Article Review Essay

Conducting their study as the transitional funding attached to the peace process in Northern Ireland is reaching its end, the authors examine the role of aid in conflict resolution particularly with regards to intangible outcomes such as identity formation. The idea behind this funding is that it reduces economic disparities between the conflicting groups and that the economic growth started by this funding will continue into the future. These funds come from the International Fund for Ireland (IFI), which addressed unemployment and poverty in Republican / Loyalist communities; the Peace I funds, which promoted social inclusion, cross-community contact, and economic development; and the Peace II funds (ended in 2006), which had similar goals to Peace I but targeted local, grassroots (nongovernmental) organizations. The authors also consider the role of external agencies as they intervene in ethnopolitical conflict and the importance of community development in the peace process. The authors are careful to note that economic aid is not a magic cure for conflict as this aid, if improperly administered, can at times heighten underlying conflicts. Indeed, in Northern Ireland, the approach has had mixed results. In designing their study, the authors took both a qualitative and quantitative approach. For the qualitative portion, the authors interviewed 98 community leaders, civil servants, and development officers from Belfast, Londonderry/Derry, and the Border region (Northern Ireland). These interviews consisted of semi-structured questions, including those attached to the Cantril Self-Anchoring Striving Scale: â€Å"What are your best wishes and hopes for your personal future? What are your worst fears and worries about your personal future? What are your best wishes and hopes for the future of your country? What are your worst fears and worries about the future of your country? † (page 166). The quantitative data was drawn from the summer 2006 Northern Ireland Public Opining Survey. The sample consisted of 1,023 adults representative of Northern Ireland’s adult population. The study as a whole was designed to look at the respondents hopes and fears about Northern Ireland’s future. Through the inclusion of qualitative data, the authors hoped to demarginalize voices that are often not heard in the official discourses of the peace process. This study yielded numerous tantalizing findings. First, the authors found that more Nationalists than Unionists imagine a future where conflicting groups are able to perceive a sense of shared community. Second, the authors found differences based on gender: more females than males saw the opportunity for building new relationships amongst communities in the future. Third, the authors found two common fears / concerns that extend across religions, genders, and ages: the fear that violence in changing the social fabric of Northern Ireland and the belief that politicians are disingenuous and not interested in serving the needs of their constituency. Fourth, the authors found that more Nationalists than Unionists saw the modernization of the economy and the political structure as means by which to support the peace process. Finally, the authors found that younger adults were more concerned about the potential failure of the peace process and the economy than older adults The authors consider numerous theories about identity formation. In designing their study, they took into consideration geographic differences in identity formation: i. e. Londonderry/Derry vs. Belfast and urban vs. rural locations. They also consider how the Irish view immigration and the infiltration of outside values. In general, this article is not convincing. Its primary strength is the detailed background to the conflicts in Northern Ireland, with a focus on the economic causes and effects of this conflict. This strength does not mitigate the effects of the article’s numerous weaknesses. First, the authors do not explicitly state their hypothesis. While exploratory studies such as this one can potentially reveal valuable information, the authors nowhere state the reasons behind the study. When questions such as identity formation are being explored, the readers need to know the authors’ relationship to the issue. For example, are the authors somehow involved in this ethnopolitical conflict? Or, are they looking at it from the perspective of an outsider? If they are outsiders, does their perspective have a bearing on how the respondents answer their questions? Second, the authors explicitly state that they wish to demarginalize those voices that are not typically heard in the official peace process discourse. However, in selecting the respondents for the qualitative portion of the study, the authors chose community leaders, civil servants, and development officers. It would seem that these are precisely the voices that are heard in the official discourse. Readers are left to wonder why the authors did not include a more representative sample of the population of Northern Ireland for this portion of the study. Third, this does not seem to be a study that was designed specifically to answer certain questions. As noted, the authors nowhere state a hypothesis. For the reader, it appears that the quantitative and qualitative data seems to have been mixed together ad hoc. In other words, the study does not seem to be designed to fit a specific question. Rather, the authors appear to have attempted to answer questions based on the information they had at hand. Fourth, as the basis for this study was largely to examine economic role of the peace process, it seems like a gross oversight that the authors did not provide data on their respondents’ demographics. In the discussion section, the authors indicate that they collected background demographic information (political party, religious views, age, gender, socioeconomic status) on the respondents, but this information was not included in the results section and does not appear to have been considered in any significant way. Finally, the analysis of the qualitative data seems a bit lacking. It would perhaps have been stronger to indentify the common themes and subthemes of the responses, rather than using the responses as illustrative examples. Because of these specific weakness as well as the authors’ failure to mention the limitations of their study and to provide specific recommendations for how their results can be used to generate future studies and/or to impact the peace process, this article is not convincing.

Health tourism,a boon or a curse Essay

Health Tourism (Also known as Medical tourism) refers to the act of traveling to a foreign country in order to receive medical care. Varying reports based on the US alone put the number of American patients seeking healthcare abroad between 500,000 to 750,000 in 2007. This is a steady increase from 2006 in which medical experts believed as many as 200,000 to 1/2 a million Americans traveled out of the country for medical procedures. These figures indicate a significant growth in the industry, currently a $20 billion market, which can reach $100 billion by 2012. Governments in places such as India and Malaysia (as well as some others) are already getting involved and investing in this growing industry. The main reasons that people travel to receive medical treatment are: Certain medical services are not available in their country of residence. Their health insurance does not cover the full cost of a procedure. Wait lines are too long. Quality of care is better in a different country. Costs are lower in a different country. (even when factoring in the travel arrangements) Medical tourism is a growing sector in India. India’s medical tourism sector is expected to experience an annual growth rate of 30%, making it a $2 billion industry by 2015.[1][2] As medical treatment costs in the developed world balloon – with the United States leading the way – more and more Westerners are finding the prospect of international travel for medical care increasingly appealing. An estimated 150,000 of these travel to India for low-priced healthcare procedures every year.[3] Advantages for medical treatment in India include reduced costs, the availability of latest medical technologies,[4] and a growing compliance on international quality standards, as well as the fact that foreigners are less likely to face a language barrier in India. The Indian government is taking steps to address infrastructure issues that hinder the country’s growth in medical tourism. The government has removed visa restrictions on tourist visas that required a two-month gap between consecutive visits for people from Gulf countries which is likely to boost medical tourism.[5] A visa-on-arrival scheme for tourists from select countries has been instituted which allows foreign nationals to stay in India for 30 days for medical reasons.[6] In Noida, which is fast emerging as a hotspot for medical tourism, a number of hospitals have hired language translators to make patients from Balkan and African countries feel more comfortable while at the same time helping in the facilitation of their  treatment.[7] Confederation of Indian Industry reported that 150,000 medical tourists came to India in 2005, based on feedback from the organization’s member hospitals. The number grew to 200,000 by 2008. A separate study by ASSOCHAM reported that the year 2011 saw 850,000 medical tourists in India and projected that by 2015 this number would rise to 3,200,000.[8] Most estimates claim treatment costs in India start at around a tenth of the price of comparable treatment in America or Britain.[9][10] The most popular treatments sought in India by medical tourists are alternative medicine, bone-marrow transplant, cardiac bypass, eye surgery and hip replacement,dental treatment. India is known in particular for heart surgery, hip resurfacing and for dental treatments at cheap prices. Lower treatment cost does not necessarily mean lower healthcare standards. There are 18 JCI accredited hospitals in India.[11] However, for a patient traveling to India, it is important to find the optimal Doctor-Hospital combination. After the patient has been treated, the patient has the option of either recuperating in the hospital or at a paid accommodation nearby. Many hospitals also give the option of continuing the treatment through telemedicine. The city of Chennai has been termed India’s health capital. Multi- and super-specialty hospitals across the city bring in an estimated 150 international patients every day. Chennai attracts about 45 percent of health tourists from abroad arriving in the country and 30 to 40 percent of domestic health tourists. Factors behind the tourists inflow in the city include low costs, little to no waiting period, and facilities offered at the specialty hospitals in the city. The city has an estimated 12,500 hospital beds, of which only half is used by the city’s population with the rest being shared by patients from other states of the country and foreigners. Dental clinics have attracted dental care tourism to Chennai[17] India’s annual earnings through Medical Tourism is all set to double to 8000 Crore Rupees [2000 million US dollars] by year 2012 according to a recent study. The main reasons the study claims why medical tourism would flourish in India include much more lower medical costs for various surgical procedures such as bone narrow transparent, coronary bye-pass surgery, knee transplant and liver transplant as compared to western countries and even many of the Asian countries. Very good medical infrastructure not only in large Metros but also in tertiary  towns is another reason for medical tourists favouring India.Availability of highly qualified medical professionals and nurses gives them the confidence to do such major procedures here. The disadvantages are: It make health sector highly commercial and the common man in the country will be hard pressed for medical care; 2) All the resources of health sector will be thrown open for the international tourist so much so that even the so called middle class will be able to ill afford the medical care. 3) Patients from overseas, if they come in droves, may bring in new types of diseases and the risks of infection. 4) In the name of medical tourism, many people who want to enjoy themselves in this country, with the ostensible intention for treatment in this country, may turn the hospitals into merry making resorts and convert the hotels into hospitals.Tourism has its own benefits as well as demerits.

Accounting Equation Paper Essay Example for Free

Accounting Equation Paper Essay ? The basic accounting equation is: Assets = Liabilities + Stockholders’ Equity. When looking at the balance sheet one can assume that assets must balance out each transaction and balance the claims to the assets (Kimmel, 2010). A balance sheet provides Assets of the company first and foremost, then Liabilities and Stockholders’ Equity and last retained earnings. This shows the companies incoming money, outgoing payments, and the money left or retained at the end of each time period being documented on the balance sheet. The components of the accounting equation affect each other in many ways. For example, when cash assets are received the company is making profit only as long as it is making more revenue than the liabilities owed. So, when using the Sierra Corporation on pg. 14 from the text the company has to pay the Liabilities: Notes payable, Accounts payable, Salaries payable, Unearned Service revenue, and Interest prior to ever turning a profit above the black. When looking at a balance sheet one needs to know all incoming as well as outgoing money to determine profitability and sustainability of a corporation. Next, when looking at a balance sheet the liabilities + the stockholder’s Equity have to ALWAYS balance out to amount of assets to ensure all things are accounted for and there are no accounting errors. When done properly the balance sheet can be used to verify the company’s revenue and the financial stability of a company based upon debt to stockholders’ equity. References: Kimmel, P. D., Weygandt, J. J., & Kieso, D. E. ( 2010). Financial accounting: Tools for business decision making (6th ed.). Hoboken, NJ: John Wiley & Sons. Accounting Equation Paper. (2016, Dec 10).

A Closer Look Into the Works of Wolfgang A. Mozart Essay

A Closer Look Into the Works of Wolfgang A. Mozart - Essay Example In all of Mozart's supreme expressions of suffering and terror, there is something shockingly voluptuous."Wolfgang Amadeus Mozart is considered one of the musical genius who produced various masterpieces during the classical period. Being a prolific composer during his life, he has composed a wide array of musical masterpieces which are widely acknowledged as "pinnacles of symphonic, chamber, piano, operatic, and choral music. These output became closely identified as parts of the standard concert repertory and are regarded as "masterpieces of the classical style (Wolfgang Amadeus Mozart 1)."Mozart was born in the city of Salzburg to Leopold and Anna Maria Pertl Mozart. When he was about three years old, Mozart's father noticed his unique musical ability.Through his father, one of Europe's leading musical teachers that time, Mozart received his intensive musical training. His father taught him to play the clavier, violin and organ. This began the famous composers' musical career wher e his formative years were spent in successful journeys throughout Europe--beginning with an exhibition in 1762 at the Court of the Elector of Bavaria in Munich and another at Imperial Court in Vienna during the same year. Afterwhich a long concert tour spanning three and a half years followed, taking him with his father to the courts of Munich, Mannheim, Paris, London, The Hague, again to Paris, and back home via Zrich, Donaueschingen, and Munich. However, they went back to Vienna during 1767 (Wolfgang Amadeus Mozart 2-6). It was in Vienna where Mozart encountered huge successes in opera. This paper will further examine the musical style utilized by Mozart in his famous compositions. As his works are generally classified as "classical masterpieces" a good starting point will be a general description of the characteristics of classical music. The next part will then tackle his works and musical style as well as Morton's characterization of the "Mozart's Musical Trademark." Social factors and other composers styles and influences which are incorporated in his works will also be examined. This report will conclude with its findings. Mozart Musical Style: Archetypal Example of Classical Style The musical style of Mozart, like that of the other Austrian composer Haydn, are considered as "archetypal example of the classical style." Accordingly, the classical period is characterized by the proliferation of music which generally has gradual and sudden contrast in mood, flexible rhythm, homophonic texture, and folkish melody. The type of music during this period can also be identified as having a more orderly and symmetric musical design compared to other eras. It should also be noted that the classical period marked the rise of amateur musicianas the the popularity of piano over the hapsichord. Accordingly, the musical style of Mozart closely paralleled the development of the classical music as a whole. This musical style was applied to his compositions which spans almost all musical genre including symphony, opera, the solo concerto, chamber music which includes string quartet and string quintet, and the piano sonata. While none of the aforementioned genre are new during his period, Mozart is regarded as having single-handedly developed and popularized the solo concerto. The composer is also famous among religious sects as he composed a great deal of religious music known as masses. His versatility as a composer also enabled him to venture into other musical forms like dances, divertimenti, serenades and other forms of light entertainment (Wolfgang Amadeus Mozart 23-24). Mozart's compositions greatly embody the

Identify three of the course learning outcomes that you will apply to Essay

Identify three of the course learning outcomes that you will apply to achieve your personal and professional goals and provide a - Essay Example Ethical values are also important factor for the effective leadership. The paper also demonstrates the effective application of personal leadership perspectives. Learning outcomes are the educational aims and objectives. The learning outcomes are the skills and goals that a learner achieves after a period of specified and supported study. At the end of the course program student can reliably demonstrate his skills. University of Warwick (2004) categories the learning specifications into four categories: Subject knowledge and understandings Subject specific skills are practical skills, practice of which is integral to the course, e.g. laboratory skills, language skills and counseling skills. Cognitive skills, intellectual skills such as an understanding methodologies, synthesis, evaluation or ability in critical analysis. Key skills are skills that are readily transferable to employment in other contexts, such as written and oral communication, working within a team, problem solving, numeric and IT skills. The learning outcomes broadly specify the: needs of the learner, needs of the society, learner knowledge about the particular subject. During my studies, under the supervision of my teachers/instructors the personal skills I acquire are: Ability to work in team, Effective communication, Ability to solve problem. As a student of business administration my professional skills are related to the business planning and management. The basic course learning outcomes of my studies which help me in my profession are: I will be able to 1. Explain the important terminology, theories, principles, concepts and analytical techniques used in leadership. 2. Apply the known terminology, theories, principles, concepts and analytical techniques used in leadership when analyzing complex and complicated managerial situations 3. Effectively synthesize important terminology, theories, principles, concepts and analytical techniques used in leadership when solving the sophisticated p roblems in complex managerial solution. These outcomes help me to achieve my personal and professional goals successfully in my field. Now I highlight one by one on the benefits of these outcomes Primary leadership theories for profit and non-profit organizations There are number of leadership theories which fall into following categories: 1. Trait theory of leadership. 2. Behavioral theory of leadership 3. Contingency theory of leadership. 4. Transformation theory of leadership 5. Invitational theory of leadership. 6. Transactional theory of leadership. 1. Trait theory of leadership. Early trait theories argued that the leadership qualities are innate and instinctive qualities. You either have these qualities or not. These are inherited Like Great man theory. Early studies assumed that leaders are born not made. But now trait theory refers to the external behavior, particular personality and behavioral characteristics much depending on the internal beliefs and thinking power of a l eader. Their main examples are: self-assurance, self-confidence, feelings and good decision making skills. Traits are the key features of the leadership. Edwin Ghiselli (1971) identified six traits for an effective leadership. These are: supervisory ability, need for occupational achievement, intelligence, decisiveness,

What is the most important skill (culinary arts) Essay

What is the most important skill (culinary arts) - Essay Example The chefs should ensure that the food particles spill on their clothing. A person’s outward appearance depicts more of the individual behavior. The second skill is respect. The chefs respect their fellow workmates as well as the working environment and the equipment. Respect entails keeping clean the workspace and the equipment after use. It also ensures that people learn how to economize on the ingredients in the kitchen and the industries as well. People should also respect the natural environment that gave rise to the inputs they process in to get output. Third, people should learn how to manage wastes. The chefs Alison Cayne observed learnt how to dispose of their wastes. They always ensure to use the entire ingredients so as to reduce the amount of waste to a minimum. The chefs also appreciate how expensive the ingredients were and, therefore, minimize the amount of waste to maintain the economic feasibility of their cooking practices. Fourth, the chefs exhibit a sense of appreciation of learning. The chefs learn from the real-time environment and apply the skills to build on the technical skills in the kitchen. In the kitchen, each chef teaches and learns from the other chefs. Applied to the industry, and classroom settings, employees, and the students continuously learn from other members. The fifth skill discussed is the appreciation of the process. The learning process proceeds systematically. The learners begin from a particular point and builds on their career as they continue along with their profession. It requires hard work to obtain the required skill to perform a specific task (Cayne 1). Those who successfully master the skills get promotion and eventually become the CEOs of the institution. She, however, says that the skill is not prevalent in the restaurant community. The sixth skill is the ability of preparedness. The skill is similar to respect and neatness. The ability ensures that the producers of a particular commodity strive to

Decision to Charge Appropriate Interest Rate Essay

Decision to Charge Appropriate Interest Rate - Essay Example However, if any of the above mentioned determinants, fails to meet the expectations of the investors, then investors become shaky regarding their investments. The investors are mainly of two types, one who receives the ownership of the business by purchasing the shares of the company, in this way they invest in the company and are known as shareholders. They demand their return in two major ways i.e. dividends (distribution of profits) and capital gain (increase in the value of shares). On the other hand, the other kind of investors, are the creditors and they provide loans to the business such that amount of loan is repayable in certain time against which they demand a return in the form of interest. Generally, if the financial prospects of the business seem sound in the future, shareholders also require more return. However, if the financial prospects of the company are to show more vulnerability and inconsistency, then loan providers charge higher interest because their investment comes at stake due to increasing risk of solvency, bankruptcy and likelihood of inability of business to pay interest and principal. In short, out of the two types of investors, i.e. shareholders and debt holders, this particular article mainly focuses upon the required rate of return demanded by the debt holders only. Generally if an organization’s future financial outlook seems to be stable and bright looking, the debt holders prefer that organization to invest in as they would find their investment less risky as compared to that organization which is found to be struggling in dealing with its financial prospects. To be more specific, debt holders will charge less interest to that business which has consistent and growing cash flows, profitability, less amount of debt included in the overall capital structure and increasing net worth of the business. All of the above mentioned factors are the determinants of a safe, prosperous and better looking business. Conversely, debt holders would charge a relatively higher interest from those businesses which have inconsistent cash flows and profitability, highly indebted and having vulnerable net worth of the business in upcoming periods. Debt holders find their investment highly risky and as a result of bearing that extra risk, they demand higher interest to compensate that risk. As far as ACME Consulting Business is concerned, its cash balance is going to increase at double rate on yearly basis with the amounts of $39K, $138K and $177K. The net profit margin is also estimated to increase as it will be 0.33%, 4.87% and 5.94% respectively. Total Debt to Total Asset ratio will also be expected to decline from 76.55% to 61.24% in three years time. Lastly, Net Worth to Total assets of the business is estimated to increase from 65.09% to 86.31% in the same period. Debt ratio of the business is however higher than industry which is a questioning sign for the business. Net Worth ratio is better than the industry whi ch can be a positive sign for the business in future. For Interstate Travel Center, the cash balance will also be increased at almost a double pace, with

As Most Theories on Motivation Are Ethnocentric In Nature, They Have Essay

As Most Theories on Motivation Are Ethnocentric In Nature, They Have Little Value in A Geocentric World - Essay Example Ethnocentrism is considered as types of attitudes as well as behaviours of various individuals. Ethnocentrism behaviour involves cooperation of members within groups and absence of cooperation outside groups. An individual with ethnocentric behaviour considers one’s group as superior and outside group as inferior and disgraceful. The implication of ethnocentrism is not only present in war and conflict rather it may be available in consumer choice. It also arises from the competition between individuals. There is no precise difference between the evolutionary procedures in order to deal with own group members and members of other groups (Axelrod & Hammond, 2003). In ethnocentrism facts, the psychological aspects of individuals possess both negative and positive outcomes. It may also cause misunderstanding and intercultural-willingness-to-communicate may get decreased. When the sensitivity of intercultural communication increases, the competence level also rises, but ethnocentrism acts as ‘an obstacle to intercultural communication competence’. The sensitivity of intercultural communication as well as multiculturalism encourages cultural diversity and maintains cultural appreciation so as to motivate the people for eliminating ethnocentrism (Dong & Et. Al., n.d.). The policy of ethnocentrism may lead to â€Å"cultural myopia† and the staffing of ethnocentric brings restriction in the development of opportunities in host nations (Hill, 2008).

To what extent do you agree with free market economies being more Essay

To what extent do you agree with free market economies being more effective than a mixed economy - Essay Example The following are some of the mixed economies where with illustrations indicating statistics of government spending in relation to GDP: Sweden 57%, France 52.8%, Iceland 57%, USA 38 %, China 20%, UK 47.3, and Hongkong 18.6%. There are other countries as well. Such economies are government managed while the rest are individual or private firms managed. As the economies grow, the government usually takes higher portion of the total spending. In developed countries, e.g. Western Europe opts to offer state welfare support. The government greatly regulates business environment and environment. Benefits of Mixed Market Economies Most businesses and industries are usually governed privately. Normally, private firms are more effective than government ones since they are usually innovative in nature and provide cheaper services and products. In a mixed economy, the government does not have the total control over the market i.e. such as in market regulation et cetera. It has been argued (Urai 2010) mixed economy may in given cases allow government to regulate the market during instances of market failure. This may include: Regulation of monopoly where they abuse their status e.g. controlling hiked prices, prevent mergers, subsidizing goods and services commonly under consumed in free market. This may include healthcare, national defense, public goods. Regulation and taxation of goods with negative implications e.g. Government can implement policies to provide macroeconomic stability e.g applying monetary policy measures during of inflation. Economic reports have shown that mixed economies are likely to create equality at a greater level while reducing extreme poverty. It may simultaneously enable people to enjoy financial rewards from their entrepreneurship and hard work (Beckwith 2011). Disadvantages of Mixed Market Economies It may be difficult to determine to what extent the government will intervene. Mixed economies usually face criticism from socialists and economis ts owing to the fact it allows excessive market forces amounting to inefficient and inequitable distribution of resources. It is criticised by free marketing since it allows too much government intervention. According to libertarians, governments are generally poor managers of economy normally influenced by short term and political factors. According to Chow 2012, the reality is, success of mixed market economies depends on how they are managed. Economists argue that every market needs some extent of government intervention. In the book, ‘Wealth of Nations’, Adam Smith argues that in wealthy countries, government should come in between to control the monopoly power. Free Markets There are various benefits that are usually associated with free markets. This has created a school of thought that basically supports the corpus of free markets economies. One of the benefits that are associated with free markets is the fact that they are competitive in nature. Their industries are commonly perfectly competitive, allocative and efficient at production. Free economies efficiently allocate their resources. Additionally, there is also variety of choices associated with free markets. Firms produce what consumers are willing and ready to buy. As it is a free market, there is no restriction as to what a firm can produce. Therefore there is usually a possibility of having a large choice compared to the mixed market. The interest of the planner is to ensure

Paper on Skunk species (Memphitis Memphitis) Research

On Skunk species (Memphitis Memphitis) - Research Paper Example Hooded Skunk (Mephitis macroura). Among these five species of skunks, the striped skunks are the largest. Striped skunks weigh up to fourteen pounds and are about the size of a house cat. They have a stout body, small head, short legs with webbed toes and a bushy tail. The thick, glossy fur is black in color with a thin white stripe down the centre of the face and a broad white stripe beginning on the back of the head which usually divides into two stripes continuing along the back. The long, bushy tail is a mixture of white and black hair. The legs have long, straight claws which they use for digging and ripping apart things as they search for food. Male striped skunks are somewhat bigger than their female counterparts. The skunk has small eyes and ears. Although it can not see well, it has a good sense of smell and hearing. Habitat and Habits The striped skunks are adaptable but prefer open areas of mixed forests and grasslands. They generally live in the abandoned dens of woodchuc ks, foxes or other mammals of similar or larger size and only occasionally excavate their own dens (Encyclopedia Britannica). Since they have very little fear of humans they often inhabit developed areas and nest in houses, walls, basements, culverts and beneath buildings, wood and rock piles. The striped skunks are usually not more than two miles away from water. Although striped skunks can dig their own dens, they seem to prefer moving into ones constructed by other animals. These dens may have one to five well-hidden openings that lead to a system of tunnels and chambers (University of Wisconsin-Stevens Point). They line one of the chambers with leaves and use it as a nest. The leaves are also used to plug the openings to the den during cold weather. A skunk gathers leaves by placing them under its body and then shuffling along to the den with the leaves held between its legs as it moves. Skunks are primarily nocturnal i.e., they are active at night and usually solitary animals. However, mother skunks can often be noticed with their offspring in tow. Skunks leave their den to rummage for food at any hour of the day. However, they are usually away from late afternoon or evening through the night. They usually move within a radius of about 800 m from the den looking for food but may go as far away as 2 km in a night (University of Wisconsin-Stevens Point). Males become more active during the breeding season and can travel as much as 8 km in a night. Adaptation Skunks are active throughout the year but go into a state of torpor inside their dens during the coldest spells of winter (Welcome Wildlife). They prepare for the winter by going on eating binges in the fall and developing a heavy layer of fat and a thick coat. Unlike hibernation, which involves significant drop in body temperature and considerably slow heart rate wherein the creature takes only about one or two breaths per minute, striped skunks go into sporadic groggy sleep intermittent with periods o f active and awake time. Studies have shown that the heart rate, body temperature and respiration of skunks drop only a little. Skunks take long torpor naps in their dens and come out to empty their scent glands and look for food when the temperature becomes warm even slightly.

Parallels between Gilgamesh and Genesis Essay Example for Free

Parallels between Gilgamesh and Genesis Essay I. Introduction: Today, we are often bombarded with various inventions and discoveries coming from different parts of the world. But it is with great amazement when we look upon the advancement made by an ancient civilization that has come to be acknowledged as the cradle of civilization, Mesopotamia, at a time when most of its neighboring people-group was pursuing a nomadic life. Not only have they revolutionized human society through its invention of the wheel, writing too, must have originated in this place as shown by the Epic of Gilgamesh. Ancient as it is, being one of the world’s earliest-known epic poetry (â€Å"Epic†) taken from Sumeria and which the Babylonians developed into a long poem, it is undoubtedly beautiful; and ancient as it may be, high respect should be given   to it as one of the literary masterpieces of mankind. Genesis on the other hand, is the first book of the Bible. Genesis is the Greek word for â€Å"beginning† or â€Å"origin†, and is a Greek translation derived from the Hebrew b’reshith meaning â€Å"in the beginning†, the first word in the Old Testament. II. Meaning and Importance A. Epic of Gilgamesh At the outset, as one reads through the poem, it would readily display the glorification of the central figure, the historical warlike king of Uruk Gilgamesh. All throughout the poem, the reader is led through his many exploits and achievements of Gilgamesh that gives the over-all impression of a constancy of battle-like stance. This I would not find surprising since this people’s land was always subjected to crisis such as the threat of invasion or the flooding of the rivers. As to the story, it relates much on how he has overcome every opponent, obstacles, and almost everything he had set out to do. Such achievements were made possible and justifiable as the narrative describes the super-human nature of the lead figure being two-thirds divine and one-third human. How Gilgamesh emerges as a conqueror comprises the first part of the story. It would seem that the author wants to establish the fact that all the hopes and aspirations of its people are embodied in Gilgamesh. The first part shows and proves that whatever man could aspire to achieve or be has been done by the superhuman Gilgamesh. The second part directs the story towards the king’s bid for immortality through his quest for the immortalized Uta-Napishtim. Structurally speaking, these two parts (which would almost appear as unrelated) divides the story. Both would seem to take the reader into two different directions, driving down two different points. The death of Enkidu serves as the turning point that separates the two parts. What serves for continuity for the narrative are the inherent traits of Gilgamesh’s character his fearlessness and obstinacy to be undaunted by obstacles. What is also a unique trait of the account of Gilgamesh is that the reading of the story is through a transcription of an oral story-telling, which the narrator in the story also revealed as a transcribed oral story of ancient times. Just as Gilgamesh was described as half-human and half-divine, so is the overall nature of the story. The narrator convinces its listeners and readers alike of the real existence of the king. However, its way of convincing is ironic since it proves the authenticity of its story through the existence of the very walls of the city of Uruk which we, present-day readers would find nowhere but in the walls of our imagination (â€Å"Assro-Babylonian Mythology: Gilgamesh†). The epic serves not only as a literary feat for early civilization; it also bears the identity of the early settlers of the Tigris-Euphrates area. However, its relevance supersedes its cultural identity. This ancient story connects its people with us and all of humanity as they ponder the same question which afflicts all men death, the destiny of every man. It also attempts to answer whether any mortal man could possibly escape it and also the mystery of what lies ahead after death. In finding the answer and conclusion to these questions lies the significance of the two parts of the story. As mentioned, the first part is given to prove the semi god-like abilities of Gilgamesh. If he then, who bears such qualities failed in his bid for immortality, as shown on the second part, how much more for ordinary mortals? The narrative convinces its hearers or readers of the inevitability of death and must resign oneself of this fact. The most that man can do is to be fearless in facing it, the way Gilgamesh triumphantly faced death together with Enkidu in the great Cedar Forest. However, its main conclusion is: that man is powerless to escape it. B. Genesis Genesis originated as part of a larger literary unit that was only later broken up into books. That larger unit is the religious history of ancient Israel, usually called the Pentateuch. In it were traced Israel’s origins from its chief formative experiences down to its settlement in the land of Palestine. Also incorporated into the narrative were law codes formulated at various times in Israelite history. The entire complex came to be ascribed to Israel’s founder and first lawgiver, Moses. This position has been modified as a result of modern Biblical scholarship. Genesis is a logical division of the original text of the Pentateuch. It represents a twofold introduction to the story of Israel’s formation as a â€Å"covenant people†Ã¢â‚¬â€God’s chosen people. The patriarchal history comprises cycles of stories relating to three major figures of the pre Israelite past, namely Abraham, Isaac and Jacob, together with supplementary traditions about other ancestors who were of secondary interest. After an introductory genealogy there appears first the story of Abraham and Isaac. Included is a fragmentary history, possibly of Moabite origin, of Lot, the ancestor of the Moabites and Ammonites, who were related to the Israelites. There is also the history of Ishmael, who is regarded as the ancestor of the Arab peoples. The second major cycle is that of Isaac and Jacob. This cycle also contains supplementary material, some of the Edomites origins, relating to Esau, ancestor of the Edomites. Finally, there is the extensive and distinctive story of Joseph, the major intrusions into which are a variant history of Judah in chapter 38 and the â€Å"blessings† of the Israelite tribes in Chapter 49. Chapter 1 tells of God’s act of creation. Chapters 2-11 record human history from Adam to Abraham and describe the Garden of Eden, the Tower of Babel, and the Flood. The connecting link between all these parts of Genesis as well as between it and the other books of the Pentateuch, which it introduces, is a concept of divine intervention in man’s history. This concept has been given the name Heitsgeschichte, â€Å"salvation history†. Israel believed itself to be the product of a history in which it had encountered a God who had made it His Covenant people. The great events of this history are traced—the Exodus from Egypt; the experiences of the Red Sea, of Sinai, and of Kadesh, where Israel waited outside the Promised Land; and the occupation of the Promised Land. All these reveal a God of mercy and kindness, though also of justice and retribution, a God who had chosen Israel out of simple, gratuitous love. This historical perspective was imposed in Genesis both on the patriarchal legends that had been derived from Palestine and on the mixed Mesopotamian- Palestinian myths and sagas from which the book’s first chapters are constructed. Thus in Genesis, Creation is seen no longer as mere myth, that is, as a religious conviction visualized in narrative. It is instead, the first in a series of God’s saving acts, by which he had brought forth an ordered universe out of primordial formlessness. Man was placed in that world as God’s image and likeness, to be its ruler. But men improved unequal to the task. His wilfulness set him in opposition to God and introduced disorder into the world. After this followed murder and the hatred of man for man, for example, Cain and Abel, Lamech and the Cainites, even cosmic disorder, which the story of the sons of God and the daughters of men attempts to, explain. The Flood is understood in Genesis as both divine retribution and mercy: it brought an end to an evil generation, but a faithful remnant was preserved in the person of the righteous Noah and those who were saved for his sake. III. Gilgamesh and the Flood in the Bible The epic makes mention of the Flood in reference with one of the oldest books of the Bible. Similarities of the two accounts were the flood, the gigantic boat, and the fact that animals and living creatures were made to come aboard along with the one human family who entered the boat. There are major disparities though as to the recounting of the event. In the account of the Bible, the coming of the Great Flood in Noah’s days was not held as a secret before men, whereas in the story of Gilgamesh, the gods have intended to have it kept as a secret. Noah was even commanded by God to preach and warn the people of its coming (as a sign of His mercy) while he builds the ark. The people however, did not listen and even taunted Noah. Such reactions may have been likely since many Bible scholars believe that prior to this incident, rain had not yet fallen on the earth. In the Bible account, the door of the ark was supernaturally closed and opened by God alone. Noah had no power or aut hority over it. In Gilgamesh’s, the sealing of the door bears no spiritual meaning. Noah’s God and the gods in Gilgamesh were shown to have deeply regretted the sending of the flood that has wiped out humanity expect for those inside the great boat. One of the gods in the epic was displeased at first with the survivors, while the God of Noah readily blessed them. IV. Conclusion The work unfolds before us the thoughts and intents of the Sumerians and the rest of the Mesopotamians. Like the rest of most societies, they give enormous significance to fame and wealth. Fearlessness is held as a great virtue, born out perhaps of their constant living in fear of antagonizing their gods who they believed caused them all their troubles. Although Mesopotamians have achieved much, they did hold a pessimistic view. Life, it seemed for them, was a constant struggle a struggle against the forces of nature and the caprices of their gods. Towards the end of the story, even the endeavors of men would come to nothing as he comes to the end of his life. â€Å"Eat, drink and be merry for tomorrow we shall die† would have been the guiding principle of Mesopotamians. Perhaps so, since one historian had noted that over forty percent of their grain production was used to make beer. Although we discuss this epic as an ancient story, the quest for the answers about life and death still continuous to haunt several people even to this present-day. Above all, however, Biblical critics of the 20th century are willing to measure Genesis by historical standards other than those of the 19th century. By those standards Genesis was condemned or defended in the time of the â€Å"Babel and Bible† controversy. That dispute developed when the Sumerian and Akkadian literatures of ancient Mesopotamia were discovered and deciphered in the 19th century. The conclusion was easily drawn that the message of Genesis was of no more relevance to the history of religions than the myths of Babylonia, whatever might be the other values of the book. But the 20th century idea of history is more attuned to that which inspired the authors of Genesis. This view recognizes that recording specific facts and dares is not the, real object of history writing. Rather, the aim is to discover and portray realities that challenge human experience and demand an accounting. By the criteria of historicism Moses can hardly said to have existed; yet Israel itsel f is the historical witness of Moses. Genesis and the Epic of Gilgamesh are two great books that could inspire people when they read it. The facts and information’s are somewhat intertwined in some ways. These two books should be treasured and cherished especially by those who want to know the history of our forefathers, their fall and how they were saved by a mighty Creator.

Oregon Wines Essay Example for Free

Oregon Wines Essay Although winemaking dates back to 1840’s, in Oregon, commercial production began in 1960’s (Hall). Having a relatively short history of 50 years, today, Oregon is the third largest wine producer state of United States. As of 2009, the state hosts to 453 wineries which are mostly small and family-owned (Wine Communications Group). History of the Oregon Wine Industry The first grape plantation in the region was made by horticulturist Henderson Luelling, in Willamette Valley by 1847. By the 1850’s Peter Britt started growing wine grapes in his Valley View Vineyard, today’s Applegate Valley. According to the census; in 1860, wine production was 11,800 litres (2,600 gallons) in Oregon (Hall). By the 1880’s, Edward and John von Pessls planted Zinfandel, Riesling, and an unkown variety of Sauvignon in southern Oregon. At the same times in the north, in Willamette Valley, Ernest Reuter has been growing Klevner wines which brought him a gold medal at St. Louis World’s Fair of 1904 (Hall). The wine industry in Oregon closed down in 1919 because of the Prohibition. It revived by the late 1930’s as a fruit wine-based producer region. At that time there were only two producers, Louis Herbold and Adolph Doener growing grapes. Oregon’s wine industry was also damaged by the success of California winemakers (Hall). The rebirth of Oregon wines dates back to 1961, when Richard Sommer founded Hill Crest Vineyard near Roseburg. Although the production was based on Riesling, he also planted some Gewurztraminer, Pinot Noir, Chardonnay, and Cabernet Sauvignon. In 1965, David Lett, the owner of Eyrie Vineyard, planted his first Pinot Noir near Convallis and after 1966, continued the production at Willamette Valley in the Dundee hills. This was the beginning of the era of Pinot Noir which Oregon is nowadays famous for (Hall). By the 1970’s many winemakers immigrated to Oregon from California. Some of them where David and Ginny Adelsheim, Dick Erath, Dick and Nancy Ponzi, Jerry and Ann Preston, Pat and Joe Campbell, Susan and Bill Sokol Blosser and Myron Redford. However, David Lett was the one who placed Oregon on the world’s wine map. In 1980, 1975 Eyrie Vineyard’s South Block Reserve Pinot Noir came second in the grand tasting of wines sponsored by the French Gault Millau guide and this called the attention of press to Oregon as a wine producer state (Hall). In 1990, Oregon was hosted to 70 wineries and 320 growers in 5,682 acres vineyard. In the early 1990s, Oregon wine industry got into the danger of Phylloxera infestation which was prevented quickly by the use of resistant rootstocks. Some beneficial laws for winemakers were enacted by the Oregon Legislature in 1995. For instance, direct in-state shipment from wineries to customers and in-store tasting were legalized (Chemeketa Community College). In 2000, the number of wineries had increased to 135 and 500 growers had been engaged in grapery in 10,500 acres vineyard. In the 2000’s producers have began giving importance to green wine production in Oregon (Chemeketa Community College). An Oregon non-profit organization, Low Input Viticulture and Enology, Inc. , has been certifying wineries for meeting certain environmental standards (Low Input Viticulture and Enology, Inc. ) In 2005, there were 314 wineries and 519 vineyards in Oregon (Chemeketa Community College). Grape Varietals Grown in Oregon Red Wine Varieties| White Grape Varieties| Baco Noir| Chardonnay| Barbera| Chenin Blanc| Black Muscat| Early Muscat| Cabarnet Franc| Gewurtztraminer| Cabarnet Sauvignon| Huxelrebe| Carmine| Melon| Dolcetto| Muller Thrugau| Gamay Noir| Muscat Canelli| Grenache| Pinot Blanc|. Leon Millot| Pinot Gris| Malbec| Riesling| Marechal Foch| Sauvignon Blanc| Merlot| Scheurebe| Petit Verdot| Semillon| Pinot Meunier| Viognier| Pinor Noir| | Sangiovese| | Syrah| | Zinfandel| | (Bernard’s Wine Gallery) Types of Wine Produced in Oregon In Oregon, wine production is mostly based on Pinot Noir and the state is one of the first Pinot-producing regions in the world. Apart from the list below indicating the wine varieties, the state also produces sparkling wine, late harvest wine, ice wine, and dessert wine (Hall). Red Wine Varieties| White Wine Varieties|. Produced in great amount| Cabarnet Sauvignon| Gewurtztraminer| Pinot Noir| Muller Thurgau| Syrah| Pinot Blanc| | Sauvignon Blanc| | Semillon| Produced in smaller amount| Baco Noir| Arneis| Cabarnet Franc| Chenin Blanc| Dolcetto| Viognier| Gamay Noir| | Grenache| | Marechal Foch| | Malbec| | Muscat| | Nebbiolo| | Petit Syrah| | Sangiovese| | Tempranillo| | Zinfandel| | Viticultural Area of Oregon Willamette Valley â€Å"Willamette Valley is the largest AVA of Oregon, running from the Columbia River in Portland south through Salem to the Calapooya Mountains outside Eugene†. The valley is 150 miles long and almost 60 miles wide (Oregon Wine Board). In the valley, summers are generally warm and arid and the winters are cool and rainy. It is ideal for cool climate grapes due to its temperate climate and coastal marine influences. During the growing season, the valley has more daylight hours than other areas of Oregon (Oregon Wine Board). â€Å"The Willamette Valley is an old volcanic and sedimentary seabed that has been overlaid with gravel, silt, rock and boulders brought by the Missoula Floods from Montana and Washington between thousands of years ago. Red Jory soil is the most common volcanic type in the region and provides excellent drainage for superior quality wine grapes. † (Oregon Wine Board) â€Å"The valley is surrounded by the Coast Range to the west, the Cascades to the east and a series of hill chains to the north† (Oregon Wine Board). The Willamette River runs through the middle of the valley. Most of the vineyards are concentrated on the west of this river, on the slopes of the Coast Range, or among the valleys and they are mostly located a few hundred feet above sea level (Oregon Wine Board). Columbia Valley Although the Columbia Valley AVA is an 11 million acre growing region, only a small section with 185 miles wide and 200 miles long lies in Oregon (Oregon Wine Board). The valley has a mostly continental high desert climate. The hot days and cool nights provide slow, even ripening and helps grapes keep their natural acidity. Annually, the area only receives 6 to 8 inches of rainfall which makes supplemental irrigation essential in the entire region (Oregon Wine Board). The area is covered with silt and sand which was deposited about 15,000 years ago. The deposited silt and sand came to the region 15,000 years ago because of a series of massive ice age floods and wind-blown loess sediment. Today the region is mostly covered by loess (fine grained calcerous silt) which is well drained and ideal for grapevines (Oregon Wine Board). The Columbia Valley mostly lies on the Columbia River Plateau. The valley is bordered by the mountain ranges on the west and north, by the Columbia River on the south and by the Snake River near Idaho on the east (Oregon Wine Board). Walla Walla Valley. As a sub-appellation of the Columbia Valley AVA, The Walla Walla Valley AVA is in the northeast of Oregon. Although most of the wineries of Walla Walla Valley are located in Washington, almost half of the vines are produced in the Oregon side (Oregon Wine Board). The region has long sunshine-filled days and cool evening temperatures. Annual rainfall is 12. 5 inches due to the Cascade Mountain Range. Therefore, irrigation is necessary for grape growing (Oregon Wine Board). The soils of the region consist of varying combinations of well-drained loam, cobbles, silt and loess (Oregon Wine Board). The valley is located at the foot of the Blue Mountains, with vineyard elevations varying from 650 to 1,500 feet. Cascade Mountain Range borders the western side of the valley (Oregon Wine Board). Umpqua Valley The Umpqua Valley AVA is surrounded by the Coast Range from the west, the Cascade Range from the east, the Willamette Valley AVA from the north and the Rogue Valley AVA from the south. The valley is 65 miles long and 25 miles wide. Umpqua River runs nearby the valley (Oregon Wine Board). There are three different climatic sub-zones in the valley. First one is the northern area around the town of Elkton which has a cool, marine-influenced climate suitable for cool-climate grape varieties. Annual rainfall is around 50 inches; therefore, the viticulturists only benefit from the rain to grow their vines. Second is the central area to the northwest of Roseburg which has an intermediate climate allowing both cool and warm varieties to grow. Last area is located on the south of Roseburg. It is suitable for warm-climate varieties, such as Tempranillo, Syrah and Merlot. This area is more arid which makes irrigation necessary (Oregon Wine Board). The Valley has diverse soils with more than 150 soil types. â€Å"The valley floor levels have mostly deep alluvial or heavy clay materials, while the hillsides and bench locations have mixed alluvial, silt or clay structures† (Oregon Wine Board). The Umpqua Valley is made up of a series of interconnecting small mountain ranges and valleys. The complex topography of the valley is a result of the collision of the Klamath Mountains, the Coast Range and the Cascades (Oregon Wine Board). Rogue Valley The Rogue Valley AVA is located in the border of California. It is 70 miles wide by 60 miles long. Rogue Valley has the highest elevations of Oregons winegrowing regions on the east. However, it is also the warmest and the driest, allowing the winemakers to grow warm-weather varieties such as Merlot, Cabernet Sauvignon and Sauvignon Blanc. Cool-weather varieties, including Pinot noir do well here due to the mountain and ocean influences (Oregon Wine Board). Rogue Valley has various soil types, ranging from sandy loam to hard clay (Oregon Wine Board). Vineyards are generally located 1,200 to 2,000 feet above the sea level and planted on hillsides. The Klamath Mountains, the Coastal Range and the Cascades converging in Rogue Valley lead to a diverse landscape. Besides, the namesake river and its tributaries, the Applegate, Illinois and Bear Creek Rivers run though the valley (Oregon Wine Board). Viticultural Practices in Oregon In Oregon, viticulturists mainly use vertical shoot position (VSP) training. However, combination of Scott Henry and Lyre is also used, with lesser amounts of GDC and hanging. Standard rootstocks used in Oregon are 101-14 and 3309, with a lot of 5C and SO4. Low to moderate vigor sites are being developed to keep the canopies small. Although some meter by meter plantings exist, majority of the vineyards are falling into the 84 to 95 range for quality. Creative viticultural practices are being used in Oregon, for example, â€Å"Joel Myer, a local vineyard consultant, uses a sensible linear feet of trellis formula to determine yields. He suggests that a pound of fruit per foot of trellis will give optimal fruit quality. At Bethel Heights Vineyard, Ted Casteel thins all Pinot Noir to one cluster per shoot. He is also experimenting with planting vines side by side, about a foot apart, and training to single guyot, to increase vine competition and slow vigor. He is also taking one of his most successful Pinot Noir fields on vertical shoot position (VSP) training and converting it to Scott Henry, just to see if opening the canopy will help enhance the ripening process and flavor development (Chien). † â€Å"Oregon has been committed to sustainable winegrowing and earth-friendly practices. Numerous vineyards of the state are certified sustainable, organic, or biodynamic† (Voorhees). Two main organizations that certify Oregon’s vineyards and wineries as sustainable are LIVE and OCSW. Low Input Viticulture Enology (LIVE). LIVE is an organization that provides education and independent third-party certification approving that the vineyards and wineries use international standards of sustainable viticulture and enology practices. They have been certifying vineyards and wineries in Oregon since 1999, in Washington since 2006 and nowadays in all of the Pacific Northwest. LIVE cooperates with Salmon-Safe in order to point out the watershed impacts and administers the Carbon Reduction Challenge, an organization helping wineries achieve energy efficiencies (Voorhees). Oregon Certified Sustainable Wine (OCSW). Founded in 2008, OCSW highlights the commitment of Oregon wineries to the responsible grape growing and winemaking. The organization certifies wine growers who meet both agricultural and winemaking requirements on sustainability and provides them a certification logo to be easily recognized by customers. To meet the agricultural requirements, 97% of the grape must be certified by LIVE, USDA Organic, Demeter Biodynamic, or Food Alliance and Salmon-Safe. On the other hand, to meet the winemaking requirements, the winery must be certified by LIVE, USDA Organic, Demeter Biodynamic, or Food Alliance (Voorhees). Producers within Oregon Valley View Winery Valley View Winery, owned by Wisnovsky family, is located in the Applegate Valley AVA, Southern Oregon. Valley View was founded in 1972 and it is one of the oldest wineries in Oregon. Valley View is famous for its pioneering efforts in producing Bordeaux varieties and blends. They mainly use grapes from the Applegate and Bear Creek Valleys of Southern Oregon’s Rogue Valley and produce Merlot, Cabernet Sauvignon, Cabernet Franc, Tempranillo, Viognier, Sauvignon blanc, Rousanne, Chardonnay and Syrah (Valley View Winery). The Eyrie Vineyards. The Eyrie Vineyards was founded by David Lett in 1966. It is composed of 49 acres in several different vineyards in Dundee Hills, Oregon which is a sub-American Viticultural Area (AVA) of Willamette Valley AVA. David Lett produced the first Pinot gris in the United States and first Pinot Noir in the Willamette Valley. The Eyrie Vineyards divide their production into three as Estate Reserve wines, Estate wines, and Limited Bottlings. All grapes for their Estate Reserve wines; Pinot noir and Chardonnay, come from Eyrie’s original planting. This is the oldest plating in the Willamette Valley at 40 years. The grapes for Eyrie’s Estate wines come mostly from their three other vineyards; Stonehedge, Sisters, and Rolling Green Farm which were planted in the 1980’s. They grow Pinot Noir, Pinot Gris and Chardonnay. Finally, their small production, limited bottling wines include Muscat Ottonel, Pinot Blanc and Pinot Meunier (The Eyrie Vineyards). Abacela Vineyard and Winery In 1992, Earl and Hilda Jones bought a 19th century homestead in southern part of the Umpqua Valley to produce Tempranillo wines which they fell in love to in Spain. In 1994 they built the winery and began planting the Tempranillos they purchased from California. They chose the Umpqua Valley because of its similar climate to the one of Spain’s Rioja and Ribera del Duero regions where Tempranillo grapes are grown. Today, in addition to the eight different Tempranillo clones at Abacela, they grow grapes and produce wine from Spains white variety, Albarino, as well as other Iberian varieties including Graciano, Tinta roriz and Bastardo (used in the production of port-style wines) and French varieties such as Syrah, Grenache, Cabernet sauvignon, Merlot, Malbec, Petit verdot and Viognier (Wines Northwest). Bibliography Abacela Vine Wine Center in Oregons Umpqua Valley Wine Region. Wines Northwest. N. p. , n. d. Web. 29 Oct. 2012. http://www. winesnw. com/abacela. htm. About The Eyrie Vineyards. The Eyrie Vineyards. N. p. , n. d. Web. 29 Oct. 2012. http://www. eyrievineyards. com/journal/? page_id=4. Chien, Mark L. The Oregon Wine Community and Its Viticulture. Pennsylvannia Wine Grape Network. Penn State Cooperative Extension, n. d. Web. 30 Oct. 2012. http://www. pawinegrape. com/uploads/PDF%20files/Documents/Travelogues/Other%20Locals/The%20Oregon%20Wine%20Industry%20and%20its%20Viticulture. pdf. Hall, Lisa Shara. History of the Oregon Wine Industry. History of the Oregon Wine Industry. Ed. Mitchell Beazley. N. p. , n. d. Web. 30 Oct. 2012. http://avalonwine. com/Oregon-Wine-history. php. History of Oregon Wine. Wikipedia. Wikimedia Foundation, 22 May 2012. Web. 28 Oct. 2012. http://en. wikipedia. org/wiki/History_of_Oregon_wine. Low Input Viticulture and Enology, Inc. N. p. , n. d. Web. 28 Oct. 2012. http://www. liveinc. org/. Northwest Viticultural Center: Oregon Wine Historical Milestones. Discover Chemeketa Community College. Chemeketa.

Parliamentary Sovereignty in the UK in the Wake of Brexit

Parliamentary Sovereignty in the UK in the Wake of Brexit POn 23 June 2016, the UK government held a referendum to decide whether the country should leave the EU. The majority citizens voted for Brexit (51.89 per cent to 48.11 per cent) with a turnout of 72%, however, they thoroughly fell behind in Scottish and Northern Irish tallies. Be that as it may, the Government was still expected to trigger Article 50 of the Treaty on European Union (TEU) as soon as possible, without the express permission from Parliament. The Prime Minister at the time, David Cameron, had promised that he would follow through with the outcome, even if that meant leaving the EU (BBC, 2017).[1] However, the situation was not as straightforward as presented by the â€Å"Leave† campaign. The principle of parliamentary sovereignty meant that the referendum result had no legal binding. Therefore, the Prime Minister and government were free to ignore the referendum result if they saw fit. Furthermore, some argued that the government had no right to trigger a leave; only Parliament could do so, as a result of the principle parliamentary sovereignty (Weale, 2017).[2] This paper discusses the topic of parliamentary sovereignty in the UK, particularly in the wake of Brexit, and briefly touches on some social consequences had Parliamentary Sovereignty not been respected. The structure of this paper is therefore as follows: First, Section 1 briefly discusses the history behind parliamentary sovereignty in the UK. Then, Section 2 discusses the Miller Case, a case where the High Court upheld parliamentary sovereignty in the wake of Brexit. Finally, Section 3 explores the European Union (Notification of Withdrawal) Act 2017, an Act of Parliament that grants the government power to leave the EU. 1. The Principle of Parliamentary Sovereignty The idea of parliamentary sovereignty was conceived circa the Case of Proclamations in 1608 (Barnett, 2017).[3] This was a court decision that reduced the power of Monarchs. Essentially, the courts decided that moving forward, Kings and Queens would have to obtain Parliament’s permission to change laws. Specifically, the Case of Proclamations stated that â€Å"the King cannot change any part of the common law [†¦.] without parliament† (House of Lords, 1610).[4] Following this, the English Civil War occurred 1642–1651, where Parliamentarians fought against Royalists for ideals such as parliamentary sovereignty. The Parliamentarians were victorious on such occasion and thus began the ‘Glorious Revolution’ in 1688, which established parliamentary sovereignty in England (Goldsworthy, 2010).[5] Then, in 1689, parliamentary sovereignty was enshrined in the Bill of Rights. Similarly to the Case of Proclamations, this bill requires Monarchs to obtain pe rmission from Parliament before changing laws. Specifically, the Bill of Rights said, â€Å"Suspending the laws or the execution of laws by regal authority without consent of Parliament is illegal† (Parliament of England, 1689).[6] In modern day Britain, Parliament consists of three main decision making bodies: the Sovereign (the monarch, i.e. the King or Queen), the House of Lords (i.e. unelected members of parliament), and the House of Commons (i.e. elected Members of Parliament, or MPs). These three bodies form the highest power in the UK. The fact that Parliament has supreme power is known as parliamentary sovereignty. In the words of Legal commentator Albert Dicey, parliamentary sovereignty gives Parliament the power â€Å"to make or unmake any law whatever† (Dicey, 1915, p.3).[7] The only limits to parliamentary sovereignty are those that Parliament sets itself (Bradley, 2011).[8] An example of this self-enforced limit is Parliament’s subordination of the UK to the EU. This came into effect in 1972, when Parliament signed the European Communities Act, under which the UK was compelled to follow EU law (Barber, 2011).[9] Parliament also has the power to lift its self-imposed limits. For exampl e, Brexit means that Parliament will repeal the European Communities Act, thus ending the EU’s control over the UK (Supreme Court, 2017).[10] It is also important to note that only Parliament can repeal Parliamentary acts. Essentially, the government and Queen cannot repeal Acts of Parliament without Parliament’s permission. 23. Parliamentary sovereignty has been a significant part of many cases and has repeatedly been called upon during cases of importance. A quote from Lord Bingham of Cornhill in R (Jackson) v Attorney General [2005] UKHL 56; [2006] 1 AC 262 at para. [9] encapsulates this significance perfectly: The bedrock of the British constitution is the supremacy of the Crown in Parliament. 2. The Miller Case Following the Brexit referendum in June 2016, Times journalist David Pannick noted that the government could not trigger Article 50 by itself; the government would have to first obtain permission from Parliament (Pannick, 2016).[11] This was because of the principle of parliamentary sovereignty. Specifically, Pannick noted that Parliament had agreed to the European Communities Act in 1972, and because only Parliament can reverse its own decisions, and therefore only Parliament can repeal the act and withdraw from the EU. He also drew attention to Article 50 of the Treaty on European Union, which says, â€Å"any member state may decide to withdraw from the union in accordance with its own constitutional requirements† (EU, 2007).[12] Pannick argued that since parliamentary sovereignty is a constitutional requirement, the EU would not accept the UK’s withdrawal without parliamentary approval (Pannick, 2016).[13] Theresa May was dismissive of these claims. She asserted that they were a tactic to delay Brexit and subvert democracy (BBC, 2017).[14] She also stated that the government did not need parliamentary approval to trigger Article 50 (Freehills, 2016).[15] Notably, Theresa May stated, â€Å"It is up to the Government to trigger Article 50 and the Government alone† (BBC, 2017).[16] Many disagreed with Theresa May, as they believed that withdrawal from the EU without Parliament’s permission would be unlawful (Weale, 2017).[17] Several members of the public felt so strongly about this that took legal action against the government. Miller v Secretary of State for Exiting the European Union, or the Miller case as it was known informally, was heard in the High Court of Justice. Miller argued that Parliamentary involvement was necessary because: â€Å"By enacting the 1972 Act, Parliament surrendered aspects of its legislative sovereignty and conferred the same upon (what are now) the EU Institutions. Such conferral cannot be undone [†¦] without Parliamentary consent.† (Supreme Court, 2016, p.21)[18] In plain English, Miller’s argument was that considering Parliament surrendered power to the EU in 1972, only Parliament could take this power back (Supreme Court, 2016).[19] The government disagreed with this claim. They believed that once the UK leaves the EU, the European Communities Act 1972 would simply cease to apply, because former treaties would not exist (Supreme Court, 2016; Weale, 2017).[20] Furthermore, the government argued that they had the royal prerogative to override parliamentary sovereignty. The royal prerogative is an old power that allows governments to make decisions without Parliament, in exceptional circumstances (Freehills, 2016).[21] The government also noted a rule that â€Å"the making and unmaking of treaties is [†¦] within the competence of the government† (Supreme Court, 2017, p.84)[22] The case was debated in the High Court for several weeks until the High Court delivered its verdict on 3 November 2016. The High Court ruled in favour of Miller: the government had to obtain parliamentary authority to trigger Article 50. The High Court had agreed with Miller’s arguments about the principle of parliamentary sovereignty (Supreme Court, 2017).[23] The court explained that because of parliamentary sovereignty, only Parliament could repeal the European Communities Act. This is because only Parliament can repeal an Act of Parliament. The High Court also explained that Article 50 would nullify several rights of UK citizens (Supreme Court, 2017).[24] These rights included the right of UK citizens to live and work freely in other EU countries, and the right to 20 days paid holiday under the Working Time Directive 2003. Parliament put these rights in place when it passed the European Communities Act in 1972. The High Court also ruled against the government’s right to use the royal prerogative (Supreme Court, 2017).[25] To explain why, the High Court cited the case of Burmah Oil Co (Burma Trading) Ltd v Lord Advocate [1965] AC 75, 101. This case involved use of the royal prerogative. Lord Reid, dismissed the royal prerogative as a â€Å"relic of a past age† (House of Lords, 1965, p.101).[26] Lord Reid also explained that the royal prerogative is â€Å"only available for a case not covered by statute† (p.101).[27] Typically, the royal prerogative is only for situations such as declaring war, dissolving parliament and governing colonies (Wade, 1961).[28] So, in Miller’s case, the High Court explained that a royal prerogative was inappropriate for triggering Brexit. Therefore, the government did not have the power to trigger Article 50 without Parliament’s approval. The government was unhappy with the High Court’s decision and chose to appeal it, and as a result the case went to the Supreme Court. Ultimately, the Supreme Court dismissed the government’s appeal, citing the same reason as the High Court (Supreme Court, 2017).[29] Essentially, the court explained, the government in 1972 needed Parliament’s approval to sign the 1972 Accession Treaty. This meant that present-day government also needed Parliament’s approval to repeal this treaty (Supreme Court, 2017).[30] Of course, those in the â€Å"Leave† camp were outraged with the High Court’s decision. Like Theresa May, they believed that Parliament was attempting to obstruct the progression of Brexit. A Ukip donor accused the High Court of declaring war on British democracy (Maguire, 2016).[31] In reality, however, this was not the case; the High Court was merely upholding the British constitution as intended, by honouring the principle of parliamentary sovereignty (Weale, 2017)[32] and following the Rule of Law. Importance of the Rule of Law. On 29 March 2017, the Prime Minister wrote to the President of the European Council to notify the European Council of the United Kingdom’s intention to leave the European Unit and the triggering of Article 50 of the Treaty. Brexit is no longer a hypothetical question. It is a concrete fact – it is happening. An issue that has been brought to the front is the belief that the Government has the power, and right, to act on Brexit without Parliaments involvement. This is even more troubling as the very constitution is built upon Parliamentary sovereignty. The issue of human rights comes up as it can be dangerous, in a country where the legislature is mostly under the control of the executive, to leave it solely up to a sovereign Parliament with an absent constitution. If the Parliament can be avoided altogether, this can lead to an even worse situation overall and so highlights how important it was for the Supreme Court in Miller to stand up for and defend the power of Parliament over the executive.   Brexit is one of the most influential and far-reaching changes to the international social and political landscapes today. Brexit will shape Britain, and the international community, for years to come. It is for this reason that it is undeniable that this process should be founded in the rule of law. To comprehend the importance of the rule of law we must give it a clear definition. A well-known definition is that of Lord Bingham: â€Å"that all persons and authorities in the State, whether public or private, should be bound by and be entitled to the benefit of all laws publicly made, taking effect (generally) in the future and publicly administered in the courts.† The Venice Commission has identified the following 8 components of the rule of law: ‘(1) Accessibility of the law (that it be intelligible, clear and predictable); (2) Questions of legal right should be normally decided by law and not discretion; (3) Equality before the law; (4) Power must be exercised lawfully, fairly and reasonably; (5) Human rights must be protected; (6) Means must be provided to resolve disputes without undue cost or delay; (7) Trials must be fair, and (8) Compliance by the state with its obligations in international law as well as in national law.’ The importance of the rule of law is recognised in multiple international documents. For example, the preamble to the UN Declaration of Human Rights notes the importance of the rule of law in protecting human rights. The Treaty on European Union also couples ‘the rule of law and respect for human rights’. It is this human rights element that the remained of this short essay will focus on. Brexit will reform the social landscape of Britain and Europe. It is of paramount importance that the rule of law is respected in this reformation to ensure that fundamental rights, particularly those of minorities and vulnerable individuals, continue to be respected. This is especially true given that there has been much debate as to whether the Brexit vote was fuelled by xenophobia and racism. Research has shown that there was an increase in support for far-right groups during the Brexit campaign and following the murder of Jo Cox. There has also been an alleged escalation in hate crime targeting migrant communities as well an increase in anti-immigration rhetoric. The Brexit vote, coupled with Trump, and the rise of the far-right, summons fears surrounding the polarization of politics and the creeping rise of extremism. With this in mind, it is quite chilling to consider Lord Bingham’s thoughts on a system which is not founded on the rule of law: â€Å"The hallmark of a regime which flouts the rule of law are, alas, all too familiar: the midnight knock on the door, the sudden disappearance, the show trial, the subjection of prisoners to genetic experiments, the confession extracted by torture, the gulag and the concentration camp, the gas chamber, the practice of genocide and ethnic cleansing, the waging of aggressive wars.† In a time when international politics is becoming increasingly unclear and strained and communities are fraught with increased fear and racial tensions, now more than ever, the rule of law and the importance of Parliamentary Sovereignty must be respected. As noted by the Prime Minister, the task before the British nation is momentous but it should not be insurmountable. Britain post-Brexit has an unclear future and an undefined path. By adhering to the rule of law, the certainty, stability and protection that it provides will ensure that this difficult task is negotiated with the utmost respect for all peoples and their inalienable human rights. 3. The European Union (Notification of Withdrawal) Act 2017 Given that the Supreme Court had dismissed the government’s appeal, the government now needed Parliament’s approval to trigger Article 50. In order to receive this approval, the government introduced a new bill in Parliament. This bill was called the European Union (Notification of Withdrawal) Act 2017.Essentially, this bill would give Theresa May the power to trigger Article 50. However, Parliament had the power to reject the bill if it felt appropriate. This was again because of parliamentary sovereignty (Weale, 2017).[33] Despite that most voters voted ‘Leave’ in the referendum, this result was not legally binding and Parliament could ignore the referendum result. The principle of parliamentary sovereignty means that the ultimate power rests with Parliament, not the public nor the results of referendums. The public only have the power to elect MPs, and once elected, MPs can go against the wishes of their constituents and make their own decisions if they want to. MPs can even go against a referendum result, despite that this might cause great anger with the British public. As Dicey stated, â€Å"the electors can in the long run always enforce their will† (Dicey, 1915).[34] However,   all three decision making bodies of Parliament – the Queen, the House of Lords and the House of Commons – approved the Notification of Withdrawal Act (BBC, 2017).[35] The Queen gave the final green flag on 16 March 2017. This gave the Prime Minister the power trigger to Article 50 and inform the EU of the UK’s withdrawal. The government officially triggered Article 50 on 29 March 2017, when a UK envoy delivered a letter of withdrawal to the President of the European Council (BBC, 2017).[36] The issue of parliamentary sovereignty then took a back seat as the UK began exit negotiations with the EU. Of the 170,000 statutory instruments that have been sent to Parliament in the last 65 years, only seventeen have been rejected, and any substantive debate over individual instruments is a rare occurrence. Responsibility has been delegated for regulation both to the government and the European Union. For this reason, possibly up to sixty per cent of UK law may be derived from EU law in some way. Furthermore, for many years, legislative and technical expertise in the pertinent areas have again been delegated to Brussels. This leaves domestic civil servants under prepared to handle the of important decisions that will need to be made in the coming years. David Allen Green’s analysis is difficult to refute: â€Å"under the cloak of the referendum result there will be a power grab by Whitehall from Westminster. Those rejoicing at â€Å"taking back control† should be careful what they wish for. The executive is, as usual, wanting to take control away from Parliament.† On many occasions, it has been asserted that because the ‘people have spoken’ through the referendum, it gives the executive the right to push onward without the consent of Parliament. On many occasions, it has been asserted that because the ‘people have spoken’ through the referendum, it gives the executive the right to push onward without the consent of Parliament. Does this mean that the claims of direct democracy, in the form of the referendum, trump the claims of Parliamentary representative democracy, with the paradoxical effect of giving more power to the executive? The greater part have affirmed that referenda are in and of themselves a product of Parliamentary authority and must accordingly rely on the statute which enables them. The 2015 EU referendum Act only called for the referendum to take place, without establishing how to approach it or the potential consequences. ‘Where, as in this case, implementation of a referendum result requires a change in the law of the land, and statute has not provided for that change, the change in the law must be made in the only way in which the UK constitution permits, namely through Parliamentary legislation.’ The actual political importance of a referendum is not subverted however. What is does assert is the basic dogma that, in a democracy, the people can speak through their representatives in Parliament. Nevertheless, direct democracy cannot be operationalised by giving undiluted power to the executive. 4. Conclusion This paper has discussed parliamentary sovereignty in the UK in the wake of Brexit. First, Section 1 introduced the concept of parliamentary sovereignty in the UK. This section explained that parliamentary sovereignty goes back to the 17th century, when the courts first enshrined the principle in the Bill of Rights. The section also drew attention to the rule that only Parliament can undo Acts of Parliament. I then discussed the Miller case in Section 2. In this case, members of the public argued that the government required Parliaments approval to leave the EU. The courts decided in favour of Millers side; that explained that Parliament was needed to trigger to Article 50 due to parliamentary sovereignty. The decision was controversial because some people saw it as an attempt to subvert the referendum result. Finally, Section 3 discussed the European Union Act 2017. This act that demonstrated the principle of parliamentary sovereignty. The government essentially asked Parliament for permission to trigger Article 50, and Parliament agreed by passing the act. In conclusion, the principle of parliamentary sovereignty was tested in the wake of Brexit. Ultimately however, courts respected the principle and gave Parliament the ultimate power over whether Britain should leave the EU. However, the future is still uncertain, as no-one yet knows what Brexit will look like. Perhaps a future Parliament will reverse the Brexit decision. After all, parliamentary sovereignty gives future Parliaments the right to reverse the decisions of previous Parliaments. What needs to be addressed is the potential consequneces that the referendum may have on Palimentary sovernety and represesentitive democracy throughout the UK. For this reason, Parliment needs to continue to be a central part of the process despite any predetermined preferences from the Government itself. Parliamentary sovereignty must remain intact as, for the many reasons stated, it is an integral part of the United Kingdom’s constitution, because its deliberate and representative functions and ability to hold the executive to account are defining features of the United Kingdom’s enduring constitution. 5. References Barber, N.W., 2011. The afterlife of Parliamentary sovereignty. International Journal of Constitutional Law, 9(1), pp.144–154. Barnett, H., 2017. Constitutional and administrative law, Taylor & Francis. BBC, 2017. BBC News website. Available at: http://www.bbc.com/news [Accessed July 14, 2017]. Bradley, A., 2011. The Sovereignty of Parliament–Form or Substance? The Changing Constitution, 23, pp.54–56. Dicey, A.V., 1915. Introduction to the Study of the Law of the Constitution 8th ed., Liberty Classics. EU, 2007. Treaty on European Union, Freehills, H.S., 2016. Judicial review litigation over the correct constitutional process for triggering Article 50 TEU. Lexology. Available at: http://www.lexology.com/library/detail.aspx?g=f43e102f-ea09-4449-b781-a35ecfe628fe [Accessed July 13, 2017]. Goldsworthy, J., 2010. Parliamentary sovereignty: contemporary debates, Cambridge University Press. House of Lords, 1965. Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75, House of Lords, 1610. Proclamations, Case of [1610] EWHC KB J22, Available at: http://www.bailii.org/ew/cases/EWHC/KB/1610/J22.html. Maguire, P., 2016. Seizing our sovereignty or declaring war on democracy: split view on judges’ ruling. The Guardian. Available at: https://www.theguardian.com/politics/2016/nov/06/brexit-this-is-what-sovereignty-looks-like#img-1 [Accessed July 13, 2017]. Pannick, D., 2016. Why giving notice of withdrawal from the EU requires act of parliament. The Times. Available at: https://www.thetimes.co.uk/article/c8985886-3df9-11e6-a28b-4ed6c4bdada3. Parliament of England, 1689. English Bill of Rights, Supreme Court, 2016. Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†), Available at: http://www.croftsolicitors.com/wp-content/uploads/2016/11/139459-UKSC-2016-0196-Skeleton-for-Expat-Interveners-final-written-case-2.pdf. Supreme Court, 2017. Miller v Secretary of State for Exiting the European Union, London. Available at: https://www.supremecourt.uk/cases/docs/uksc-2016-0196-judgment.pdf. Wade, W., 1961. Administrative Law, London: Oxford University Press. Weale, A., 2017. The Democratic Duty to Oppose Brexit. The Political Quarterly, 88(2), pp.170–181. [1] BBC [2] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 177 [3] Hilaire Barnett, Constitutional and administrative law (Taylor & Francis 2017) [4] House of Lords, Case of [1610] EWHC KB J22 [5] Jeffrey Goldsworthy, Parliamentary sovereignty: contemporary debates (Cambridge University Press 2010) [6] Parliament of England, English Bill of Rights [7] Albert Dicey, Introduction to the Study of the Law of the Constitution (8th edn, Liberty Classics 1915) [8] Anthony Bradley, ‘The Sovereignty of Parliament–Form or Substance?’ (2011) The Changing Constitution 54 [9] Nicholas Barber, ‘The afterlife of Parliamentary sovereignty’ (2011) International Journal of Constitutional Law 149 [10] Supreme Court, Miller v Secretary of State for Exiting the European Union [11] David Pannick, Why giving notice of withdrawal from the EU requires act of parliament [12] EU, Treaty on European Union [13] David Pannick, Why giving notice of withdrawal from the EU requires act of parliament [14] BBC [15] Herbert Smith Freehills, Judicial review litigation over the correct constitutional process for triggering Article 50 TEU [16] BBC [17] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 180 [18] Supreme Court, Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†) 21 [19] Supreme Court, Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†) [20] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 180 [21] Herbert Smith Freehills, Judicial review litigation over the correct constitutional process for triggering Article 50 TEU [22] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [23] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [24] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [25] Supreme Court, Miller v Secretary of State for Exiting the European Union 85 [26] House of Lords, Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75 101 [27] House of Lords, Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75 101 [28] William Wade, Administrative Law (Oxford University Press 1961) [29] Supreme Court, Miller v Secretary of State for Exiting the European Union [30] Supreme Court, Miller v Secretary of State for Exiting the European Union [31] Patrick Maguire, Seizing our sovereignty or declaring war on democracy: split view on judges’ ruling [32] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 174 [33] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 174 [34] Albert Dicey, Introduction to the Study of the Law of the Constitution (8th edn, Liberty Classics 1915) [35] BBC [36] BBC Parliamentary Sovereignty in the UK in the Wake of Brexit Parliamentary Sovereignty in the UK in the Wake of Brexit POn 23 June 2016, the UK government held a referendum to decide whether the country should leave the EU. The majority citizens voted for Brexit (51.89 per cent to 48.11 per cent) with a turnout of 72%, however, they thoroughly fell behind in Scottish and Northern Irish tallies. Be that as it may, the Government was still expected to trigger Article 50 of the Treaty on European Union (TEU) as soon as possible, without the express permission from Parliament. The Prime Minister at the time, David Cameron, had promised that he would follow through with the outcome, even if that meant leaving the EU (BBC, 2017).[1] However, the situation was not as straightforward as presented by the â€Å"Leave† campaign. The principle of parliamentary sovereignty meant that the referendum result had no legal binding. Therefore, the Prime Minister and government were free to ignore the referendum result if they saw fit. Furthermore, some argued that the government had no right to trigger a leave; only Parliament could do so, as a result of the principle parliamentary sovereignty (Weale, 2017).[2] This paper discusses the topic of parliamentary sovereignty in the UK, particularly in the wake of Brexit, and briefly touches on some social consequences had Parliamentary Sovereignty not been respected. The structure of this paper is therefore as follows: First, Section 1 briefly discusses the history behind parliamentary sovereignty in the UK. Then, Section 2 discusses the Miller Case, a case where the High Court upheld parliamentary sovereignty in the wake of Brexit. Finally, Section 3 explores the European Union (Notification of Withdrawal) Act 2017, an Act of Parliament that grants the government power to leave the EU. 1. The Principle of Parliamentary Sovereignty The idea of parliamentary sovereignty was conceived circa the Case of Proclamations in 1608 (Barnett, 2017).[3] This was a court decision that reduced the power of Monarchs. Essentially, the courts decided that moving forward, Kings and Queens would have to obtain Parliament’s permission to change laws. Specifically, the Case of Proclamations stated that â€Å"the King cannot change any part of the common law [†¦.] without parliament† (House of Lords, 1610).[4] Following this, the English Civil War occurred 1642–1651, where Parliamentarians fought against Royalists for ideals such as parliamentary sovereignty. The Parliamentarians were victorious on such occasion and thus began the ‘Glorious Revolution’ in 1688, which established parliamentary sovereignty in England (Goldsworthy, 2010).[5] Then, in 1689, parliamentary sovereignty was enshrined in the Bill of Rights. Similarly to the Case of Proclamations, this bill requires Monarchs to obtain pe rmission from Parliament before changing laws. Specifically, the Bill of Rights said, â€Å"Suspending the laws or the execution of laws by regal authority without consent of Parliament is illegal† (Parliament of England, 1689).[6] In modern day Britain, Parliament consists of three main decision making bodies: the Sovereign (the monarch, i.e. the King or Queen), the House of Lords (i.e. unelected members of parliament), and the House of Commons (i.e. elected Members of Parliament, or MPs). These three bodies form the highest power in the UK. The fact that Parliament has supreme power is known as parliamentary sovereignty. In the words of Legal commentator Albert Dicey, parliamentary sovereignty gives Parliament the power â€Å"to make or unmake any law whatever† (Dicey, 1915, p.3).[7] The only limits to parliamentary sovereignty are those that Parliament sets itself (Bradley, 2011).[8] An example of this self-enforced limit is Parliament’s subordination of the UK to the EU. This came into effect in 1972, when Parliament signed the European Communities Act, under which the UK was compelled to follow EU law (Barber, 2011).[9] Parliament also has the power to lift its self-imposed limits. For exampl e, Brexit means that Parliament will repeal the European Communities Act, thus ending the EU’s control over the UK (Supreme Court, 2017).[10] It is also important to note that only Parliament can repeal Parliamentary acts. Essentially, the government and Queen cannot repeal Acts of Parliament without Parliament’s permission. 23. Parliamentary sovereignty has been a significant part of many cases and has repeatedly been called upon during cases of importance. A quote from Lord Bingham of Cornhill in R (Jackson) v Attorney General [2005] UKHL 56; [2006] 1 AC 262 at para. [9] encapsulates this significance perfectly: The bedrock of the British constitution is the supremacy of the Crown in Parliament. 2. The Miller Case Following the Brexit referendum in June 2016, Times journalist David Pannick noted that the government could not trigger Article 50 by itself; the government would have to first obtain permission from Parliament (Pannick, 2016).[11] This was because of the principle of parliamentary sovereignty. Specifically, Pannick noted that Parliament had agreed to the European Communities Act in 1972, and because only Parliament can reverse its own decisions, and therefore only Parliament can repeal the act and withdraw from the EU. He also drew attention to Article 50 of the Treaty on European Union, which says, â€Å"any member state may decide to withdraw from the union in accordance with its own constitutional requirements† (EU, 2007).[12] Pannick argued that since parliamentary sovereignty is a constitutional requirement, the EU would not accept the UK’s withdrawal without parliamentary approval (Pannick, 2016).[13] Theresa May was dismissive of these claims. She asserted that they were a tactic to delay Brexit and subvert democracy (BBC, 2017).[14] She also stated that the government did not need parliamentary approval to trigger Article 50 (Freehills, 2016).[15] Notably, Theresa May stated, â€Å"It is up to the Government to trigger Article 50 and the Government alone† (BBC, 2017).[16] Many disagreed with Theresa May, as they believed that withdrawal from the EU without Parliament’s permission would be unlawful (Weale, 2017).[17] Several members of the public felt so strongly about this that took legal action against the government. Miller v Secretary of State for Exiting the European Union, or the Miller case as it was known informally, was heard in the High Court of Justice. Miller argued that Parliamentary involvement was necessary because: â€Å"By enacting the 1972 Act, Parliament surrendered aspects of its legislative sovereignty and conferred the same upon (what are now) the EU Institutions. Such conferral cannot be undone [†¦] without Parliamentary consent.† (Supreme Court, 2016, p.21)[18] In plain English, Miller’s argument was that considering Parliament surrendered power to the EU in 1972, only Parliament could take this power back (Supreme Court, 2016).[19] The government disagreed with this claim. They believed that once the UK leaves the EU, the European Communities Act 1972 would simply cease to apply, because former treaties would not exist (Supreme Court, 2016; Weale, 2017).[20] Furthermore, the government argued that they had the royal prerogative to override parliamentary sovereignty. The royal prerogative is an old power that allows governments to make decisions without Parliament, in exceptional circumstances (Freehills, 2016).[21] The government also noted a rule that â€Å"the making and unmaking of treaties is [†¦] within the competence of the government† (Supreme Court, 2017, p.84)[22] The case was debated in the High Court for several weeks until the High Court delivered its verdict on 3 November 2016. The High Court ruled in favour of Miller: the government had to obtain parliamentary authority to trigger Article 50. The High Court had agreed with Miller’s arguments about the principle of parliamentary sovereignty (Supreme Court, 2017).[23] The court explained that because of parliamentary sovereignty, only Parliament could repeal the European Communities Act. This is because only Parliament can repeal an Act of Parliament. The High Court also explained that Article 50 would nullify several rights of UK citizens (Supreme Court, 2017).[24] These rights included the right of UK citizens to live and work freely in other EU countries, and the right to 20 days paid holiday under the Working Time Directive 2003. Parliament put these rights in place when it passed the European Communities Act in 1972. The High Court also ruled against the government’s right to use the royal prerogative (Supreme Court, 2017).[25] To explain why, the High Court cited the case of Burmah Oil Co (Burma Trading) Ltd v Lord Advocate [1965] AC 75, 101. This case involved use of the royal prerogative. Lord Reid, dismissed the royal prerogative as a â€Å"relic of a past age† (House of Lords, 1965, p.101).[26] Lord Reid also explained that the royal prerogative is â€Å"only available for a case not covered by statute† (p.101).[27] Typically, the royal prerogative is only for situations such as declaring war, dissolving parliament and governing colonies (Wade, 1961).[28] So, in Miller’s case, the High Court explained that a royal prerogative was inappropriate for triggering Brexit. Therefore, the government did not have the power to trigger Article 50 without Parliament’s approval. The government was unhappy with the High Court’s decision and chose to appeal it, and as a result the case went to the Supreme Court. Ultimately, the Supreme Court dismissed the government’s appeal, citing the same reason as the High Court (Supreme Court, 2017).[29] Essentially, the court explained, the government in 1972 needed Parliament’s approval to sign the 1972 Accession Treaty. This meant that present-day government also needed Parliament’s approval to repeal this treaty (Supreme Court, 2017).[30] Of course, those in the â€Å"Leave† camp were outraged with the High Court’s decision. Like Theresa May, they believed that Parliament was attempting to obstruct the progression of Brexit. A Ukip donor accused the High Court of declaring war on British democracy (Maguire, 2016).[31] In reality, however, this was not the case; the High Court was merely upholding the British constitution as intended, by honouring the principle of parliamentary sovereignty (Weale, 2017)[32] and following the Rule of Law. Importance of the Rule of Law. On 29 March 2017, the Prime Minister wrote to the President of the European Council to notify the European Council of the United Kingdom’s intention to leave the European Unit and the triggering of Article 50 of the Treaty. Brexit is no longer a hypothetical question. It is a concrete fact – it is happening. An issue that has been brought to the front is the belief that the Government has the power, and right, to act on Brexit without Parliaments involvement. This is even more troubling as the very constitution is built upon Parliamentary sovereignty. The issue of human rights comes up as it can be dangerous, in a country where the legislature is mostly under the control of the executive, to leave it solely up to a sovereign Parliament with an absent constitution. If the Parliament can be avoided altogether, this can lead to an even worse situation overall and so highlights how important it was for the Supreme Court in Miller to stand up for and defend the power of Parliament over the executive.   Brexit is one of the most influential and far-reaching changes to the international social and political landscapes today. Brexit will shape Britain, and the international community, for years to come. It is for this reason that it is undeniable that this process should be founded in the rule of law. To comprehend the importance of the rule of law we must give it a clear definition. A well-known definition is that of Lord Bingham: â€Å"that all persons and authorities in the State, whether public or private, should be bound by and be entitled to the benefit of all laws publicly made, taking effect (generally) in the future and publicly administered in the courts.† The Venice Commission has identified the following 8 components of the rule of law: ‘(1) Accessibility of the law (that it be intelligible, clear and predictable); (2) Questions of legal right should be normally decided by law and not discretion; (3) Equality before the law; (4) Power must be exercised lawfully, fairly and reasonably; (5) Human rights must be protected; (6) Means must be provided to resolve disputes without undue cost or delay; (7) Trials must be fair, and (8) Compliance by the state with its obligations in international law as well as in national law.’ The importance of the rule of law is recognised in multiple international documents. For example, the preamble to the UN Declaration of Human Rights notes the importance of the rule of law in protecting human rights. The Treaty on European Union also couples ‘the rule of law and respect for human rights’. It is this human rights element that the remained of this short essay will focus on. Brexit will reform the social landscape of Britain and Europe. It is of paramount importance that the rule of law is respected in this reformation to ensure that fundamental rights, particularly those of minorities and vulnerable individuals, continue to be respected. This is especially true given that there has been much debate as to whether the Brexit vote was fuelled by xenophobia and racism. Research has shown that there was an increase in support for far-right groups during the Brexit campaign and following the murder of Jo Cox. There has also been an alleged escalation in hate crime targeting migrant communities as well an increase in anti-immigration rhetoric. The Brexit vote, coupled with Trump, and the rise of the far-right, summons fears surrounding the polarization of politics and the creeping rise of extremism. With this in mind, it is quite chilling to consider Lord Bingham’s thoughts on a system which is not founded on the rule of law: â€Å"The hallmark of a regime which flouts the rule of law are, alas, all too familiar: the midnight knock on the door, the sudden disappearance, the show trial, the subjection of prisoners to genetic experiments, the confession extracted by torture, the gulag and the concentration camp, the gas chamber, the practice of genocide and ethnic cleansing, the waging of aggressive wars.† In a time when international politics is becoming increasingly unclear and strained and communities are fraught with increased fear and racial tensions, now more than ever, the rule of law and the importance of Parliamentary Sovereignty must be respected. As noted by the Prime Minister, the task before the British nation is momentous but it should not be insurmountable. Britain post-Brexit has an unclear future and an undefined path. By adhering to the rule of law, the certainty, stability and protection that it provides will ensure that this difficult task is negotiated with the utmost respect for all peoples and their inalienable human rights. 3. The European Union (Notification of Withdrawal) Act 2017 Given that the Supreme Court had dismissed the government’s appeal, the government now needed Parliament’s approval to trigger Article 50. In order to receive this approval, the government introduced a new bill in Parliament. This bill was called the European Union (Notification of Withdrawal) Act 2017.Essentially, this bill would give Theresa May the power to trigger Article 50. However, Parliament had the power to reject the bill if it felt appropriate. This was again because of parliamentary sovereignty (Weale, 2017).[33] Despite that most voters voted ‘Leave’ in the referendum, this result was not legally binding and Parliament could ignore the referendum result. The principle of parliamentary sovereignty means that the ultimate power rests with Parliament, not the public nor the results of referendums. The public only have the power to elect MPs, and once elected, MPs can go against the wishes of their constituents and make their own decisions if they want to. MPs can even go against a referendum result, despite that this might cause great anger with the British public. As Dicey stated, â€Å"the electors can in the long run always enforce their will† (Dicey, 1915).[34] However,   all three decision making bodies of Parliament – the Queen, the House of Lords and the House of Commons – approved the Notification of Withdrawal Act (BBC, 2017).[35] The Queen gave the final green flag on 16 March 2017. This gave the Prime Minister the power trigger to Article 50 and inform the EU of the UK’s withdrawal. The government officially triggered Article 50 on 29 March 2017, when a UK envoy delivered a letter of withdrawal to the President of the European Council (BBC, 2017).[36] The issue of parliamentary sovereignty then took a back seat as the UK began exit negotiations with the EU. Of the 170,000 statutory instruments that have been sent to Parliament in the last 65 years, only seventeen have been rejected, and any substantive debate over individual instruments is a rare occurrence. Responsibility has been delegated for regulation both to the government and the European Union. For this reason, possibly up to sixty per cent of UK law may be derived from EU law in some way. Furthermore, for many years, legislative and technical expertise in the pertinent areas have again been delegated to Brussels. This leaves domestic civil servants under prepared to handle the of important decisions that will need to be made in the coming years. David Allen Green’s analysis is difficult to refute: â€Å"under the cloak of the referendum result there will be a power grab by Whitehall from Westminster. Those rejoicing at â€Å"taking back control† should be careful what they wish for. The executive is, as usual, wanting to take control away from Parliament.† On many occasions, it has been asserted that because the ‘people have spoken’ through the referendum, it gives the executive the right to push onward without the consent of Parliament. On many occasions, it has been asserted that because the ‘people have spoken’ through the referendum, it gives the executive the right to push onward without the consent of Parliament. Does this mean that the claims of direct democracy, in the form of the referendum, trump the claims of Parliamentary representative democracy, with the paradoxical effect of giving more power to the executive? The greater part have affirmed that referenda are in and of themselves a product of Parliamentary authority and must accordingly rely on the statute which enables them. The 2015 EU referendum Act only called for the referendum to take place, without establishing how to approach it or the potential consequences. ‘Where, as in this case, implementation of a referendum result requires a change in the law of the land, and statute has not provided for that change, the change in the law must be made in the only way in which the UK constitution permits, namely through Parliamentary legislation.’ The actual political importance of a referendum is not subverted however. What is does assert is the basic dogma that, in a democracy, the people can speak through their representatives in Parliament. Nevertheless, direct democracy cannot be operationalised by giving undiluted power to the executive. 4. Conclusion This paper has discussed parliamentary sovereignty in the UK in the wake of Brexit. First, Section 1 introduced the concept of parliamentary sovereignty in the UK. This section explained that parliamentary sovereignty goes back to the 17th century, when the courts first enshrined the principle in the Bill of Rights. The section also drew attention to the rule that only Parliament can undo Acts of Parliament. I then discussed the Miller case in Section 2. In this case, members of the public argued that the government required Parliaments approval to leave the EU. The courts decided in favour of Millers side; that explained that Parliament was needed to trigger to Article 50 due to parliamentary sovereignty. The decision was controversial because some people saw it as an attempt to subvert the referendum result. Finally, Section 3 discussed the European Union Act 2017. This act that demonstrated the principle of parliamentary sovereignty. The government essentially asked Parliament for permission to trigger Article 50, and Parliament agreed by passing the act. In conclusion, the principle of parliamentary sovereignty was tested in the wake of Brexit. Ultimately however, courts respected the principle and gave Parliament the ultimate power over whether Britain should leave the EU. However, the future is still uncertain, as no-one yet knows what Brexit will look like. Perhaps a future Parliament will reverse the Brexit decision. After all, parliamentary sovereignty gives future Parliaments the right to reverse the decisions of previous Parliaments. What needs to be addressed is the potential consequneces that the referendum may have on Palimentary sovernety and represesentitive democracy throughout the UK. For this reason, Parliment needs to continue to be a central part of the process despite any predetermined preferences from the Government itself. Parliamentary sovereignty must remain intact as, for the many reasons stated, it is an integral part of the United Kingdom’s constitution, because its deliberate and representative functions and ability to hold the executive to account are defining features of the United Kingdom’s enduring constitution. 5. References Barber, N.W., 2011. The afterlife of Parliamentary sovereignty. International Journal of Constitutional Law, 9(1), pp.144–154. Barnett, H., 2017. Constitutional and administrative law, Taylor & Francis. BBC, 2017. BBC News website. Available at: http://www.bbc.com/news [Accessed July 14, 2017]. Bradley, A., 2011. The Sovereignty of Parliament–Form or Substance? The Changing Constitution, 23, pp.54–56. Dicey, A.V., 1915. Introduction to the Study of the Law of the Constitution 8th ed., Liberty Classics. EU, 2007. Treaty on European Union, Freehills, H.S., 2016. Judicial review litigation over the correct constitutional process for triggering Article 50 TEU. Lexology. Available at: http://www.lexology.com/library/detail.aspx?g=f43e102f-ea09-4449-b781-a35ecfe628fe [Accessed July 13, 2017]. Goldsworthy, J., 2010. Parliamentary sovereignty: contemporary debates, Cambridge University Press. House of Lords, 1965. Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75, House of Lords, 1610. Proclamations, Case of [1610] EWHC KB J22, Available at: http://www.bailii.org/ew/cases/EWHC/KB/1610/J22.html. Maguire, P., 2016. Seizing our sovereignty or declaring war on democracy: split view on judges’ ruling. The Guardian. Available at: https://www.theguardian.com/politics/2016/nov/06/brexit-this-is-what-sovereignty-looks-like#img-1 [Accessed July 13, 2017]. Pannick, D., 2016. Why giving notice of withdrawal from the EU requires act of parliament. The Times. Available at: https://www.thetimes.co.uk/article/c8985886-3df9-11e6-a28b-4ed6c4bdada3. Parliament of England, 1689. English Bill of Rights, Supreme Court, 2016. Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†), Available at: http://www.croftsolicitors.com/wp-content/uploads/2016/11/139459-UKSC-2016-0196-Skeleton-for-Expat-Interveners-final-written-case-2.pdf. Supreme Court, 2017. Miller v Secretary of State for Exiting the European Union, London. Available at: https://www.supremecourt.uk/cases/docs/uksc-2016-0196-judgment.pdf. Wade, W., 1961. Administrative Law, London: Oxford University Press. Weale, A., 2017. The Democratic Duty to Oppose Brexit. The Political Quarterly, 88(2), pp.170–181. 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