cleaned up. Enter the intervenor, Biscayne Bay Waterkeeper, who insisted that the consent decree was improper as it did not take rising sea levels caused by climate change into effect. Federal district court judge Federico A. Moreno considered the consent decree and rejected it because it lacked sufficient incentive for the county to abide by the decree. The court did not mention BBWK's concern. Nevertheless, Miami-Dade appears to have gotten the message that it needs to be paying attention. The county has a task force devoted to sea level rise and it is preparing a report with recommendations. This is from the April 28 minutes of the task force: Chairman Ruvin said that sea level rise was inevitable, and to ensure that the community remained insurable, it was important to begin implementing a plan to address this issue. … Chairman Ruvin noted the Task Force members had heard enough information to understand the necessity of developing a plan to address sea level rise. He said that there were global engineering firms with entire divisions devoted to sea level rise, and suggested that the County conduct a competitive process to retain the services of some of these firms to develop this plan. It remains to be seen, of course, whether the task force's recommendations will be accepted.
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Carbon Emissions | Climate Change Litigation | Regulation | Rising Sea Levels | Supreme Court | Year in Review
Tags: IPCC, UARG v. EPA, Clean Power Plan, coal, S&P, Mega-Trend, Cook County, stormwater, Miami-Dade, sewer, infrastructure
The Top 6 at 12: Highlights of the Top Climate Change Legal Stories in the Second Half of 2013
2013 has drawn to a close; here is our take on the top six climate change legal stories in the last six months. 1. Climate Change Assessments - Blockbuster legislation may have been evaded once more but that has not stopped those in the trenches. Assessments of climate change risk are becoming more routine. For example, the September 2013 Record of Decision for the Gowanus Canal Superfund Site required assessment of "periods of high rainfall, including future rainfall increases that may result from climate change" in implementing certain aspects of the cleanup remedy. Another example was provided by the Department of Housing and Urban Development, which in November required in its second round of community block grants for disaster relief that prospective grantees consider in their Comprehensive Risk Analysis "a broad range of information and best available data, including forward-looking analyses of risks to infrastructure sectors from climate change and other hazards, such as the Northeast United States Regional Climate Trends and Scenarios from the U.S. National Climate Assessment, the Sea Level Rise Tool for Sandy Recovery, or comparable peer-reviewed information." Even the Nuclear Regulatory Commission looked at climate change with regard to its September draft generic environmental impact statement for the long-term continued storage of spent nuclear fuel. 2. Low Carbon Fuel Standards - In Rocky Mountain Farmers Union v. Corey the Ninth Circuit reversed several district court rulings limiting under the "dormant Commerce clause" the California Air Resources Board's Low Carbon Fuel Standard. Although the Commerce clause of the Constitution, U.S. Const., art. I, § 8, cl. 3. "does not explicitly control the several states," it "has long been understood to have a 'negative' aspect that denies the States the power unjustifiably to discriminate against or burden the interstate flow of articles of commerce.'" Rocky Mountain at 31 (citation omitted). California's Low Carbon Fuel Standard supported carbon dioxide emission reduction "by reducing the carbon intensity [i.e., the amount of carbon dioxide emitted per unit of energy produced] of transportation fuels that are burned in California." It thus potentially burdened producers of ethanol in the Midwest and petroleum producers outside California, but that did not matter. Specifically, the court held that the LCFS was not facially impermissibly discriminatory in favor of ethanol, was not improperly extraterritorial and did not discriminate against petroleum fuels. Accordingly, California is still on its path to a reduction in the carbon intensity of its fuels by 10% by 2020, as mandated by the 2006 Global Warming Solutions Act. 3. The Cost of the Grid - On November 14, the Arizona Corporation Commission ruled that Arizona's net metering program should spread the cost of maintaining a reliable grid among all of Arizona Public Service's customers, including its rooftop solar customers. Up to that point rooftop solar customers were paid for the electricity they provided to the grid at retail rates, without any adjustment for the cost of the grid. The Commission concluded that this resulted in a "cost shift" from customers that were paying for the grid, to rooftop solar customers, who weren't. APS put on a good case demonstrating that rooftop solar customers were substantially benefitting from the grid by drawing power at night, during cloudy weather and during the periods of daylight when solar power production did not exceed the customer's needs. Many have criticized solar power as unfairly subsidized. In Arizona at least, one of those subsidies is being addressed. 4. New Carbon Dioxide Emission Standards - Following over 2.5 million comments, EPA rescinded its proposed rule governing carbon dioxide emissions from new coal-fired power plants. In its place it proposed on September 20 a rule setting CO2 emission standards for new large natural gas power plants (1,000 lbs/MW-hr), new small natural gas power plants (1,100 lbs/MW-hr), and new coal-fired power plants (1,100 lbs/MW-hr). From our perspective, the most significant facet of this new rule is that it actually will apply to plants that are being built. The withdrawn proposed rule only applied to new coal plants, which EPA concluded would not be built anyway before 2030. Equally significant, as pointed out in EPA's news release on the proposal, is that "EPA has initiated outreach to a wide variety of stakeholders that will help inform the development of emission guidelines for existing power plants." 5. The Fifth Assessment Report of the Intergovernmental Panel on Climate Change – The IPCC's Working Group I issued The Physical Science Basis, its part of the Fifth Assessment Report. Working Groups II and III will publish in 2014. Among other things WG I concluded: "Unequivocal evidence from in situ observations and ice core records shows that the atmospheric concentrations of important greenhouse gases such as carbon dioxide, methane, and nitrous oxides have increased over the last few centuries." "The temperature measurements in the oceans show a continuing increase in the heat content of the oceans. Analyses based on measurements of the Earth's radiative budget suggest a small positive energy imbalance that serves to increase the global heat content of the Earth system. Observations from satellites and in situ measurements show a trend of significant reductions in the mass balance of most land ice masses and in Arctic sea ice. The ocean's uptake of carbon dioxide is having a significant effect on the chemistry of sea water." But if one remains skeptical, this consensus view of the world's leading climate scientists should not cause one alarm, the climate change skeptics have not thrown in the towel. For example, according to one website, "climate science as proclaimed by the IPCC is a morass where what is scientific knowledge cannot be easily separated from speculation and what is wrong." One won't find seafarers plying the Northern Sea Route in the skeptic camp, however. Russia logged a record year of transits in 2013 (over 200), up from just 4 in 2010. 6. Climate Change Liability Lawsuits - For the first time since 2005, when Comer v. Nationwide Mutual Insurance was filed, there is no climate change liability lawsuit on the docket anywhere. All have been defeated. Comer was the last to succumb, with its opportunity to file a petition for certiorari expiring on or about August 14. The IPCC Fifth Assessment establishes climate change is not going away, but we will have to wait to see if anyone is going to attempt to make someone pay for it.
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Carbon Dioxide | Climate Change | Regulation | Solar Energy | Utilities | Year in Review
Tags: Comer, IPCC, Fifth Assessment, Low Carbon Fuel Standard, LCFS, Northern Sea Route, Rocky Mountain Farmers Union v. Corey, net metering, solar cost shift, carbon dioxide emission standards, new natural gas plants, new coal plants
Top 6 at 6: Highlights of the Top Climate Change Stories in the First Half of 2013
Another six months have passed and it is time for our semi-annual look at climate change and its intersection with the law. Here are some highlights of the last six months: 1. The Administration's Focus. After months of silence in the 2012 presidential campaign, President Obama rejuvenated his administration's commitment to addressing climate change. We heard in his inaugural address: "We will respond to the threat of climate change, knowing that the failure to do so would betray our children and future generations. Some may still deny the overwhelming judgment of science, but none can avoid the devastating impact of raging fires and crippling drought and more powerful storms." He carried this forward in his State of the Union address less than a month later: "I urge this Congress to get together, pursue a bipartisan, market-based solution to climate change, like the one John McCain and Joe Lieberman worked on together a few years ago. But if Congress won't act soon to protect future generations, I will. (Applause.) I will direct my Cabinet to come up with executive actions we can take, now and in the future, to reduce pollution, prepare our communities for the consequences of climate change, and speed the transition to more sustainable sources of energy." And in a speech this past Tuesday the promises took another step toward reality when the President outlined his "climate action plan." Recognizing the logjam in Congress, the Administration's plan is based on authority the executive branch already has. The salient points include: 1) further restrictions on powerplant greenhouse gas emissions (notably addressing coal); 2) promotion of resilience and adaptation with respect to weather-related calamities; 3) additional permitting of renewable energy facilities on public lands; and 4) engagement in the international arena on climate change such as working out a global free trade agreement on clean energy technologies. The goal is a reduction of U.S. greenhouse gas emissions by 17%. The Wall Street Journal called these "sweeping climate policies." We will see; with no new authority, Gina McCarthy's nomination to head EPA held up, and the bounty of natural gas unleashed by fracking, greenhouse gas reduction may be achieved by the market, see Leveraging Natural Gas to Reduce Greenhouse Gas Emissions, not governmental efforts. 2. 400 PPM. On May 9, Mauna Loa Observatory of NOAA's Earth System Research Laboratory reported that the average weekly value of atmospheric carbon dioxide at the observatory had reached 400 ppm, a level unsurpassed in 3 million years. The world collectively ignored the number, treating it more like an insignificant decimal, 0.0004, which it was (a decimal, not insignificant). We don't think anyone will dispute that there are three ways to interpret this number: it's bad, it's good, it's neither. Climate scientists are unanimous that it's bad. There is nothing saying it's good. Which means the justification for not taking action on climate change is that the ever increasing levels, and the ever increasing rate of accumulation, of carbon dioxide in the atmosphere (see the graphs by the observatory), are of no consequence. US Airways will probably side with the climate scientists - it canceled 18 flights as a result of the record-breaking temperatures in the southwest this past weekend. As a footnote, we note that Mauna Loa's number is an average, and is subject to refinement. As it turned out, the 400 ppm number was refined a few weeks later to 399.89. 3. Free Trade. In 2009 Ontario enacted its Green Energy Act to promote renewable energy in the province. One approach is the adoption of a feed-in tariff (mandatory above-market rates for electricity derived from renewable resources). This had successfully been pioneered in Germany. Ontario legislators also saw the opportunity to spur job growth by giving subsidies to businesses that sourced their wind turbines and solar panels in Ontario (i.e., "domestic content"). Japan jumped on this protectionism immediately and sought consultations with Canada under the General Agreement on Tariffs and Trade and the World Trade Organization. The consultations were ineffective and Japan requested a panel to hear the dispute concerning Ontario's "domestic content requirements," with which renewable energy generators were required to comply "in the design and construction of electricity generation facilities in order to qualify for guaranteed prices" under the feed-in tariff program. Last December the panel ruled in favor of Japan on the domestic content requirements. Canada appealed and this May the appellate panel affirmed. Ontario's energy minister has confirmed that Ontario will abide by the WTO decision and revise its Green Energy Act. We conclude that free trade remains colorblind. 4. Climate Change Liability Lawsuits. For seven years now, the first wave of climate change liability lawsuits have roiled the legal waters. It bears remembering that in October 2009, the plaintiffs in these cases rode the crest of the wave. The Second Circuit had reversed the trial court's dismissal in Connecticut v. American Electric Power (AEP), and the Fifth Circuit likewise overturned the Southern District of Mississippi's dismissal of Comer v. Murphy Oil USA. Plaintiffs had standing; the political question doctrine did not apply. Things have gone badly for the plaintiffs since. All readers of this blog know of the Supreme Court's decision in AEP, stifling the plaintiffs' case under the doctrine of displacement. This year two more decisions confirmed the Judicial Branch's hostility to these claims. Comer made it back to the Fifth Circuit, where dismissal was summarily affirmed on the doctrine of res judicata. And the last of the original quadriga, Native Village of Kivalina v. ExxonMobil Corp., found its petition for certiorari denied in April, thus leaving the Ninth Circuit's affirmance of dismissal unchanged. The only reed left for the plaintiffs is the granting of a petition for certiorari in Comer, a prospect we deem unlikely, if only because the appeal would be based on a purely procedural question of little likelihood of being repeated and of little relevance to the larger climate change issues. 5. Ursus Maritimus. On March 1 the D.C. Circuit in In re Polar Bear Endangered Species Act Litigation affirmed the district court's dismissal of challenges to the Fish and Wildlife Service's designation of the polar bear as threatened under the Endangered Species Act because "due to the effects of global climate change, the polar bear is likely to become an endangered species and face the threat of extinction within the foreseeable future." The polar bear's friends (environmental groups) sought to have the bear listed as "endangered." Ursus maritimus's less-than-friends (the State of Alaska and hunting groups), urged that no listing was appropriate. The standard in such reviews is relatively simple: "Our principal responsibility here is to determine, in light of the record considered by the agency, whether the Listing Rule is a product of reasoned decisionmaking." The Court found that it was, holding specifically the the Listing Rule rests on a three-part thesis: the polar bear is dependent upon sea ice for its survival; sea ice is declining; and climatic changes have and will continue to dramatically reduce the extent and quality of Arctic sea ice to a degree sufficiently grave to jeopardize polar bear populations. See Listing Rule, 73 Fed. Reg. at 28,212. No part of this thesis is disputed and we find that FWS's conclusion – that the polar bear is threatened within the meaning of the ESA – is reasonable and adequately supported by the record." As arctic resource development progresses as the ice retreats, the polar bear's Endangered Species Act listing is sure to take on larger significance, both as a model for the preservation of other arctic species, and as a tool to block development. 6. Compressed Natural Gas (CNG). On June 13 the Fifth Circuit affirmed the district court's decision in Association of Taxicab Operators USA v. City of Dallas. In the case the local taxicab organization challenged a city ordinance that allowed CNG-fueled taxicabs "head-of-the-line" privileges at Love Field in downtown Dallas. Plaintiff's theory was that section 209(a) of the Clean Air Act, which prohibits states and their political subdivisions from adopting emission standards for motor vehicles, preempted the ordinance either directly or by implication. The Fifth Circuit did not agree. Traditional police powers of the state were preserved to the state by section 209(d) of the Clean Air Act. More importantly, an ordinance granting head-of-the-line privileges, on its face did not set an emission standard, as required by the statute. As to any implied preemption, the ordinance may have influenced taxicab operators to alter their behavior, but it did not compel them to do so. Less than 7% of Dallas's taxicabs served Love Field and the only place CNG cabs had head-of-the-line privileges was at Love Field; there were plenty of other places for gasoline powered cabs to pick up fares. Accordingly implied preemption did not apply either. One of our themes in a world beset by climate change is that there will be winners and there will be losers. Little did taxicab operators know they would be both.
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Carbon Dioxide | Carbon Emissions | Climate Change | Greenhouse Gases | Legislation | Regulation | Utilities | Year in Review
Tags: Association of Taxicab Operators v. City of Dallas, In re Polar Bear Endangered Species Act Litigation, Connecticut v. American Electric Power, Native Village of Kivalina, Green Energy Act, feed-in tariff, WTO, Mauna Loa, President Obama, Flat Earth Society, 400 ppm, res judicata
Top 6 at 12: Highlights of the Top Climate Change Stories in the Second Half of 2012
2012 has drawn to a close. We chronicle here six of the most significant stories on the climate change front in the last six months. For those looking for hope that government is taking action to rein in greenhouse gas emissions, the focus is on California, where cap-and-trade stepped into reality with California's first emissions auction. Nationally and internationally regulation is at a standstill or going backward. In the courts, the climate change liability plaintiffs were pounded again as the Ninth Circuit confirmed the dismissal of Native Village of Kivalina v. ExxonMobil Corp. Responding to climate change, however, is a different story. Superstorm Sandy was a wakeup call on adaptation and the impacts of extreme weather; the National Flood Insurance Program managed to obtain statutory authority to include climate change in its considerations. 1. Superstorm Sandy – Climatologists are confident that the changing climate will lead to more frequent and more severe storms. Sandy, following Hurricane Irene the previous year, delivered on both predictions. A nine-foot storm surge at Battery Park. Transformers exploding and putting Manhattan into darkness. The Hoboken PATH station submerged. $50 billion in damage. Superstorm Sandy set records and was completely consistent with the concerns of proponents of climate change mitigation and adaptation. Did it have anything to do with climate change or was it simply a chance confluence of events? The weather pattern was unusual. There was a hurricane (albeit fading), coupled with a nor'easter, intersecting with an arctic high pressure front, under a full moon. Individually, those are independent of climate change. But there was also a record lack of sea ice, which has a measured and observed effect on global atmospheric circulation, which could result in severe weather coming together more severely. So quite possibly Sandy is a result of climate change. More important than the academic debate, however, is the impact on adaptation. Regardless of one's views on climate change, Sandy demonstrated that a major metropolitan area is vulnerable to extreme weather. Steps will be taken to flood-proof subways, bury electric lines, raise seawalls, improve evacuation plans and emergency response, etc. All of these are part of the steps needed to adapt to climate change. Whether it is acknowledged as linked to climate change or not (but see Bloomberg Business Week cover following Sandy: "It's Global Warming, Stupid!"), adaptation is going to happen. 2. Presidential Election - Climate change was an important part of the campaign: "The Obama-Biden cap-and-trade policy will require all pollution credits to be auctioned, and proceeds will go to investments in a clean energy future, habitat protections, and rebates and other transition relief for families." The 2008 election campaign that is. It was a completely different position in 2012. Or maybe not different at all. No one could tell because nobody was talking about it. Even Sandy wasn't enough to propel climate change into the debate in the last week of campaigning. 3. Native Village of Kivalina v. ExxonMobil - The last filed of the original quartet (American Electric Power, General Motors, Comer, and Kivalina) of climate change nuisance cases, Kivalina finally made it to a federal appellate court, where in September it met the same fate as its brethren: dismissal affirmed. Plaintiffs asked for rehearing. The Ninth Circuit wasn't interested. As of this writing, the only case left is Comer v. Murphy Oil USA, which is on appeal following its dismissal last March (for the second time) by the Southern District of Mississippi. According to that court, plaintiffs lose for a wide variety of reasons: standing, political question doctrine, res judicata, collateral estoppel, displacement, statute of limitations and proximate cause. 4. Cap-and-trade - California, alone among the fifty states, instituted its multi-industry full-fledged cap-and-trade program auctions in November. All of its allowances for 2013 were sold at a price slightly above the mandated floor price of $10/ton. Regulators and environmental groups hailed the auction as a success; some business groups were less enthusiastic. The California Chamber of Commerce sued the California Air Resources Board to invalidate the auctions. Meanwhile, the Regional Greenhouse Gas Initiative in the northeast continues with its allowances trading at the floor price, and with less than 2/3 of its allowances selling in its August and December auctions. Some commentary concludes that it is time for RGGI to shut down as its CO2 emission goals have been met. From where we sit, RGGI's success or failure can't be judged until its carbon trading is done in connection with a robust economy. The world economic malaise suppresses business, and with it, carbon dioxide emissions. California may face the same issue. 5. National Flood Insurance Program Reform - Could a poisonously partisan Congress vote for this: (1) IN GENERAL- The Council shall consult with scientists and technical experts, other Federal agencies, States, and local communities to--(A) develop recommendations on how to--(i) ensure that flood insurance rate maps incorporate the best available climate science to assess flood risks; and (ii) ensure that the Federal Emergency Management Agency uses the best available methodology to consider the impact of--(I) the rise in the sea level; ..."? Not the Congress we know. Or so we thought. Somehow, somewhere, someone put this into a draft, which made it into and out of a committee, ended up on the floor of both houses, survived two votes and came out as an enrolled bill for the president's signature. The president signed it into law in July. This was part of the miscellaneous section of the Moving Ahead for Progress in the 21st Century Act (aka the Transportation and Student Loan Bill), which may explain how this occurred. In any event, climate change considerations are statutorily mandated as part of the NFIP. 42 USC § 4101a(d)(1). We can expect a report by July 6, 2013. Id. § 4101a(d)(1)(B). Who'd have thunk? 6. Global GHG Regulation - COP-18, the Conference of the Parties to the United Nations Framework Convention on Climate Change, wrapped up in Doha, Qatar in the middle of December widely panned as ineffective. While it extended to 2020 the Kyoto Protocol addressing global greenhouse gas emissions, major nations (Canada, Russia, Japan and New Zealand) dropped out, and the United States continued to refuse to participate. Thus, only about fifteen percent of global emissions are now covered by the protocol (the EU and other European nations, as well as Australia, continue to support the protocol). Developing nations (whose emissions are not restricted by Kyoto) had hoped to obtain commitments for funding "climate finance" of $100 billion, but that did not occur either. One can see parallels between the Kyoto Protocol and the Western Climate Initiative and RGGI. In all three members have dropped out and the commitment to address greenhouse gas emissions waivers. The fiscal cliff was the focus at the end of 2012; climate change got short shrift. 2013 may establish that that was short-sighted.
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Carbon Emissions | Climate Change | Climate Change Litigation | Flood Insurance | Rising Sea Levels | Weather | Year in Review
Tags: Kyoto Protocol, NFIP, cap-and-trade, AB 32, Kivalina, Comer, Doha, Obama, Sandy, adaptation
The Top 6 at 6: A Review of the Most Important Climate Change Legal Stories in the First Half of 2012
Arbitrary and capricious. Familiar words to anyone involved in regulatory activity. But also applicable to calendars, which willy-nilly cut off a series of events and ascribe them to one solar cycle, as if the sun gave two hoots. As we perused the various "Climate Change: Year in Review" reviews that crossed our desk last January, we concluded 365 days are arbitrary and one year capricious in assessing what is important to resurrect and re-discuss. We further concluded that a 12-month look-back is too long. So, for what it is worth, here is one of six months. 1. Cap-and-Trade in the U.S. - On January 1 the Western Climate Initiative (WCI) (or what remains of it) initiated its long-anticipated cap-and-trade program for greenhouse gas emissions. Notwithstanding the lack of support from other WCI members, California and Quebec are moving forward with a cap-and-trade program. California's and Quebec's mandated reporting rules applied to stationary sources emitting at or above 25,000 metric tons of CO2e per year. On May 9 coordination between the two programs was announced initiating the 45-day public comment period. The first auction will be held in November and then, on January 1, 2013, enforcement begins when covered entities must participate. It is obviously too soon to tell how successful the California program will be, but when the world's eighth largest economy takes an initiative, it is likely to have impact elsewhere, particularly when it is the only program in the nation. 2. Greenhouse Gas Liabilities and Insurance Coverage - We didn't think there would be anything to say this year about coverage for GHG liabilities. After all, in the only case in litigation the Virginia Supreme Court issued its opinion in AES Corp. v. Steadfast Insurance Co. in September 2011 and concluded that there was no "occurrence" triggering coverage made in the allegations pleaded by the Native Village of Kivalina against AES Corporation. But then the Court granted a motion for reconsideration in January and many puzzled as to what was going on. Apparently nothing as the Court reiterated its previous conclusions in an April 20, 2012 opinion. The decision will be significant in Virginia because it may have upset coverage in more conventional cases, as the concurring opinion of Justice Mims suggests. As for the rest of the nation, it is one decision, on one issue, on one set of facts. The case is important because it is the first, but we will be surprised if it provides guidance anywhere else. As for greenhouse gas liability that is a story unto itself. Like something out of a Steven King novel, the Comer v. Murphy Oil case refuses to pass quietly into the night. This is the case that was dismissed by the Southern District of Mississippi, reversed by the 5th Circuit, vacated by the 5th Circuit en banc when it accepted rehearing and then reinstated as dismissed when the 5th Circuit's quorum dissolved. Following a denial of a request for a writ of mandamus from the U.S. Supreme Court, the Comer plaintiffs re-filed their complaint against over 100 electric utilities, oil companies, chemical companies and coal companies alleging their GHG emissions were responsible for the ferocity of Hurricane Katrina. And the Southern District of Mississippi dismissed the plaintiffs again on March 20. And plaintiffs appealed again. We don't expect the case to be finally at rest until the Supreme Court denies certiorari, or accepts it (perhaps in order to address the Ninth Circuit's much-anticipated decision in Native Village of Kivalina v. ExxonMobil, which has been pending for over six months since oral argument). 3. Natural Gas: The Bridge Fuel - With the combining of two technologies, hydraulic fracturing and horizontal drilling, a resource of unprecedented volume is "changing the game" of energy. "Annual shale gas production in the US increased almost fivefold, from 1.0 to 4.8 trillion cubic feet between 2006 and 2010. The percentage of contribution to the total natural gas supply grew to 23% in 2010; it is expected to increase to 46% by 2035." Thus reported the Energy Institute at the University of Texas in February in a 400+ page tome entitled Fact-Based Regulation for Environmental Protection in Shale Gas Development. Momentously, the UT researchers report "there is at present little or no evidence of groundwater contamination from hydraulic fracturing of shales at normal depths." The reference to "normal depths" acknowledged that in December 2011 the EPA linked contamination in Pavilion, Wyoming to shallow fracking operations. In March 2012, however, EPA agreed to conduct further testing. And then in May, a personal injury tort case, Strudley v. Antero Resources Corp. et al., No. 2011-CV-2218 (2d Jud. Dist. Ct. Col. May 9, 2012), brought against fracking operators in Colorado was thrown out because plaintiffs could not muster adequate proofs of specific causation. Despite some intense opposition, fracking is moving forward. What does all of this have to do with climate change? Natural gas when burned emits half the carbon dioxide of coal. Accordingly, some argue that natural gas is the bridge to a low-carbon future. If so, then fracking builds that bridge. 4. Innovative Climate Change Legal Theories - Last spring the sound and the fury were intense as the environmental organization Our Children's Trust unleashed several dozen regulatory petitions and a dozen lawsuits across the nation. The goal: establish the public trust doctrine as applicable to the atmosphere and use it to implement greenhouse gas regulation. It appears that all of that is signifying nothing. Over two dozen petitions were denied in 2011 and two lawsuits were dismissed (Montana and Colorado). It did not get any better in 2012. The first six months of this year delivered only bad news to OCT. State courts dismissed lawsuits in Alaska, Arizona, Minnesota, Oregon, and Washington. The federal court in the District of Columbia did the same. Plaintiffs took a voluntary dismissal in California. To be sure, OCT has filed appeals (the one in Minnesota is scheduled to be argued on July 18). Having failed to convince a single court so far, we think we are safe in predicting an uphill battle. 5. Power Plant Performance Standards - On April 13, 2012, a scant seven months before the presidential election, the EPA published in the Federal Register standards of performance for all new fossil fuel-fired electricity-generating units requiring them to meet an electricity-output-based emission rate of 1,000 lb of carbon dioxide for every megawatt-hour of electricity generated. The only plants that can meet this standard without implementing costly carbon capture and storage technology are natural gas plants. Thus, the administration took a strong stand against coal-based generation. Or it is all smoke and mirrors. As EPA notes in the proposed rule, because of the glut of natural gas made available by fracking, there is little likelihood of a new coal-powered plant before 2030. Notwithstanding, industry groups have filed a half-dozen lawsuits seeking to derail the rule. 6. EPA's Greenhouse Gas Regulatory Program - Less than a week ago USEPA and its GHG program got a firm "thumbs up" from the D.C. Circuit. Inundated with over two dozen appeals of various USEPA GHG regulations, the Endangerment Finding, the Tailpipe Rule, the Tailoring Rule and the Timing Rule (for citations see The DC Circuit Locks in USEPAs GHG Regulations Sort Of). The court turned away every challenge, sometimes on the merits and sometimes on procedural grounds such as standing. There is much that deserves comment not the least of which are the differences between the states with California, Connecticut, Delaware, Illinois, Iowa, Maine, Maryland, Massachusetts, New Hampshire, New Mexico, New York, North Carolina, Oregon, Rhode Island, Vermont, and Washington, lining up on one side, and Alabama, Florida, Indiana, Kansas, Kentucky, Louisiana, Nebraska, North Dakota, Oklahoma, South Carolina, South Dakota, Texas, Utah, and Virginia lining up on the other. To focus more on legal matters, several challenges were turned away on standing. For example, neither states nor industry groups could challenge the Tailoring Rule as they did not allege the requisite injury. Because the Tailoring Rule benefits small businesses (who are not required to comply with certain GHG emission requirements), it would appear that the door may remain open for parties who allege competitive injury (i.e., non-regulated entities gain a competitive advantage). In the meantime, do not expect Congress this election year to touch the issue.
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Carbon Dioxide | Climate Change | Climate Change Litigation | Greenhouse Gases | Insurance | Legislation | Regulation | Year in Review
Tags: Steadfast v. AES, Kivalina, Our Children's Trust, atmospheric trust litigation, ATL, fracking, Pavilion, Strudley v. Antero Resources cap-and-trade, WCI, occurrence, GHG emissions limitations, coal-based generation, Coalition for Responsible
2011: Notwithstanding Extreme Weather, US Climate Policy Does Not Move Forward
NOAA reported that 2011 was one for the record books: 12 weather and climate-related disasters each causing over $1 billion in damage. One might expect (or hope) that a national climate change policy would be coming into place to prevent repeating or setting a new record. One would be disappointed. U.S. climate policy is "uncertain," to quote Michael Morris, CEO of American Electric Power, "dysfunctional" is the word applied by Resources for the Future, "hamstrung" is how the chief UN climate change negotiator and Executive Secretary of the UNFCCC, Christiana Figueres, calls it. We don't disagree with these viewpoints; they are accurate. But if a response to climate change is the goal, it is worse than these commenters are acknowledging because not only has Congress shown that it is incapable of getting anything done, other avenues are not delivering either. As the year expires we thought it might be helpful to sift through the year's detritus and assess the status of attempts to reduce carbon dioxide emissions, distinct from overt attempts like passing laws and adopting regulations. 1. Tax emissions - Some will remember our blog on the federal lawsuit brought by Mirant Corp. against Montgomery County challenging the County's tax on carbon emissions which fell only on Mirant. The County challenged the federal court's jurisdiction and won before the federal district court. In June, however, the Fourth Circuit reversed. With that Montgomery County folded its tent and abandoned its carbon tax. 2. Favor renewable energy - The inexorable scrutiny of the markets has proved the undoing of several former high-flying renewable energy ventures. Most well-known is the debacle with Solyndra LLC, whose well-publicized collapse generated scrutiny by the FBI and Congress. Others that have failed with less limelight in 2011 include numerous solar companies (Solar Millennium, Stirling Energy Systems, Evergreen Solar, Spectrawatt), as well as ventures in wind (Skycon), energy storage (Beacon Power), and biofulels (Range Fuels). 3. Impose liability for emissions of carbon dioxide - The results here are mixed. Everyone points to American Electric Power v Connecticut for the principle that for greenhouse gas liability claims the federal common law of nuisance has been displaced by federal regulation. They could equally point to Connecticut v AEP before the Second Circuit for the principle that the political question doctrine does not bar these types of claims or to the Fifth Circuit panel in Comer v Murphy Oil USA that held similarly. However, even if the cases are permitted to move forward, they face daunting problems in proof of causation. 4. Force state action to regulate carbon dioxide - We blogged last May and just this month about the tidal wave of litigation unleashed by Our Children's Trust, an Oregon environmental group that had orchestrated a dozen suits asserting the defendant States had an obligation under the public trust doctrine to restrain carbon dioxide emissions, as well as regulatory petitions in about 40 jurisdictions. Time has not been good to OCT. First, its petitions have been denied by at least 23 agencies (Arkansas, Connecticut, Georgia. Hawaii, Idaho, Illinois, Iowa, Louisiana, Maine, Maryland, Michigan, Nevada, New Hampshire, North Dakota, Ohio, Oklahoma, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, and Wyoming). Where OCT filed lawsuits, three states (Arkansas, Minnesota and New Mexico) responded with motions to dismiss. The lawsuit against Montana was dismissed. In the federal lawsuit, the plaintiffs lost a motion to transfer. 5. Reach regional agreements - With great fanfare the Regional Greenhouse Gas Initiative was launched in 2005. Despite a recent study that claims significant economic benefit to the states in RGGI, its future success is unclear. New Jersey pulled out, New Hampshire tried to leave but the governor vetoed the bill. In New York, there is a court challenge. 6. Voluntarily trade carbon dioxide emissions credits - The only carbon exchange in North America came to an end in 2010 when the Chicago Climate Exchange closed its doors. A shadow of its former self, the CCX now registers verified emission reductions based on a comprehensive set of established protocols. 7. Develop carbon capture and storage - The most prominent project in the US came to a halt in July when American Electric Power concluded not to build a full-scale CCS plant at its Mountaineer, West Virginia plant. As noted above, AEP explained its decision as based on the uncertainty of US climate policy. The lack of direction in American climate change response hurts business. AEP walked away from a $300 million Department of Energy match. It didn't help that the Virginia consumer advocate, in successfully arguing against including CCS costs in the rate base, asserted: "Any potential benefit is speculative and outweighed by the enormous cost of the pilot project." Some may think no policy is the best policy. We think otherwise. Climate change is happening. There will be a response. All will benefit if that response is choreographed over time, rather than rushed into when political consensus ultimately concludes that something must be done NOW. Maybe in 2012? Happy New Year.
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Carbon Dioxide | Carbon Emissions | Climate Change | Climate Change Litigation | Legislation | Regulation | Renewable Energy | Weather | Year in Review
Tags: NOAA, Mirant, CCS, Carbon Capture, Mountaineer, Chicago Climate Exchange, CCX, RGGI, Our Children's Trust, Figueres, Solyndra, Spectrawatt, One Beacon, Range Fuels
McCarter & English's Climate Lawyers Blog Named to LexisNexis' 2011 Top 50 Environmental Law & Climate Change Blogs List
by noauthor
McCarter & English is pleased to announce that the firm's ClimateLawyers.com blog has been selected by LexisNexis as one of the Top 50 Blogs for the Environmental Law & Climate Change Community. McCarter & English LLP is pleased to announce that the firm's ClimateLawyers.com blog has been selected by LexisNexis as one of the Top 50 Blogs for the Environmental Law & Climate Change Community. The list recognizes preeminent thought leaders in the blogosphere that are creating invaluable content for all segments of the environmental law and climate change practice. "Most good blogs provide frequent posts on timely topics, but the authors in this year's collective take their blogs to a different level by providing insightful commentary that demonstrates how blogs can—and do—impact the practice of environmental and climate change law," said Tracie Morris, Web 2.0 Manager, for LexisNexis in an emailed statement. ClimateLawyers.com, launched in 2008, is dedicated to the discussion of legal, public policy, and business risk questions presented by climate change and renewable energy initiatives. Authors of the blog include McCarter partners J. Wylie Donald(Wilmington), Francis Kirk (Newark) and Grace Kurdian (New York) of the firm's Climate Change & Renewable Energy Practice Groupin which Mr. Donald and Ms. Kurdian are co-chairs. Selection was partly based on commentary submitted to LexisNexis through the online community page which allowed members to share feedback and make suggestions for new blogs to be nominated. After the commentary stage, LexisNexis compiled the final list of nominees and then selected the Top 50 Environmental Law & Climate Change Blogs for 2011. It is expected that LexisNexis will soon put the matter to a vote inviting the online community to pick the Environmental Law & Climate Change "Blog of the Year." "We are very pleased to be named to the Top 50 list and appreciate all of the support we've received from colleagues and clients in this endeavor," said Mr. Donald. "Our site has existed for about four years and has a growing readership. As environmental concerns continue to exist in our communities and inside the courtroom, McCarter is working to be at the forefront of the discourse. Our experienced team draws from the firm's insurance coverage, energy, environmental, tax, real estate, litigation, and intellectual property lawyers to address the myriad legal needs of our clients in these areas. We look forward to continuing a healthy and persuasive conversation about the issues affecting companies and our communities." About McCarter & English McCarter & English, established more than 160 years ago, represents Fortune 500 and middle-market companies in their national, regional and local litigation and on important transactions. Its 400 attorneys are based in offices in Boston, Hartford, New York, Newark, Philadelphia, Stamford and Wilmington. http://www.mccarter.com
e5c679ed-6aff-4a2c-a392-4f3c5e750082|0|.0|27604f05-86ad-47ef-9e05-950bb762570c
Climate Change | Year in Review
Tags: McCarter & English, Blog
ClimateLawyers Blog Nominated for Top 50
February 8, 2011 12:44
There was a lot of hype in the papers today about some contest in Dallas with people running around, bumping into each other, dropping balls and otherwise exhaling a lot of greenhouse gases. We contemplated a discussion of the Superbowl but knew you would be more interested in some shameless marketing. So here's where we are: LexisNexis has nominated the blog for the first ever LexisNexis "2011 Top 50 Environmental Law & Climate Change Blogs." In their words, "For the first time, the LexisNexis Environmental Law & Climate Change Community is honoring a select group of blogs that set the online standard for our practice area," said Karen C. Yotis, ELCCC Community Manager, in an emailed statement to us. As some of you may know, we initiated the blog, ClimateLawyers.com, in 2008, in the vanguard of those addressing climate issues in the legal profession. We have focused on not just being a news blog, but instead try to incorporate analysis in everything we post. We like to think that we are succeeding as our readership is consistently growing. The blog is dedicated to the discussion of legal, public policy, and business risk questions presented by climate change and renewable energy initiatives. LexisNexis has created an online community page to allow members to provide commentary on the list. To show your support of ClimateLawyers.com, please click here. The deadline for comments is February 14.And since we promise analysis, here is some. In climate change circles, there has been much written about the conclusions that can be drawn from the hard data. The scientific community is agreed that climate change is occurring. It is also agreed that atmospheric carbon dioxide levels are the highest they have been in thousands and thousands of years. Where the controversy has been is whether one can conclude that anthropogenic carbon dioxide is the cause of climate change. Similarly here. The hard facts are the writings in the various blogs under consideration. There is no dispute that we and our peers labor to churn out our best thoughts. The question, though, is what are those thoughts' significance? And that in turn depends on who is reading, which in turn may depend on whether he or she has found what was in the blog worth reading before. So there is a large amount of serendipity in this blog competition and the ultimate conclusion may depend on exactly what question the judges ask. Be that as it may, if you have positive comments about our writing, we would be grateful if you would let the folks at LexisNexis know. Thanks.
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Climate Change | Greenhouse Gases | Year in Review


Objective To analyze hospitalization for lower extremity amputations (LEAs) and amputee rates in persons with and without diabetes in Italy. Research Design and Methods All patients with LEAs in the period 2001–2010 were identified analyzing the National Hospital Discharge Record database. For each year, amputee and hospitalization rates for LEAs were calculated either for persons with diabetes or without. Time trend for major and minor amputations were analysed. Results From 2001 to 2010 a mean annual number of 11,639 individuals underwent a lower extremity amputation: 58.6% had diabetes accounting for 60.7% of total hospitalizations. In 2010, the crude amputee rate for LEAs was 20.4 per 100,000 inhabitants: 247.2 for 100.000 persons with diabetes, and 8.6 for those without diabetes. Having diabetes was associated to an increased risk of amputation (Poisson estimated RR 10.9, 95%CI 9.4–12.8). Over the whole period, a progressive reduction of amputee rates was observed for major amputations either among persons with diabetes (?30.7%) or without diabetes (?12.5%), while the rates of minor amputations increased progressively (+22.4%) among people without diabetes and were nearly stable in people with diabetes (?4.6%). A greater number of minor amputations were performed among persons with than without diabetes: in 2010, the minor-to-major ratio among persons with diabetes (2.5) was more than twice than in those without diabetes (1.0). Conclusions The nationwide analyses confirm a progressive reduction of hospitalization and amputee rates for major LEAs, suggesting an earlier and more diffuse approach aimed at limb salvage.


text:
Q: Show that $-2, -1, 0, i$ lies in the Mandelbrot set but that $1$ lies outside of it The Question
Let $c$ be a complex number. The complex numbers $z_n(c)$ are defined recursively by
$z_1(c)=c$, $z_{n++1}(c)=(z_n(c))^2+c$ for $n\geq1$
The Mandelbrot set is defined by
$M=\{c\in\mathbb{C} |$ the sequence $(z_n(c))$ is bounded $\}$
Show that each of $-2, -1, 0, i$ lies in $M$ but that $1 \notin M$
For -2, -1, and 0 I just did some math and showed by example that they have an upper bound.
I am stuck on how to prove that $i\in M$. I'd imagine that it's an induction, but not sure how to go about it.
Additionally, it's pretty obvious (if you go through it a bit) that for $c=1$ the set of recursive equations are unbounded. Could someone help me figure out how to to show this inductively?

A: The sequence for $i$ goes like
$$i\mapsto -1+i\mapsto -i\mapsto -1+i\mapsto\ldots $$
so it is eventually periodic, hence bounded.
The sequence for $1$ starts
$$1\mapsto 2\mapsto 5\mapsto\ldots $$
so seems to diverge. Indeed, this follows from proposition 2 below.
Proposition 1. If $|c|>2$, then $c\notin M$.
Proof.
Now if $|c|>2$, then we show by induction that $|z_n(c)|$ is $\ge |c|$ and strictly increasing by a factor $>1$:
$$|z_{n+1}(c)|\ge |z_n(c)|^2-|c|\ge (|z_n(c)|-1)|c|>|c|$$
as $|z_n(c)|\ge |c|>2$. And then
$$|z_{n+1}(c)|\ge |z_n(c)|^2-|c|\ge |z_n(c)|\cdot|c|-|z_n(c)|=|z_n(c)|(|c|-1).$$
We conclude $|z_{n}(c)|\ge (|c|-1)^n$ for $n\ge 1$, so the sequence is unbounded. $_\square$
Proposition 2. If $|z_m(c)|>2$ for some $m$, then $c\notin M$.
Proof.
By proposition 1, we may assume $|c|\le 2$.
$$ |z_{n+1}(c)|\ge |z_n(c)|^2-2$$
Now if $|z_n(c)|=2+h$, then $|z_{n+1}(c)|\ge 2+2h$. Thus from $n=m$ on, $|z_n(c)|-2$ grows exponentially. $_\square$

redpajama_set_name: RedPajamaStackExchange


text:
Apple denies hackers holding millions of iPhones, iCloud accounts ransom
Apple reassures customers that none of its systems have been breached, dismissing hackers' claims that millions of iPhones and iCloud accounts are at risk of being wiped
Published: 23 Mar 2017 10:15
Apple says none of its systems have been breached and denies that hackers are holding millions of iPhones and iCloud accounts to ransom.
"There have not been any breaches in any of Apple's systems including iCloud and Apple ID," the company said in a statement.
The statement comes after Motherboard reported on 21 March 2017 that a group of hackers calling themselves the Turkish Crime Family was threatening to wipe millions of iPhones and iCloud accounts unless Apple paid a ransom of $75,000 or hand over $100,000 worth of iTunes gift cards by 7 April 2017.
The hackers claimed to have access to up to 559 million Apple email and iCloud accounts, but did not provide any of the supposedly stolen credential to verify this claim apart from a YouTube video they said showed a member of the group using stolen credentials to access an iCloud account and view photos.
The hackers reportedly shared screenshots of emails allegedly exchanged with Apple, including one where a member of Apple's security team asked the group to share a sample of the stolen data.
According to Apple, the list of email addresses and passwords hackers claim to have appears to be from "previously compromised third-party services".
A person familiar with the contents of the alleged data set said many of the email accounts and passwords contained in it matched data leaked in a past breach at LinkedIn, reports Fortune.
More than 160 million LinkedIn accounts were exposed in 2012, but the full extent of the breach only came to light in 2016.
Apple said it will continue to "actively monitor" the situation and work with law enforcement to ensure that user data remains safe.
"To protect against these type of attacks, we recommend that users always use strong passwords, not use those same passwords across sites, and turn on two-factor authentication," Apple said.
Independent security advisor Graham Cluley said the claims underline the potential for hackers to steal data and use the media to increase pressure on organisations to pay up to avoid exposure.
Read more about two-factor authentication
Apple introduces two-factor authentication for iCloud and other services to protect users from hackers trying to access their accounts.
Swiss researchers propose a two-factor authentication system that does not require user interaction to help speed adoption of strong security.
The web's top brands implement two-factor authentication for consumer web authentication.
It may seem daunting, but two-factor authentication options are manageable for nearly all enterprises.
"I believe that companies should do everything in their power to protect their customers and prevent criminals from profiting from extortion," he wrote in a blog post.
"I do hope that the media stories will help remind Apple users of the importance of using a strong, unique password to secure their account and enable two-factor authentication to make their accounts harder to break into," he said.
Paul Calatayud, CTO at security firm FireMon, said anyone who does not use two-factor strong authentication to any account runs the risk of the password being harvested, or guessed.
"For example, if my e-mail account happens to be Yahoo, and if that account is affected by the breach that recently came to light, then there is a chance that the attackers are already able to compromise other accounts I hold, such as my Apple ID," he said.
Read more on Privacy and data protection
Fourth man jailed for iCloud celebrity hacking
Apple iOS 10.3 beta gets pushy with iCloud two-factor authentication
By: Ramin Edmond
US man jailed for hacking into celebrity accounts
Apple iCloud and Gmail hacker gets 18 months in jail
Fourth man jailed for iCloud celebrity hacking – ComputerWeekly.com
Apple iCloud and Gmail hacker gets 18 months in jail – ComputerWeekly.com
Apple iCloud and Gmail hacker set to plead guilty, ... – ComputerWeekly.com

redpajama_set_name: RedPajamaCommonCrawl


Typically, inflammation of any kind is considered to be a bad sign, a response to some sort of injury or disease. In the case of dairy cattle, inflammation of the udder is most often associated with mastitis.
Udder inflammation is also present a few days before and after calving. During this transition time, numerous metabolic diseases such as ketosis and fatty liver can also occur. Does swelling of the udder add to the disorders prevalent at calving?
To investigate this, Barry Bradford, an associate professor at Kansas State, and a team of researchers from Kansas State, Iowa State University and Michigan State University, studied the impact of anti-inflammatory drugs during the first seven days of lactation.
The researchers initially thought that treating cows with anti-inflammatories after calving might alleviate some common fresh cow issues and help cows transition from gestation to lactation. Instead of preventing fatty liver, the results showed that by stopping the swelling, liver fat content rose and plasma glucose concentration in mature cows dropped. Both of these responses are often associated with early-lactation metabolic diseases.
The group discovered that inflammatory pathways promote a temporary state of insulin resistance in cows, resulting in glucose conservation. Therefore, this insulin resistance induced by inflammation may be adaptive and beneficial in helping an animal shift into lactation. For this reason, inflammation in fresh cow udders could be a good thing.
The findings were published in the American Journal of Physiology. The role of inflammation in dairy cattle and other species has not been studied much, but these results suggest that inflammation may be advantageous or even necessary at some stages in life. Bradford and the research team plan to look deeper into this topic.


Reduces storage time and improves filtration.
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Throughout its history, Lallemand Brewing has always kept close ties with the brewing community. An example of such ties is the offering of the Lallemand Brewing's premium brewing yeasts product line. These brewing yeasts deliver unmatched consistency, reliability and purity, allowing brewers to take full control of the brewing process, exercise their full creativity and obtain the exact aromatic and flavor qualities they want. Also part of the Lallemand Brewing offering is the complete AB Vickers range of products. With over 200 years of history and simultaneously traditional and innovative, the AB Vickers product range includes beer and wort clarification products , yeast nutrients and brewing enzymes. From small local breweries up to the largest beer production companies, many organizations around the world rely on the AB Vickers range thanks to the constant technical innovation and expertise that backs it. Finally, Lallemand Brewing is proud to bring to the brewing community outstanding education, services and products via the Siebel Institute of Technology. Founded in 1872 by Dr. J. E. Siebel., the Siebel Institute of Technology's objective is, in the founder's own words, to promote progress of the brewing industry "based on fermentation, which is done by instruction, investigation, analysis and otherwise." True to this promise, the Siebel Institute of Technology rapidly became one of the world's most respected brewing schools and analytical laboratories, and a key part of North America's brewing tradition while contributing to the education of generations of brewers around the world.


This is the first post I've written to link up with my new writing linky – how exciting! Here's to plenty of time spent in the world of writerly ponderings! Ahhhh I can just feel myself relaxing. It could be the effect of the wine I'm drinking of course… but no, it's just the thought of sharing some writing-chat with people who know where I'm coming from. Excellent.
So, how has September been for me creative-writing-wise? Well, so far it's been a bit of a flat month. Having set myself various monthly word count goals since starting my novel in May, it had reached 50,000 words by the end of August. And then? Well, then I ground to a halt. The sum total of my creativity this month has been a poem and a limerick. My novel has progressed by not even a single word.
Of course it's been with good reason: Yes, it seems that starting a linky to motivate you with your writing, takes up rather a lot of the time you would normally spend writing! But still, the fact that the linky has now launched means I should have more time to write this week, so I'll be doing just that. In fact I'll be setting myself a writing challenge before I finish this post. As is usual with my writing style, I have no idea what this challenge will be yet – I'll just have to see what words form themselves on the tips of my typing fingers.
When I haven't been linky-launching this week I have been mulling over the issue of word counts and their relationship with quality. I set myself a lot of creative challenges on this blog and many of them are to do with writing a certain number of words. In July I did CampNanoWriMo for the first time and It helped me to write 15,000 words of my novel that month. All along I've been using the James Thurber quote above as a bit of a mantra. It's helped me focus on getting the words out – and thus the writing practice in – without obsessing about getting it perfect. I figure I'm not going to get it 'right' at this stage of my writing journey. In fact I suspect that I am never going to get it 'right', not to my satisfaction anyway!
But I recently read a post by Victoria who blogs at Coffee. Write. Repeat. about why she doesn't write every day. Victoria did CampNanoWriMo when I did but felt that, although she achieved her word count goal, a lot of what she wrote wasn't up to scratch because she was writing the words just for the sake of getting the word count. She felt she'd now have to put a lot of work into re-writing that perhaps she wouldn't have had to, had she not charged ahead to achieve a numerical target.
And it got me thinking – by pushing myself to write a certain number of words per month am I actually making more work for myself in the future? Obviously, I accept that my novel will need numerous drafts and redrafts however I write it (and however long it takes) but would it need fewer if I just wrote it more slowly? Am I chasing quantity at the cost of quality?
But then, if I don't set myself a word count target there's a risk I won't write any of my book at all. I have three kids one of whom is a baby. I work (albeit in a very part-time manner) I have a social life (of sorts!) I have a house that insists on becoming messy if I don't attend to it, a fridge of food that refuses to cook itself and a husband who, occasionally, would rather like it if I didn't have my fingers welded to my keyboard. All in all it's a pretty packed schedule. If I don't give myself targets how will I make myself write when I want to sleep or need to attend to all those other (vital) things? Is my love of writing enough to push me on?
Oooh a challenge for the week has now occurred to me! I'm not going to set myself any targets for this week at all. I'm going to tell myself I don't have to write anything. It doesn't matter if I don't write. I can if I like, but if I want to watch the last couple of episodes of season four of Breaking Bad (followed by a hefty chunk of season five) then I can. If I want to write poems or short stories for my blog (for my favourite linkys Prose for Thought and The Prompt) then I can… but I don't have to. No pressure!
This might not sound like much of a challenge to anyone who doesn't know me and how I write, but it is – I thrive on having targets to reach and goals to achieve. My first task will be to convince myself there really is no pressure.
I'll report back next week!
This entry was posted in Poetry, Pondering, Prose and tagged #whatI'mwriting, campNaNoWriMo, creative process, goals, writing on 9 September 2014 by Maddy.
I was recently invited to take part in a 'virtual blog tour' which is basically a journey through the blogosphere stopping off at various blogs along the way. Each blogger answers a few questions about themselves and then invites and introduces another couple of bloggers who answer the same questions on their blog a week later, and so it continues. It's a great way of finding new blogs and gaining an insight into why bloggers write what we do!
I was invited by the lovely Morgan Prince of Shaking Away the Cobwebs. I've been reading Morgan's blog since last year when we both started regularly linking up with Prose for Thought to share our creative writing. She is a stay-at-home-mum who is working on a novel (and various other projects) and I can identify with a lot of what she blogs about. I really enjoyed reading about her creative process in her blog tour post last week.
My biggest project at the moment is my novel. It's a psychological mystery (with a thriller edge). After an accident, its central character finds she has different memories of the last seventeen years than her loved ones do (in fact some of her loved ones are different people altogether!) The book follows her trying to figure out what is going on and what the truth is, while a growing threat to her safety lurks in the background.
My blog is my other big project. I started it as a place to record my experiences as I explored my ambition to become a published author but as time has gone by I have found myself posting more and more of my poetry and flash fiction on it. To begin with I found doing this terrifying, as I couldn't bear for anyone to read my work (what with the self-doubt demon biting at my toes) but overcoming that fear has been massively beneficial. It's given me the confidence to submit my work to various competitions and publications and I've even had a tiny bit of success that way!
Hmmm. Well, I think every writer has their own voice and style of writing but really I'm still exploring what mine is. I very much feel I am on a voyage of discovery in this area (even though that does sound a bit pretentious!).
In a way I like to think that my book is different from other psychological thrillers because although it has threatening elements and a mystery to unravel it is really a story of maternal and familial love. On the other hand, the genre is a popular one at the moment so I think there's something to be said for not straying too far from what readers expect and want when they pick that sort of book.
My blog doesn't really fit into a box – I suppose it's a writer's blog but I'm not a published author, and I also blog a bit about parenting but it's not a mummy blog. It's also unique in that it's full of my own pieces of fiction. Every blog is different though- that's part of the fun.
I also write as a record. My blog is obviously this, but I have written poetry about how I feel about my children and about certain events and experiences. I wrote a poem about pregnancy as I wanted to remember how it felt to be heavily pregnant, and I wrote about birth (as a record but it also turned out to be very cathartic). So for me writing is a very important tool – I use it to capture, remember, imagine, create and even recover. These days I would feel lost without it.
I like to set myself challenges. I don't have much free time to write so I find that setting myself weekly or monthly word count goals (as well as other aims like 'enter a flash fiction competition' or 'write a poem on such-and-such a subject') help me to use my time more effectively. For my novel, I've been setting myself monthly targets since May and I'm currently nearly 50,000 words into the first draft. Doing CampNaNoWriMo last month helped too!
Outside of the structure of my self-imposed challenges, there is a lot of 'winging it' that goes into my writing. I'm not much of a planner – I like to write and see how things evolve. I love it when characters surprise me (which they frequently do) and am always open to sudden changes in direction (the 'thriller element' of my book just appeared!). Really my writing process is just me on the sofa, with a laptop and a drink, seeing how it goes.
I also have an ongoing limerick challenge where I write a limerick on a subject of my sons' choosing and post it on my blog, so in that way my kids are very much a part of my process!
Lastly, I read a lot of fiction. This feels intrinsic to my writing. I love getting stuck in a good book!
I've been following Mummy Tries' blog since the start of the year when I happened across it on a linkie. At the time she (who shall remain nameless as she blogs anonymously!) was heavily pregnant with her third child and attempting to write a book. My third baby was ten months old at the time so I could identify! Since then she has become a loyal and supportive blogging friend.
I can throughly recommend a visit to Mummy Tries where she blogs about life with her hubby and three cherubs. She shares parenting insights, thrifty tips, what she has learnt while on the GAPS diet and lots of 'free from' recipes. She also takes the odd trip down memory lane to a dysfunctional past that is well behind her. She is currently writing a self help book and hopes to inspire others to break the 'Cycle of Dysfunction' like she did. I'm continually impressed by how often she blogs and how much she manages to fit into her life, especially with so little sleep. I'm looking forward to reading her Blog Tour post next Monday and finding out more about her book!
The other blogger I would like to introduce is Chrissie from Muddled Manuscript. Chrissie is another fellow writer and mum-of-three who I met (in a virtual sense) early this year. Her blog focusses on her writing and right from the start I was fascinated by her insights into the novel-writing process. She has a lot of experience as she started writing her first book fourteen years ago (and she's still younger than me)! She is a talented writer who also posts a lot of her own creative work – both poems and short stories – on her blog so it's well worth a read.
Chrissie has been an inspiration to me as she has taken part in – and won – no fewer than eight NaNoWriMo's, three of the November ones (where participants aim to write a 50,000 word novel in a month) and five CampNaNoWriMo's (where participants can choose their own word target… but she has also written a 50,000 word novel each time)! It was Chrissie who encouraged me to take part in (and win) last month's CampNaNoWriMo. She has been an excellent support to me with my writing for months and become a good friend in the process.
Well, I really enjoyed writing this post so thank you Morgan for inviting me to the tour.
Remember to pop over to Mummy Tries and Muddled Manuscript next Monday to read their blog tour posts – I'm looking forward to it!
This entry was posted in Pondering, Prose and tagged ambition, blogging, campNaNoWriMo, creative process, goals, novel, questions, writing on 11 August 2014 by Maddy.
Yes, I won Camp NaNoWriMo!
Of course 'winning' just means achieving the word count target you set yourself – I completed my 15,000 words last night – but it still feels good!
As I said in my last post, I've really enjoyed Camp and I fully intend to do it again sometime. With my CampNaNo words added to it, my novel is now at just over 46000 words so I'm making progress. I'm hoping to finish the first draft by the end of October.
And now for a campfire with some marshmallows toasted on sticks!
This entry was posted in Pondering and tagged ambition, campNaNoWriMo, creative process, goals, success, writing on 27 July 2014 by Maddy.
We're two-thirds of the way through the month so I thought I'd do a bit of a summary of my CampNaNoWriMo experience so far.
So… it's been pretty good! I've just reached 12,000 words of my 15,000 word target so, even though school holidays have now started (which means my writing time is reduced), I'm fairly confident of making the target. Of course, writer's block has an unhappy habit of appearing just when I need it least so the last 3000 words might not be easy to come by but let's think positive – I'm determined to make it!
Regular readers of this blog will know that I am not a stranger to setting myself word count goals (I did 20,000 in May and 10,000 in June) and might be wondering – is Camp Nano is any different to this?
Yes, as is so often the case in this crazy online world, the feeling that 'you are not alone' plays a large role. When you take part in CampNaNo you become part of something bigger than just being a solitary writer working towards your own private targets. For a start, you get placed in (or can choose your own) virtual cabin full of cabin mates with whom you can chat and swap advice and encouragement. I have a lovely group of writers in my cabin, all aiming for word counts similar to mine and I've enjoyed talking to them in our little private forum. I've also found a few new blogs and exchanged tweets with fellow campers through the #CampNaNoWriMo hash tag. This has been great for the inevitable moments of self doubt.
2) The incentive to win!
I've personally found that having stated my word count target somewhere outside of my own blog I feel even more determined to achieve it but – even better than that – with CampNaNo if you reach your target by midnight on the last day of the month you are declared a 'winner' and get a little winners badge to display on your blog! Ok, it's hardly great fame and riches but for the *slightly* competitive amongst us (and if you saw my involuntary, two-handed victory air-punch (with accompanying roar) as my 4-year-old won the obstacle race in this year's sports day you'd know what I mean) this a surprisingly big incentive!
Oh yes, that subject you hated at school really comes into it's own with CampNaNo. At the start of the month you tell the site what your word target is and it calculates how many words you need to write per day to achieve that. It's all displayed in a graph and as the days go by you can keep entering your word count (as often as you like) and your progress appears on the graph along with info about what your average daily count is, whether you're on target etc. You can also see the stats of anyone else in the camp if you're feeling interested/competitive/nosey. Feel free to take a look at mine here! I've found it really helpful and motivating. There have been days when I've not written at all and have felt like I'm not getting anywhere and then it's been useful to look at the graph and see that actually I'm doing fine. I'll miss it next month!
There are also other reasons to take part – for instance camp sends you daily emails with writing prompts and challenges which are helpful if you're suffering from writers block. It's a great idea but I haven't read many of mine as I've been too focussed on writing!
So there you have it: for the first time in my life I'm enjoying camping!
This entry was posted in Pondering, Prose and tagged campNaNoWriMo, creative process, goals, novel, writing on 20 July 2014 by Maddy.
CampNaNoWriMo starts tomorrow so preparations here are in full swing!
Although by 'full swing' I mean I'm sitting here thinking 'I really must get organised' while actually doing nothing at about it. But that's pretty much how I start every holiday – I'm a last minute scrambler who's much more likely to concentrate on writing a list of things to pack than actually getting anything in the suitcase.
Not that CampNaNo is a real holiday (and thank god for that, I hate camping) it's just a virtual one: "An idyllic writers retreat, smack-dab in the middle of your crazy life" is how it describes itself. I just have to write 15,000 words in a month and enter daily word counts onto the camp nano website. Easy.
Or perhaps not as I struggled to write 10,000 words this month and school holidays start in the middle of July so I'll have even less free time. But I'm up for the challenge!
Anyway some things are sorted. For a start, last night I completed the 10,000 word challenge I sent myself for June so the first draft of my novel stands at just over 30,000 words now. So assuming I reach my CampNaNo goal it should have reached 45,000 by the end of July which is probably more than half of the draft. I say 'probably' because, due to not being a planner, I have no real concept of how long my book is likely to be. But my gut says 80,000 words (give or take the odd 10,000).
What I DO need to do before tomorrow though is sort out my characters as some of them are a bit hazy. And I could really do with working out where the next few chapters are going to be taking me. I'm currently following a 'let's see what happens' approach which is quite fun (and surprising) but is a bit too 'seat of the pants' to be comfortable. And I need to be comfortable while camping don't I? I've got to have an air bed and a camping stove and my own duvet at least!
This entry was posted in Pondering and tagged campNaNoWriMo, creative process, goals, intention, novel, writing on 30 June 2014 by Maddy.
Ever heard of NaNoWriMo (Nation Novel Writing Month) ?
In case you haven't, it's an annual, online creative writing challenge to write a 50,000 word novel between the first and the last day of November. It's been running since 1999 and attracts participants from across the world.
It describes itself as: "a fun, seat-of-your-pants approach to creative writing… for anyone who has ever thought fleetingly about writing a novel." Basically you write (crazily fast) throughout the month, entering what you've written into their secure site where the words are counted (but never seen by a human eye) and logged. If you hit the target by the end of the month you are declared a winner. And maybe you'll be able to get your novel published at some point in the future – over 250 NaNo novels have been traditionally published since its inception… and counting!
Sounds fun? A bit mad perhaps? Well yes. I toyed with the idea of taking part in it last November (for all of two seconds before deciding: "Who am I kidding? I couldn't possibly do that – I haven't slept for nearly a year!") and am vaguely considering doing it this year.
But then via my friend Chrissie who is a total NaNoWriMo enthusiast (I think she may have done seven of them… possibly more) I became aware of an offshoot of the main event: CampNaNoWriMo which takes place twice a year in April and July. This is a less pressured event that you can enter with anything upwards of 10,000 words (and you can write short stories and scripts and things – it's quite flexible).
So, I've decided to take part next month! I'm all signed up with a target of 15,000 words. If I manage that (and if I hit my 10,000 target for this month) my novel will have reached 45,000 words by the end of July.
I'm quite excited! But it does mean I need to write fast to finish my target for this month. I also need to leave myself time before July 1st to do some preparation work because basically I've got to the point where I need to plan more of my book before I can write more of it. Yes, If you're a fastidious planner you can read this and feel smug because my novel is barely planned at all. I only really have a vague outline and am mostly making it up as I go along. Tsk.
On that note, I'd better scarper.
This entry was posted in Pondering and tagged campNaNoWriMo, creative process, goals, NaNoWriMo, novel, writing on 23 June 2014 by Maddy.


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Home Top News ECP dismisses Cheema's allegations as 'baseless'
ECP dismisses Cheema's allegations as 'baseless'
A day after the rejection of the nomination papers of PTI leader Jamshed Iqbal Cheema, and his wife for NA-133 (Lahore) by-poll scheduled for Dec 5, the Election Commission of Pakistan dismissed on Sunday the allegations he leveled against it as ill-founded.
On Saturday, the returning officer rejected the nomination papers of Cheema and his wife Musarrat (his covering candidate) on the ground that the proposers and seconders for the two are not residents of the constituency as required under the relevant election laws.
In a statement, the election body said Cheema accused it of transferring the votes of his proposers from NA-133 to some other constituency.
The ECP said their votes are registered in NA-130 since 2018, adding that 2018 voter lists and subsequent review lists are available on record to back up its claim. It vowed not to make any compromise over the transparency of the election.
On Saturday, the ruling PTI decided to challenge the Election Commission of Pakistan decision of rejecting the nomination papers of Cheema and his wife.
Cheema, speaking at a presser, said that no one could be barred from participating in the election process on a technical basis. "The biggest party of the country could not be deprived of the right to contest the by-election," he said.
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Ford Mustang Mach-E GT: an ice-proof SUV
Ford now wants to offer a new, even stronger image. To prove it, the brand invited us to test the Mustang Mach-e GT in extreme conditions.
The world is changing. And it's not the auto industry that says otherwise, where all players are trying to find a new way to reconcile their historical DNA with market demand. It gets stuck on the side of the Ford. Despite the appearance of the Ford Mustang Mach-E, which has already violently turned a page in the history of the manufacturer, the Blue Oval still has a watered-down image in this part of the world.
Test – Ford Mustang Mach E: consumption, autonomy and measured performance of our supertest
These are the scars of a long-standing rift between Ford USA and Ford Europe, born out of the merger of British and German branches. If the bridges over the Atlantic still existed, from the 90s the brand launched the One Ford movement to close ranks and become one. But there were still models specific to the European market, but there was no real icon. But if the Mustang, Mach-E or Explorer can cross the ocean since then, Ford will give it a big shot with the new Adventurous Spirit movement.
A new adventure for Ford
With this new look, Ford plans to assert its origins and break away from its fake German brand image. It will avoid this without going through the 100% electric box, small Fiesta and Focus, S-Max and C-Max minivans, Mondeo sedan and EcoSport crossover, among others. In other words: all models that no longer carry the image the brand is looking for. It is also clear that the models that no longer fit the market, the more bulimic SUV with ever-stretching dimensions.
That's what this new strategy, which will focus on the kind of cars that Ford can carry the desirable image of the United States above all, proves. They will be divided into four big families. There we will find the line Escape from the city, with city models like the Ford Puma. The Adventure Active series will focus on SUVs designed for family use and exploring new horizons. Almost unseen, row Ultimate Outdoor It will highlight the ruggedness with the arrival of vehicles with Yankee blood like the officially imported Bronco.
Ford presented us with a new 100% electric strategy until 2030 (but not only).
Finally, Ford will not neglect the sports fiber with the family Wild Performance, where the Ford Mustang Mach-E already sits, we recognize as one of the first pillars of the inevitable electrification of all these next series. Because it's also where Ford wants to go, from 75 EV orders per day in Europe to 2,000 in 2024. So Ford doesn't want to be a niche manufacturer, but it's on a slippery slope. do it quickly and well to achieve their short-term goals. And to show us the philosophy better Spirit of adventure and with all the art of jumping on slippery ground, the manufacturer entrusted us with the Mustang Mach-E GT on the Flaine ice circuit.
An elephant in a china shop
This SUV, we already know that. And this is especially the case with the GT version, which left us with fond memories during its official launch: its brash character has everything Mustang. If that's not enough to make it a true Mustang, the Mach-e is definitely the Mustang of SUVs: it's a flood everywhere, always quick to get out of its way, whether it's in terms of power or the level of the rear axle. It declares the color.
Ford Mustang Mach-E GT test: electric hooligan
But on the ice it is better than ever not to put the brain in the glove box, just like on the asphalt of the road closed for the event. Despite the presence of dirty tires, the physics is there and the 2.2-ton SUV is waiting to go straight. Therefore, it requires strong neural connections and a lot of finesse in the execution of commands, which does not facilitate conditional withdrawal. Something to make you feel like an elephant in a china shop.
Especially since all the excesses here are paid in cash, sometimes with excessive braking and shaky ABS, sometimes with a saturated front axle. The solution: lie and trick the electronic crutches by caricaturing the movements and stepping outside your comfort zone. One way to achieve this is to tip the car on the nose before cornering with the brake grid, keeping the angle on the steering wheel longer than necessary and quickly and quickly re-aligning the axle. short acceleration. If well-choreographed, you'll slide off all four wheels without excessive train slip, which should be prohibited in any case: any attempt to reverse steer prematurely realizes the systems' trickery and can then send you into the wall. from the snow. It's not easy.
The electric fairy is in the service of motor skills
If the benefits of the electric fairy are many, the ones brought when driving on snow or ice allow more than one conversion. However, even the best integral transmissions with a manual shaft will never show the same immediacy and precision of transmission provided by two independent electric machines. Only in a very small window will it be possible to maintain drift in the dust plume after sinking between the bottom spin and the spin.
Video test – Ford Mustang Mach E GT: Electric monster for Halloween
Obviously, such an exercise is far from all the notions of efficiency that an electric car wants to promote. We have definitely forgotten that day because we weren't there for it. However, we still wanted to perpetuate the consumption meter. After first setting a record for Automobile Propre with an average of 69kW/100km, we're up to 82kW/100km here, or the equivalent of 110km of autonomy in these conditions. . But it is of course completely useless to consider these energy data, because they do not represent any reality.
He was born in the United States
If its weight is sensitive, the Mustang Mach-E demonstrated on asphalt as well as snow that its dynamic capabilities can be much closer to that of a (very) large sedan than an SUV. Therefore, many were able to find their account with the new "all SUV" strategy sought by Ford, even with an electric drive system. But the manufacturer still has a long way to go, he will have to monitor all his indicators to know if he is on the right track. If the analogy with our driving session is confirmed, the future is sure to be fun.
Currently, the Ford Mustang Mach-E GT is one of the only US-made representatives of this future. Keep in mind that it is listed at €87,200.
Photo credit: DR Clément Choulot
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Q: How do I get a list of redirect urls from Dell.com I am working on a web scraping project and want to get a list of products from Dell's website. I found this link (https://www.dell.com/support/home/us/en/04/products/) which pulls up a box with a list of product categories (really just redirect urls. If it doesn't come up for you click the button which says "Browse all products"). I tried using Python Requests to GET the page and save the text to a file to parse through, but the response doesn't contain any of the categories/redirect urls. My code is as basic as it gets:
import requests

url = "https://www.dell.com/support/home/us/en/04/products/"
page = requests.get(url)

with open("laptops.txt", "w", encoding="utf-8") as outf:
    outf.write(page.text)
    outf.close()

Is there a way to get these redirect urls? I am essentially trying to make my own site map of their products so that I can scrape the details of each one. Thanks

A: try using selenium chrome driver it helps for handling dynamic data on website and also features like clicking buttons, handling page refresh etc.
Beginner guide to web scraping

A: This page uses JavaScript to get and display these links - but requests/urllib and BeautifulSoup/lxml can't run JavaScript.
Using DevTools in Firefox/Chrome (tab: Network) I found it reads it from url
https://www.dell.com/support/components/productselector/allproducts?category=all-products/esuprt_&country=pl&language=pl&region=emea&segment=bsd&customerset=plbsd1&openmodal=true&_=1589265310743
so I use it to get links.
You may have to to change country=pl&language=pl in url to get it in different language.

import requests
from bs4 import BeautifulSoup as BS

url = "https://www.dell.com/support/components/productselector/allproducts?category=all-products/esuprt_&country=pl&language=pl&region=emea&segment=bsd&customerset=plbsd1&openmodal=true&_=1589265310743"
response = requests.get(url)

soup = BS(response.text, 'html.parser')

all_items = soup.find_all('a')
for item in all_items:
    print(item.text, item['href'])

BTW: Other method is it use Selenium to control real web browser which can run JavaScript.