Thursday, October 3, 2019
Climate Change And Its Impact On Ski Industry Tourism Essay
Climate Change And Its Impact On Ski Industry Tourism Essay This essay talks about the presence of climate change and its impact on ski industry which is dependent activity on weather conditions. Global warming has been considered as a mega risk and it has a tendency to be permanent and therefore it is extremely complicated to measure its outcomes. As Nicholls (2006) mentioned, climate change is nowadays strongly accepted by many worlds scientists and governments as an issue of tremendous alarm for the people worldwide. This essay considers different models of possible impacts of global warming on different parts of the world. Steyger and Mayers (2008) said that since the 1990s the likely dependence of snow tourism to climate change has received greater alertness in the media. Increasing number of authors focus on this matter as well as on the adaption strategies of ski resorts. This paper demonstrates that global warming is a problem which forced majority of ski resorts all over the world to respond to weather changes in order to survive. Essay talks about options that are available to ski resorts and brings on the discussion of their usage and their effectiveness. Ski resorts all over the world are likely to experience a loss of snow consistency and that is why supervision of ski regions has to be more conscious when it comes to future of snow conditions in their geography area. Global warmings impact on ski industry Models of projected outcomes of global warming Climate as well as the natural environment associated with weather change can likely to impact open-air leisure and tourism. Businesses linked to skiing industry are largely exposed to the projected impacts of global warming because skiing is an activity dependent on climate conditions. Bricknell and McManus (2006) considered that it is one of the first and the most visibly impacted industries by the risk of global warming worldwide. Folland et al (2001) as mentioned in Moen and Fredman (2007) stated that annual snow cover level in the northern hemisphere has decreased by approximately 10% since 1966 and also that previous decade was wetter and warmer compared to the prior 30-year period in whole Europe. Global warming has already affected and will most probably carry on with affecting physical and natural systems all over the world. As Moen and Fredman (2007) refered to Intergovernmental Panel on Climate Change (IPCC, 2001), the expected effects of global warming include a proposed boost of globally averaged outside temperature by 1.4 to 5.8Ã °C between years 1990 and 2100 which would also possibly lead to sea level rise of 0.88m globally. ZAMG (2007) as cited in Breilings and Charamza (1999) found out that because of global warming the line of usual snowfall steadiness will raise by about 150 m of altitude per 1Ã °C of warming. For better picture, low attitude ski resorts are those below 1800-2000 m and thus, the majority of ski resorts in the world. Not to mention Breilings and Charamzas (1999) estimation that a 1Ã °C rise in average temperatures with winter drought may reduce the duration of snow cover by 50% at altitudes in range of 1400 1600 m. For example, Moen and Fredman (2007) estimated that no more than 63% of the entire Swiss ski regions will be snow consistent once a temperature raise by 2Ã °C, not to mention the impact in the worst case and thus, in increase of temperature by 5.8Ã °C, taking to account IPCCs model. If we link these few findi ngs together, we may conclude that in the worst circumstances, the natural snow dependability will rise by 870m of altitude by year 2100 which would mean that ski resorts of altitude about 2000m may end up with as much snow as altitudes in regions about 1000m today. Larsson (2003) concentrated his research on climate change adaption in Canada and the findings are very similar to of those in Europe. He used model of McCarthys (2001) research which estimated that global warming in Arctic land areas may become theatrical by year 2080. Summer temperatures would increase by 4.0-7.5Ã °C, winter temperatures by 2.5-14.0Ã °C. These numbers are even more. If these predictions are about to be fulfilled, it would lead to melting of permafrost, leading to soils with condensed bearing capacity in ice rich areas and active regions of irregular permafrost. Additionally as he found out, the global warming effects may decrease periods of extreme cold and on other hand increase frequency of extreme heat in North America. Growing sea levels and danger of rainstorm course, and thus danger of coastal flooding, variations in timing, regularity and severity of flooding linked to rainstorms are likely to become a reality. Moen and Fredman (2007) mentioned that according to Mendelsohn and Markowski (1999), global warming would most likely have an effect on outdoor leisure in three ways in the future. These include accessibility of leisure possibilities throughout longer summer seasons and shorter winter seasons. The comfort in general, satisfaction of leisure activities and the quality of the leisure experience. These kind of changes will generate winners as well as losers as diverse sorts of outside recreation activities involve dissimilar climatic conditions. These outcomes are though generalisations that may be applicable at collective level, whilst it would expect large district and neighbouring variations between different tourism activities. All of the above findings are alarming for winter tourism destinations and therefore managements of ski areas have to be very aware of possible impact of climate change on their ski spots as the snow is fundamental aspect of ski tourism. Snow conditions as a key factor Winter tourism is in many ways reliant on natural features such as terrain, elevation or vertical fall. On other hand, even more significant features are weather conditions, and thus temperatures, airstream and snowfall. With decrease in snow cover, whatever the terrain or vertical fall may be, it is almost impossible to develop any ski opportunities. More authors agreed that snow cover is a key variable for consumers to decide where to ski. Suggestions that impacts on global warming on winter tourism can be significant are apparent from research from different parts of the world. For example, Fukushima et al (2002) as expressed in Moen and Fredman (2007) formed the interactions connecting air warmth, rainfall, snow intensity and the amount of skiers at seven different ski resorts in Japan. They found out that the number of skiers decreased by 30% when temperature increased by 3-C. Godfrey (1999) found out that one of the most important aspects influencing destination choices of Engl ish skiers going to Canada is snow conditions. These findings strengthen an argument that snow conditions and snow cover may be regarded as the most important factor for any ski resort. As discussed and illustrated before, the phenomenon of global warming may, and most likely will have a huge impact on snow conditions in mountains and ski areas and thus it will also have significant influence on businesses of new as well as matured ski destinations. Majority of them started to feel impacts of global warming and they are trying to find solutions in order to respond to weather changes so they have better chance to survive and keep their businesses alive. The question is, is all it possible even without not enough natural snowfall? Adaption by ski industry Artificial snow-making Steiger and Mayer (2008) concentrated their research on Austrias and Swisss ski industry and stated that technically created snow is the most used alteration approach for unusually hot winter seasons. Nicholls (2006) who researched climate change and its impact on outdoor tourism in Europe said that key technological alteration to snow absence is the implementation of artificial snow-making facilities. Moen and Fredman (2007) considered that the most general adaptation to snow-deficient winters in Sweden is also artificial snow-making. The practice of snowmaking is increasingly characteristic for the Australian ski industry too (Bricknell and McManus, 2006). Snowmaking may be used not only to influence ski season durations but also to reduce snow changeability throughout the season. This is viewed as an insurance policy for overcoming the unreliability of seasons and dealing with the potential impacts of climate change. Snowmaking could be considered short to medium-term adaptation a pproach, not just for low altitude ski destinations but as well as for financially strong year-round resorts at higher altitudes (Nicholls, 2006). For instance, in Austria almost 60% of the ski areas are covered by artificial snow-making facilities (FSO, 2007 in Steyger and Mayer, 2008). But the distribution of snow-making cannot be related to global warming as trends in tourism, status, and competitive advantage are crucial features. Steiger and Mayer (2008) said that ski resorts are forced to build up snow-making capabilities with cost for their financial strength as warm winters are becoming more common than in the past. However the possible assistance of this machinery to the practicability of winter tourism destinations have yet to be formed by researchers as the significant expenditures are linked with this measure. For instance, approximately 27% of ski resorts in Switzerland have a reduced cash stream already and most do not seem to be viable without help (Seilbahnen Schweiz 2006 in Steiger and Mayer, 2008). Elsasser and Burki (2002) and Scott et al. (2003) as described in Nicholls (2006), stated that snowmaking ameniti es are costly to assemble and preserve, and need significant amounts of water and power to work. For that reason, many of the small and middle range ski resorts would not have enough money for the implementation of such technology. Usage of snow-making technology In preparation for the skiing season of 2006-2007 the Austrias Tyrolean ski industry invested EUR 55 million in snowmaking, with EUR 270 million in overall investments even though, the past winter seasons had brought sufficient snowfall yet at lower elevations (Tiroler Tageszeitung 2006 as illustrated in Steyger and Mayers, 2008). This points out that while the operators observe climate circumstances as regularly too blurred and uncertain, they are well aware of global warming and are searching for adaptation strategies. Also, medium-term investment strategies are not tailored, as there is a lot of confidence in the improvement capacities of snowmaking machinery with a clear perceivable hole between weather change and economic investment phases (Mayer et al 2007 in Steiger and Mayer, 2008). As they mentioned, while the poor winter seasons at the end of the 1980s sparked artificial snowmaking in Tyrol, additional distribution was not related to weather unpredictability and global warm ing scenarios. On other hand, there is tendency to supply even naturally snow consistent ski resorts in high altitude areas higher than 2000m or in even 2500m with snow-making amenities. These elevations may be regarded as naturally snow consistent even in pessimistic global warming scenarios. As they said, snow-making amenities can be also used as promotion instrument to be a magnet for tourists, to build reputation and to maintain prices higher than it would generally be. These resources could perhaps be used in more sustainable way than just unnecessary usage of water wealth and other detriments of snow guns. Snow-making guns are not necessarily used in order just to make ski slopes usable for longer period of time. Main enthusiasm for the unique diffusion of snowmakers are that snowmaking should secure tourist capacity consumption, cable car companies revenues, and images of resorts in which domestic as well as international ski rivalry go on. Furthermore, it ought to guarantee broad environment for teaching and exercising of winter sports. How is global warming related to diffusion of snow-making facilities? Austrias case is different as there are many high-altitude ski resorts but Bricknell and McManus (2006) interviewed CEOs of three different ski resorts in Australia on this issue. CEOs assured that snowmaking technology may help to negate projected climate change impacts. The CEO of one resort suggested that, under global warming, snowmaking conditions may be unaffected or even improved because drier colder nights are good for snow-making which would assist the long term viability of the industry. The CEO of second resort noted that snowmaking is a necessary investment regardless of the potential impacts of climate change due to current consumer demands on the industry. CEO of third resort however, argued that global warming could have significant impact on artificial snow-making as this technology still depends on climate conditions and thus it still would not necessarily overcome the issue. Global warming and artificial snow-making Global warming may influence snowmaking in few ways. Decrease in natural snowfall would require more snowmaking; increase in average temperatures would decrease the length and amount of possibilities and boost the expenses of making snow; and variations in rainfall may distress the water supply for snowmaking (Scott et al., 2006 in Moen and Fredman, 2007). Analyses in North America have exposed that artificial snowmaking can significantly lessen the pessimistic outcomes of climate change but only if the temperature stays adequately low (Scott, 2006; Scott et al., 2006 in Moen and Fredman, 2007). Nicholls (2006) stated that artificial snow-making needs certain climatic surroundings, as for example minimum temperatures to be met and hence, this system may in several circumstances be prohibited beside the increase in warmth related to the global warming. The most important thing about snow-making is that snow guns and their usage are limited by weather conditions (Steiger and Mayer, 2008). High-quality snow can be accomplished with snow creation starting below -6Ã °C at average humidity. On top of that, snowmaking conditions are prejudiced by warmth and wetness; if the air is wetter, lower temperatures are required. With recent snowmaking tools snow can be produced below -5Ã °C. Fliris (1974) weather tables as expressed in Steiger and Mayer (2008) demonstrate a strong connection between -2Ã °C daily average temperature and -6Ã °C daily lowest temperature (Nicholls, 2006). Days reaching the threshold of -2Ã °C daily average temperature are defined as prospective snowmaking days with best snowmaking conditions. Additionally, snowmaking is only considered realistic if it can poise out the loss during snowmelt. Therefore for majority of low-altitude ski resorts this strategy does not patch up the issue of global warming for long term and they have to start to look for other strategic options in order to overcome the problems of peak season shortness and falling visitor numbers as a result of climate change. Moen and Fredman (2007) adopted from Burki et al (2003) some other adaption strategies ski resorts may consider. Apart from snow-making, resorts could concentrate on different activities in order to fulfil consumer requirements and to survive on competitive business market. Slope development and operational practices At active ski areas, slope expansion alterations consist of: slope contouring, landscaping, and the defence of glaciers. Contouring or flatting ski slopes could be grooming slopes in the summer season to eliminate rocks or shrub vegetation, to reduce the snow deepness needed to operate and represent a cost saving approach for snowmaking (Scott and McBoyle, 2007). Land contouring can also be used to capture snowmelt and top up snowmaking tanks during the winter. Strategic placing and planting of tree cover can capture moving snow and to some extent gloom ski slopes, which would reduce snowmelt and snowmaking needs. Additionally to the adjustment of already operating skiable environment, the expansion of new skiable terrain in climatically privileged sites is generally cited as an alteration to climate change. The development of north facing slopes, which retain snowpack longer, is one strategy too. As Scott and McBoyle (2007) realised, more authors agreed that expansion of ski areas i nto higher elevations, with generally more reliable snow cover, where a longer ski season is possible, seems to be one of the key climate change adaptation strategies considered by ski area operators in the European Alps. Thirty six ski areas in Austria were awaiting authorisation to develop their operations into higher elevations in 2002- 2003. Wolfsegger et al. () as illustrated in Scott and McBoyle (2007) said that expanding to higher elevations was the third most favourite global warming adaptation choice by Austrian ski area managers, after snowmaking and sharing snowmaking costs with the accommodation industry. Nicholls (2006) also agreed that strategy of development of higher altitude ski resorts is option that tends to be of favour for existing ski resorts. Large ski corporations over smaller, family-owned businesses tend to use this strategy. Although, such improvements would present a host of ecological and safety concerns which the industry would need to deal with in order to uphold the industry in a viable approach. These comprise bigger pressure from new production as well as improved waste creation. Also due to mountain terrain or height this strategy is in many cases impossible. Other option is to cooperate or expand into areas with more reliable snow which may on other hand diversify income structure of resorts. Scott and McBoyle (2007) said that high elevation mountain environments are particularly sensitive to disturbance and opposition from the public and environmental groups may pose a significant constraint on this adaptation strategy in some locations. Marketing incentives and new product developments Bricknell and McManus (2006) suggested that many resorts use strategy of flexible ticket pricing policy and thus reducing ticket prices in order to attract more skiers. Scott and McBoyle (2007) mentioned that ski companies have already begun to experiment with incentives or guarantees to overcome skiers reluctance to book a ski holiday because of uncertain snow conditions. In the winter of 1999-2000, for example, the American Skiing Company promised visitors to its six New England region ski resorts a 25% reduction on their next vacation if the ski area failed to open 70% of their ski runs during the Christmas-New Year holiday period. Warm temperatures that season forced three of the six resorts to pay customers rebates (Keates, 2000 in Scott and McBoyle, 2007). Another strategy could be to develop non-snow related activities in winter or to become all season destination as more choices could attract more tourists and it could bring other benefits. All year round tourism could be developed by providing climate independent tourism such as conference or educational tourism. Nicholls (2006) mentioned that the building of conference amenities combined with the contribution of a broad variety of outside leisure activities during the seasons may provide resorts with a balanced, constant source of revenue that is less dependent on weather conditions. On other hand, the expansion of such substitutes needs an primary lay out of funds which may go beyond the capabilities of smaller ski businesses. Over the past three decades, many ski areas in North America have diversified their operations beyond traditional ski activities to include the provision of skiing and snowboarding lessons, accommodation and retail sales (Scott and McBoyle, 2007). The Economist (1998) referred to the alteration of major ski resorts in North America from ski areas to winter theme parks, as the Disneyfication of the winter sports industry (Scott and McBoyle, 2007). Non-skiers represent an important market at ski resorts. Williams and Dossa (1990) estimated that 20-30% of visitors to ski resorts in Canada did not ski during their visit (Scott and McBoyle, 2007). They also pointed out that in season 1974-75, lift tickets stood for almost 80% of profits for the usual ski area in the US. Nowadays, lift tickets stand for not even than half the profits, as other activities have risen in significance. Therefore to diversify the market and also to decrease the pressure of demand on ski lifts, this strategy see ms to be very supportive for existing ski resorts with capabilities to do so. Many ski resorts have made substantial investments to provide alternate activities for non-skiing visitors. For example snowmobiling, skating, dog sled-rides, indoor pools, health and wellness spas, fitness centres, squash and tennis, games rooms, restaurants, retail stores and many others. Moen and Fredman (2007) agreed, developing alternatives to skiing during winter is well recognised strategy to overcome falling visitor numbers into ski areas; however he pointed out, that it is also problematic as many of these alternatives are reliant on snow conditions or ice-covered lakes and thus dependant on climate conditions. All year round tourism The most promising strategy in order to completely overcome the problems of global warming may be to develop all-year round tourism. Moreover, offset pessimistic financial effects as of global warming, such a strategy would as well have optimistic public effects on conventional winter destinations as seasonal dissimilarity in employment prospects are bridged over. A number of ski resorts have further diversified their business operations to become four season resorts, offering non-winter activities such as golf, boating and white-water rafting, mountain biking, paragliding, horseback riding and other business lines. At many larger resorts, real estate construction and management has also become a very important source of revenue. On other hand, as Bricknell and McManus (2006) stated, the development of summer tourism needs long term preparation in order for them to develop appreciation in this market. The resorts will have to contend with each other and with summer destinations such as coastal locations, which would be in many cases very tough, especially where coastal summer tourism takes place. The expansion of tourism into the summer season in sequence to support or to swap snow tourism may also direct to environmental conflicts. Activities that resorts may want to promote, such as bike riding and horse riding, could unintentionally leak out into regions of preservation where they are forbidden. These kinds of activities are also known to worsen environmental issues, such as erosion and the spread of exotic species. If these forms of tourism increase in popularity, the carrying capacity for these mountain destinations must be re-evaluated to encompass their potential impacts. Role of public sector The public good characteristic of climate change creates complicated challenge for financial and political organizations. The lack of an unchanged weather is not connected to growing prices and is not necessarily measured to the top valued consumers. To maintain well-organized policies, inputs from financial estimations of global warming impacts are essential. Such financially viable measures consist of direct economic impacts to the economy as well as benefits to the contributors. For instance, Scott et al. (2002) as described in Scott and McBoyle (2007) used spending records to present approximation of the possible economic impacts from g oobal warming on skiing in Canada, whilst Richardson and Loomis (2005) calculated the effects of climate on motivation to pay to visit Rocky Mountain National Park. Many authors put some efforts to place an economic value on global warming impacts to tourism and outside leisure. For example, as Scott and McBoyle (2007) said, Meier (1998) approxima ted the cost of global warming for the 4 season tourism in Switzerland at USD 1.1 1.4 billion by the year 2050. Scott and McBoyle (2007) said that better weather forecasting would make available an enhanced foundation for risk assessments and tactical business choices, as well as the timing of seasonal openings or when to begin artificial snowmaking. Negotiations with ski operators in eastern North America propose that the industry does not presently use seasonal forecasts in their operational decision-making and substantive enhancements in forecasting accurateness would be necessary before these products would achieve a level of realistic value for the ski industry. Some ski operators yet think about five to seven days forecasts as too untrustworthy for operational decision-making and applied forecasts from different countries or classified services instead of governmental forecasts (Scott and McBoyle, 2007). Announcements to the community through the media could be a further aspect of forecasting that could be improved in some areas. Ski operators occasionally have adversarial interaction wi th a number of neighbouring media for the reason that of what they recognise as inaccurate exposure of weather conditions and forecasts that they disagree cost them business (King, 2005 in Scott and McBoyle, 2007). Government support to the ski industry has taken place in the variety of discounted energy costs, long-standing leases of communal lands and infrastructure fundings, but the industry has not gained from the kinds of backing programs offered to other climate-sensitive trade sectors such as for example, sponsor harvest insurance for the agriculture sector. In the future, skiing based tourism economic losses consequential from unpleasant climate circumstances may be adequate for government concern and support in some cases. Government participation in the ski industrys prospect could perhaps take a number of forms. Direct involvement could come throughout financial assistance, cover support or marketing proposals. Ultimately, government policies linked to land and water use, and energy and revenue spending could impact skiing operations positively. Government financial assistance for snowmaking was greatly supported by Austrian ski area managers, whilst government assistance for financial losses because of poor winters was only to some extent supported (Wolfsegger et al, 2005 as demonstrated in Scott and McBoyle, 2007). Conclusion This essay discussed the problem of global warming and its projected impacts on ski industry all over the world. It demonstrated that climate change is broadly accepted as a mega risk, particularly for businesses dependant on weather conditions. Numerous ski resorts, especially those that are established at lower elevations could face serious problems if climate change forecasts are about to be accurate in the future. Among limited supply of downhill ski resorts, coupled with an existing high demand for the activity, it would possibly lead to yet other remarkable increase in prices and environmental pressures. Ski resorts have several strategy options to consider when it comes to problem of not sufficient snow cover in their geography area. Some tend to use artificial snow-making facilities, some aim to diversify their business portfolio by offering a new products and developments of new tourism attractions. The most promising strategy to overcome global warming problem, as regarded by few authors, was to become an all-year round tourism destination. However, all of these adaption strategies tend to go hand in hand with the issue of sustainability which should be taken more seriously as all developments take place in extremely sensitive environments. The essay demonstrated that adaption strategies are increasingly used already by ski resorts in many parts of the world and that sometimes these are not even related to global warming. The most commonly used adaption strategies are not without ecological and financial costs. Water usage from natural water bodies can lesser water intensities and influence fishing harmfully. Power needs are high as well and inversely linked to warmth, and will thus sustain higher expenditure the warmer the temperatures get. By means of this type of disorder of demand to ski regions with higher altitude, ecological loads upon the nearby environments would be enlarged. This paper only fairly points out issues that come along with new developments and expansions of ski regions and these should be further discussed and analysed.
Wednesday, October 2, 2019
Phenomenology and Architecture Essay -- Environmental and Architectural
Introduction Phenomenology can be deemed to be both an unambiguous academic research field and a theoretical design current within contemporary architecture and is usually founded on oneââ¬â¢s experience of the materials used in construction inclusive of their sensory characteristics. In this regard, architecture is the impetus towards transformation and inspiration of an individualââ¬â¢s daily existence. Unlike other forms of art, architecture employs the immediacy of an individualââ¬â¢s sensory perception. The complete architectural experience is dependent on many factors such as details, materials, texture, color phenomena, transparency and shadows, time passage, etc. There is the huge phenomenon that phenomenology does not exist in architecture but rather the problems associated with it. This theory is very debatable and this paper will aim at expounding on some of the aspects associated with phenomenology. Acoustical Intimacy Science The ear, which is the organ that the body uses to achieve acoustical intimacy, is capable of defining a space and the resultant effect is a sculptural image encrypted in the deep parts of the mind. Acoustic science dictates that sound can be softened or refracted by the surfaces of copious entities of personal life. All spaces and buildings posses individual characteristic sounds of monumentality or intimacy, hostility or hospitality and invitation or rejection. The ability to hear generates a sense of solidarity and connection contrary to the ability to see which creates a feeling of solitude. The sound of a friend approaching you behind your back definitely has a charge filled with emotion as th... ...nds: TU Delft Department of Industrial Design, 2006. Holl, Steven, Juhani Pallasma, and Alberto Perez- Gomez. Questions of Perception. Tokyo: a+u Publishing Co., 1994. Le Corbusier. Towards a new architecture. London: Architectural press, 1959. Levin, D.M. The Opening of Vision ââ¬â Nihilism and the Postmodern Situation. New York and London: Routledge, 1988. Pallasmaa, Juhani. An Architecture of the Seven Senses, Questions of Perception. Tokyo: a+u Publishing Co., 1994. Pallasmaa, Juhani. The eyes of the skin ââ¬â Architecture and the Senses. Great Britain: Academy Editions, 1994. Yusufzai, Zinat. ââ¬Å"The Lucidity of Place.â⬠Thesis of Master of Architecture in the Virginia Polytechnic Institute and State University (2001): 10-20. http://scholar.lib.vt.edu/theses/available/etd-11302001-161439/unrestricted/thesis-low-res.pdf (accessed February 19, 2014).
COMPARE AND CONTRAST THE WAY WORDSWORTH AND HUGHES WRITE ABOUT NATURE E
COMPARE AND CONTRAST THE WAY WORDSWORTH AND HUGHES WRITE ABOUT NATURE IN THEIR POEMS DAFFODILS AND THISTLES Hughes wrote the poem ââ¬Å"Thistlesâ⬠which is about how these plants are. He speaks about them as if they were a sign of violence, and violent creatures. He views them as a symbol of vengeance, pain and threat. The thistles are spiky and can hurt anyone. They are dull, immortal, green, rough, and produce a big amount of chaos, written in Wordsworth on the other hand, wrote about ââ¬Å"Daffodilsâ⬠which are small golden flowers. They look vivid, colourful and peaceful. These flowers produce a state of calm, sweet and memorable moments. Written in romantic era of literature, in 1804 Each poet creates a different mood in their poems. Hughesââ¬â¢ use of imagery creates a bad and nasty mood. It even creates horrible and mean moods, and sometimes a scary mood. The use of imagery has a reason to it as well; the purpose of it is to make people get a vision, a small scene, and a picture in their minds of what thistles look like, and what they do to be so painful. Hughesââ¬â¢ way of using imagery is good as it explains whatever he sees; it shows that he can use other things or words to explain his views. An example of this imagery is the line that says ââ¬Å"everyone manages a plume of bloodâ⬠this makes people think that everyone has a river of blood on them, so it brings a horrible scene into peopleââ¬â¢s minds. Wordsworth doesnââ¬â¢t use much imagery but whenever he does, he uses it in such a way that people want to continue to read the poem a few more times. His was of using imagery makes people get a nice and pleasant view of the daffodils, like for example in the line ââ¬Å"tossing their heads in sprightly danceâ⬠this shows t... ...w, which makes you want to keep the scene in mind all the time and makes you think about the daffodils. But, when you think about the scene of the thistles poem, it isnââ¬â¢t as nice and pleasant. This is because the thistles represent a battle, a fight, in which death is involved, when you read it, it reminds you of wars, of fires and all unpleasant memories. The daffodils basically show happiness and joy to everyone, that is why I prefer it. The words that the poet uses in order to describe the poem are exceedingly special as they describe the location in which the daffodils can be found and admired. In the poem he doesnââ¬â¢t talk about the daffodils beside the lake, it also talks about how it affected his life and how he kept on thinking in the daffodils after being in the lake. This poem is more memorable than the thistles one, which is why I prefer it more.
Tuesday, October 1, 2019
Dell in Brazil
1. Why did Dell decide to invest in Brazil? Dell decided to invest in Brazil because of its strategy to expand internationally. Dell had operations in many countries but did not have any manufacturing plants in Latin America, which was the fastest growing market for computers. Brazil was the ideal place for its manufacturing plant in Latin America because it presented a huge potential market for Dell since it was Latin Americaââ¬â¢s largest country with over 170 million people. Dell felt that the only way to dominate and become effective it the Brazilian market was to have its own manufacturing plant in Brazil.In addition, Brazil contained high import tariffs which would cut away at Dellââ¬â¢s profits if it had to export products from the U. S. into Brazil. Also attractive was Brazilââ¬â¢s membership in Mercosul. This would be beneficial for Dell because any company producing 60% of a product in a Mercosul country would be exempt from all tariffs when exporting to other coun tries associated with Mercosul. These countries associated with Mercosul included Argentina, Uruguay, Paraguay, Chile, Boliva, and Brazil. Therefore, Dell would have an advantage when exporting its products from Brazil to any of these other Mercosul countries. . What were the pros and cons of the five short-listed states for Dellââ¬â¢s investment in Brazil? Why did Dell select to invest in the state of Rio Grande do Sul? The 5 short listed states for Dellââ¬â¢s investment in Brazil included Sao Paulo, Rio de Janeiro, Parana, Rio Grande do Sul, and Minas Gerais. Some of the pros that were common in all of these states were adequate levels of education, a sufficient pool of qualified labor, a steady supply of electricity, and sufficient telecommunications and transportation infrastructure.Beginning with the pros for Sao Paulo, this state contained the largest market for personal computers in Brazil due to its large population. It also had a huge supply of skilled labor. Sao Paul o presented two attractive locations for the plant in the cities of Sao Jose dos Campos and Campinas. The cons for Sao Paulo included the mannerisms of the state government officials who seemed indifferent to Dellââ¬â¢s specific needs and concerns. Sao Pauloââ¬â¢s investment promotion agency did not seem catering to Dellââ¬â¢s selection team since the state did not have any problems attracting foreign investment.In addition, Sao Paulo did not offer Dell any special financial incentives to attract their investment. Next, Rio de Janeiro had several pros common to all 5 states as previously mentioned. However, the state offered Dell very few financial incentives with the intention of receiving a counter offer from Dell. Dell responded negatively to this initial low offering of incentives and did not return to renegotiate. Parana also contained the same pros that were common among the 5 states. On the other hand, the main negative of the state included the amount of financial i ncentives that the government was offering.These financial incentives did not compare to the financial incentives that other states such as Rio Grande do Sul offered. In addition, the state and its promotional agency did not seem determined to attract Dellââ¬â¢s investment. Dell was given a general presentation that did not address the company specifically. Aside from the common pros listed above, Minas Gerais greatest advantage was its investment promotion agency INDI. The agency was very qualified and catering to Dellââ¬â¢s concerns. The INDI even set up meetings for Dellââ¬â¢s selection team to meet state government officials.The state also offered favorable financial incentives that included a 70% reduction in ICMS tax for 10 years and a loan of R$20 million to be paid back in a 4 year period with a 4 year grace period. The state also offered free land for the plant to be built on. However, the cons of Minas Gerais centered around the region being highly industrialized. The Dell selection team felt that the state was a ââ¬Å"heavy-industry, rust-belt, region. â⬠Because of this, Dell felt that the government would not be able to satisfy Dellââ¬â¢s specific needs as a high-technology company.The last state was Rio Grande Do Sul, which was most attractive to Dell. The biggest plus of this state was its independent, non-profit investment promotion agency, Polo. Polo was very helpful in addressing Dellââ¬â¢s concerns and even went to Dellââ¬â¢s office in Texas to give a presentation. The Polo was eager to seek high technology investment and was determined to attract Dellââ¬â¢s investment. For other pros, Rio Grande do Sul had an adequate infrastructure and had one of the most efficient telecommunications infrastructures in the country.This would create huge cost savings for the plant. The state also posed few security concerns as its roads were much safer than roads in other states such as Sao Paulo. Rio Grande Do Sulââ¬â¢s capita l, Porto Alegre, was the ideal location of the plant. This city specifically made Dell feel at ease since the crime rate was very low. Other pros included existence of many established universities, a huge pool of skilled labor, and a high standard of living among the population.Most of all, the government offered Dell the most favorable incentives out of the 5 states. It offered a 75% reduction in ICMS tax for 12 years, and R$20 million loan with a 5 year grace period and a 10 year payback period. The main negative of Rio Grande Do Sul was the recent change in its state government creating an uncertainty in political views toward foreign investment. Olivio Dutra had just been voted into office and was greatly opposed to the deal and the financial incentives that had been previously offered to Dell by the state.This change in the political environment was a huge negative as Dellââ¬â¢s new deal was now discarded. Dell eventually decided to invest in the Rio Grande Do Sul mainly be cause of its investment promotion agency, Polo. As described above, the Polo was very catering to Dellââ¬â¢s specific needs. Polo was very well prepared when the site selection team came to visit. The agency arranged private interviews with business leaders and state officials. It even took Dellââ¬â¢s selection team to a local bar that resembled the atmosphere of Texas.This local microbrewery contained well educated and friendly people, which convinced the team that there was certainly qualified, personable, and articulate people that could be hired at the new plant. Poloââ¬â¢s determination and quick, thorough preparation won the attention of Dellââ¬â¢s selection. In addition, the state offered Dell the most favorable financial incentives out of the 5 states. 3. Why didnââ¬â¢t the new governor Olivio Dutra approve of the deal that former governor Britto had negotiated with Dell? Olivio Dutra was part of the socialist Workersââ¬â¢ Party.He did not approve of the de al because he was opposed to the government giving multinational corporations special incentives and benefits. By offering these corporations special benefits, the multinational corporations could play each state against each other for their own self interest. Many felt that these corporations were already extremely wealthy and did not need to be seeking tax advantages from poor states. Throughout his campaign against governor Britto, he focused on criticizing the excessive benefits that Britto had given these multinational corporations.Therefore, when Dutra finally took office, he had to follow through with his words and take action. This then led to Dutra rejecting Dell and Fordââ¬â¢s deals by suspending the loans granted to these corporations and refusing to offer tax incentives. 4. Given the changed terms of operation, which of Dellââ¬â¢s options seems most plausible to you: (a) Leave Brazil entirely? ; (b) Move the plant to another state? ; or (c) Try to renegotiate with Governor Dutra? I believe that Dell should first try to renegotiate with Governor Dutra. Dutraââ¬â¢s actions had already cause the state to lose Fordââ¬â¢s investment.Losing another huge opportunity for investment in Rio Grande Do Sul would be horrible for Dutraââ¬â¢s reputation as the new governor. Therefore, I believe Dutra would be willing to be less strict concerning its ââ¬Å"no incentivesâ⬠policy. As the case states, Dutra was even willing to renegotiate with Ford after hearing that it was moving its operations to another state. However, Ford had already made their decision to move and was not going to renegotiate. Therefore, I believe Dutra would not also risk losing Dellââ¬â¢s investment and would be even more willing to renegotiate with the company.It would not hurt Dell to see what Dutra will offer during renegotiations. If Dutra still maintains a strict stance on providing few incentives, then Dell should move its operations to Minas Gerais, which had a lso offered favorable financial incentives. Although the company may be concerned over the political policy uncertainty of Dutra, Dutra has had a reputation for his honest and effective ways. For this reason, if he does grant Dell financial incentives, he would stay true to his words so Dell would not have to question the future political environment. 5) In your view, which factor was decisive for Governor Dutraââ¬â¢s new relaxed policy towards Dell? The decisive factor for Governor Dutraââ¬â¢s new relaxed policy was Fordââ¬â¢s decision to move its operations out of the state to Bahia. The loss of Fordââ¬â¢s investment was detrimental to Rio Grande do Sul because Fordââ¬â¢s operations in the state could have improved its economy and provided thousands of jobs for its residents. For this reason, this lost opportunity was very bad for Governor Dutraââ¬â¢s political reputation in the eyes of Rio Grande do Sulââ¬â¢s people.If Governor Dutra also let Dellââ¬â¢s in vestment slip away, this could ruin Dutraââ¬â¢s political status and eliminate his chances of ever being reelected as governor. Therefore, Dutra probably learned from his mistake in the Ford renegotiations of being too strict with his ââ¬Å"no incentiveâ⬠policy. Dell could easily move its operations to another state such as Minas Gerais, who also offered Dell similar incentives. This would be easy to do since Dell had not yet started to build its plant in Rio Grande do Sul. This certainly caused Dutra to have a more relaxed policy towards Dell with the intention to not lose Dellââ¬â¢s investment as well.
Monday, September 30, 2019
Academic Stress Essay
This annotated bibliography was prepared at Stanford University under the supervision of faculty from the Law School and the School of Education working in collaboration with Challenge Success. It is not intended to be all-inclusive. If you are aware of articles, books, or other materials that should be included, please send an email to Professor Michele Dauber at mldauber@gmail.com. Please feel free use this bibliography and cite it or the materials in it. You can use it several ways. 1. If you know the topic you are interested in (i.e., depression), you can scroll down and read the ââ¬Å"Summary Findings by Topic,â⬠and then locate the cited articles by searching the document on the authorââ¬â¢s name, searching chronologically. 2. You can also search this document for the keyword ââ¬Å"depressionâ⬠and read the abstracts of the articles that contain that keyword. 3. You can scan the most recent reseach by reading the most recent abstracts in the ââ¬Å"Annotated Bibliography of Sources in Reverse Chronological Order. Internationally, students that are not academically burnt out tend to have higher GPA scores and self-esteem than students that are academically burnt out (Lee et al., 2010). Studies show an important relationship between increased school work and decreased sleep, as well as the relationship between decreased sleep and increased feelings of anxiety, depression, and fatigue (Fuligni & Hardway, 2006). Longitudinal studies show an increasing pressure placed on children and adolescents in terms of expected time spent on school and school-related work, which could result in less time for things like extracurricular activities, sleeping, and spending time with family (Juster, Ono, & Stafford, 2004). Yadusky-Holahan, M., Holahan, W. (1983). The effect of academic stress upon the anxiety and depression levels of gifted high school students. Gifted Children Quarterly 27(42): 42-46. Keywords: academic stress, student anxiety and depression, living situation, gifted students The primary goal of this study was to understand the relationship between living situation (living alone or with a roommate) and anxiety and depression for high-ability, high-achieving students. Findings show that stressors relating to the school environment, academic expectations, and workload were found to be potential contributors to heightened depression. The study had various hypotheses, including the prediction that increased anxiety and depression levels would be found for those students that lived alone, because they were lacking peer support. The participants included sixty twelve-grade students who attended a competitive public school. Thirty of these students lived alone, and thirty had chosen to live with roommates. Measures were taken to limit environmental effects, and three instruments were used to gather three separate tests over a five month period. These instruments included The Depression Adjective Check Lists, the IPAT Anxiety Scale, and the Mooney Problem Check List. The data was gathered before school started, in the middle of the semester, and just before final examinations. Results showed that depression was significantly higher mid-semester versus beginning of the semester, except for females with roommates. Males with roommates and females without roommates reported significantly higher levels of depression during the final exam period. Stressors relating to the school environment, academic expectations, and workload were found to be potential contributors to this heightened depression. Other findings were that only women in single rooms had increased levels of academic stress as the semester progressed (though this may have been due to environmental factors). In sum, this population demonstrated a link between academic stress and depression. This finding, as well as other finding pertaining to living situations, imply that there needs to be increased social interaction in residential living schools to help students cope and gain peer support in a high-stress environment. 1982 Hansell, S. (1982). Student, parent, and school effects on the stress of college application. Journal of Health and Social Behavior, 23(1), 38-51. Keywords: stress, college applications, student, parent, and school characteristics This study examined the relationship between student, parent, and school characteristics and the stress of college applications. Data from 254 high school students in an affluent private high school revealed that student and parent characteristics influence the experience of stress during college applications. Students with lower socioeconomic status, higher seniority in the school, or whose parents were most heavily involved in school affairs demonstrated the greatest blood pressure increases. The researchers employed two studies, the first was to assess cardiovascular changes caused by the SAT among eleventh grade students, and the second study involved interviewing students (grades nine through twelve) to elicit cardiovascular responses to the stress of college applications. Though the results of this study cannot be generalized to other types of school environments, there are important implications regarding the influence that student/parent characteristics and school environments have on stress levels surrounding the college application process. 1958 Sarnoff, I., Lighthall, F. F. , Waite, K. S. , Davidson, K. S. and Sarason, S. B. (1958). A crosscultural study of anxiety amongst American and English school children. Journal of Educational Psychology 49: 129-137. Keywords: test anxiety, general anxiety, international comparison This study demonstrates that the link between examinations and anxiety are longstanding. The researchers involved in this study attempted to validate a measure of anxiety, which had been used in their previous studies. The researchers were able to see if correlates of test anxiety were similar across two different cultures, as well as examine the effects that a school examination has on test anxiety. English children must take the ââ¬Å"eleven plusâ⬠examinations, which determine their educational future and (at that time) had no counterpart in American culture. After distributing the Test Anxiety Scale and the General Anxiety Scale to equivalent groups of English and American children, results confirmed the hypotheses of the study. English children had higher test anxiety scores than American children, because of the greater importance of their school exams. The children in both countries had similar scores for general anxiety. As school grade increased, the importance of test examinations increased as well. Finally, girls had higher scores on both types of anxiety than boys in both countries, which researchers attributed to more social acceptability of girls to express fear and distress. Again, this studyââ¬â¢s findings demonstrate that the link between examinations and anxiety are longstanding. The increasing importance of tests in both cultures could imply the increasing levels of anxiety in children.
Sunday, September 29, 2019
Falling in Love
Falling in Love ââ¬Å"Hey, hellooo, man what is wrong with you? You have been acting strange lately and I think it has something to do with you falling in love. â⬠Nicole said. ââ¬Å"Yea, falling in love has some weird effects on me. â⬠Kendall responded. The two girls continue to chatter about the effects of falling in love. Falling in love can have a variety of devastating and enjoyable effects such as always have a companion, getting a major increase in self-esteem, and last but no least losing focus in school and schoolwork.One of the most serene effects of falling in love is always having a companion. My friend Kendall used to feel lonely all of the time. You see she was the only one in our clique that had yet to experience falling in love with someone. All of that changed the day she fell in love with her now permant lover. Now Kendall never feels lonely. For example, every single day Kendallââ¬â¢s lover stops by her house just to spend a little time with her. Ke ndall is now in love and not a single day goes by that Kendal even thinks about being lonely.When I finally fall in love I hope to be like Kendall and have a great effect of falling in love like having a companion. ââ¬Å"Man, do you know that I got a D- in Mr. Merjetskiââ¬â¢s class? I went and asked him about it and he told me that if I wasnââ¬â¢t so busy falling in love with you and got busy with my schoolwork that I couldââ¬â¢ve and wouldââ¬â¢ve done better. â⬠Falling in love at times can have a negative effect such as losing focus in school and your schoolwork. A few of my friends are in love and their schoolwork is starting to become affected.They spend most of their class time focusing on their lovers instead of their schoolwork. Statistics show that when a high school teenager is in love that their grades in school seem to drop. Falling in love takes a lot of focus and most teens lose focus in school just to focus on falling in love. Self-esteem is self-resp ect. The dictionary defines self-esteem as confidence in your own merit as an individual person. Falling in love can have a very optimistic effect like getting a major increase in self-esteem.Most of my friends that are falling in love or have fallen in love are now more confident in themselves. For example, Rachael had very little to none self-esteem. When she fell in love with her current lover he complimented her everyday for different stuff. He complimented her hair, style, and one time he even complimented the color of the nail polish she had on. After receiving all those compliments Rachaelââ¬â¢s confidence of herself slowly but surely began to buildup. Like most of my friends after falling in love my confidence too began to intensify.Falling in love can be an incredible experience with excellent effects like getting a boost of self-esteem, and having a companion. With every good there comes a bad. Falling in love can have some unpleasant effects such as losing focus on sch ool and schoolwork. These are the three effects that my friends have experience in falling in love. So my advice to you is to fall in love, and experience it just as my friends have. Even though falling in love has its ups and downs it is still worth a shot.
Saturday, September 28, 2019
A Biography Of The John Marshall, 4th Chief Justice Of The United States
A Biography Of The John Marshall, 4th Chief Justice Of The United States John Marshall: Life and Legacy Before John Marshall, the most basic responsibilities of the judicial system did not exist. In fact, justices could not even overturn blatantly unconstitutional laws. With Marshall, however, everything changed. Through his tenure as Chief Justice of the Supreme Court, John Marshall established the ground rules for the new American government by strengthening the judicial branch and bringing forth the equal three branches of government essential to American politics. Great men often rose from the humblest of beginnings, and John Marshall was no exception. He was born in a log cabin in Germantown, Virginia, on September 24, 1755, the first of fifteen children born to Thomas Marshall and Mary Keith. He was not the only member of his family to rise to greatness; his brother James served as judge for the Circuit Court of Washington, D.C., his brothers Keith, William, and Charles were lawyers, and his cousin Humphrey became a U.S. senator for Kentucky. As a child, Marshallââ¬â¢s education was formative to his future. He was homeschooled by his father for most of his childhood, cultivating a love of classical and contemporary literature that would aid him in his future endeavors. At the age of fourteen, he was sent to Campbell Academy in Washington, where he attended class with future president James Monroe. From 1775 to 1780, Marshall served in the Continental Army, initially as a lieutenant and eventually as a captain; his admiration of his comman der George Washington grew, especially after they endured the harsh winter at Valley Forge together. After the war he studied law at the College of William and Mary and was admitted to the bar in 1780. He began a legal practice by defending clients against British creditors, which prepared him for the long legal and political career he had in front of him. Marshallââ¬â¢s political career was long indeed, and was crucial in forming the newly independent America. It began in 1782 when he won a seat in the Virginia House of Delegates, a position he would return to in later years. He began to prepare himself for his future as the Chief Justice of the Supreme Court in 1785 when he became a city recorder, where one of his duties was to preside over small court cases. Marshall made a name for himself as a fair, intelligent man who ruled based on the common good (Life and Legacy). A few years later, his reputation earned him a role in Virginiaââ¬â¢s convention to ratify the United States Constitution; he then used his popularity to encourage others to ratify the Constitution and won by a narrow margin (Britannica). Shortly after this, he turned down several positions such as U.S. Attorney General and minister to France in favor of continuing his private law practice, which was flourishing at the time. In 1798, however, he accepted the re quest of President John Adams to participate as an envoy in the diplomatic mission that later became known as the XYZ affair. Along with Elbridge Gerry and Charles Pinckney, Marshall was sent to France in an attempt to restore harmony between the United States and France, specifically to stop French attacks on American ships. The three men were to meet with the Foreign Minister, the Marquis de Talleyrand, but instead were greeted by several mediators known anonymously as X, Y, and Z. The French agreed to stop the attacks in exchange for an agreement to pay American merchant claims against the French and give a large amount of money to the Marquis. This resulted in a Cold War-like conflict between France and America and culminated in the formal severance of any official alliances with the United States (history.state.gov). During this time, Marshall had been elected Secretary of State and conducted the negotiations that led to Americaââ¬â¢s continuing isolationism. He served as Se cretary of State for about a year and was then appointed Chief Justice of the Supreme Court, after the first Chief Justice John Jay declined reappointment. Marshall was sworn in on February 4th, 1801, which marked the end of his political career and opened his long and successful legal career. Marshall served as Chief Justice for thirty-four years, the longest tenure of any chief justice, and in this time established the ground rules of American government (Smith). He ruled on over 1000 decisions, writing the opinions for over half of them. This was a major change in Supreme Court workings; prior to Marshall it was common for each justice to write his own opinion for each case, but Marshallââ¬â¢s court only published one opinion. This practice led to an impression of authority from the Supreme Court, as multiple opinions concerning a new and unexplored body of law created a lack of certainty and trust in both the lawmakers and the law itself (Britannica). Marshallââ¬â¢s court was also known for its unanimity and stability; with only the occasional dissenter, the court was able to rule far more effectively and authoritatively than it had with the previous Chief Justices. Because of the capable manner in which Marshall ran the Supreme Court, he was able to rule on coun tless decisions that shaped the very structure of the American government. Marshallââ¬â¢s most famous ruling, and arguably the most important ruling in Supreme Court history, was with Marbury v. Madison in 1803. The circumstances surrounding this case were complicated (PBS). In the controversial election of 1800, Democratic-Republican Thomas Jefferson defeated Federalist John Adams, causing a few months of political panic for the largely-Federalist Congress before Jeffersonââ¬â¢s inauguration. With the help of the Judiciary Act, Adams created several positions for judges and appointed a large number of justices of the peace and circuit judges in his last days and hours of the Presidency; in fact, this was when Marshall received his appointment to Chief Justice of the Supreme Court. Adams did this with the intention of ensuring that the Federalists would remain in power even with a Democratic-Republican president, since judicial positions were typically filled for life. These commissions were not delivered on time, however, and when President Jefferson took office on March 5, 1801, he ordered that James Madison, his secretary of state, could not deliver the remaining commissions, thus invalidating them. William Marbury was one of the appointees whose commission was not delivered and he requested a writ of mandamus from the Supreme Court forcing Madison to deliver the commissions. Marshallââ¬â¢s court considered several questions when determining its ruling: ââ¬Å"Does Marbury have a right to the commission? Does the law grant Marbury a remedy? Does the Supreme Court have the authority to review acts of Congress and determine whether they are unconstitutional and therefore void (lawnix.com)?â⬠were among the most important. It was decided that while Marbury had a right to the commission and the law granted him a remedy, the court could not write a mandamus for him because the Judiciary Act of 1789 which granted that right was directly contradicted by the Constitution. By ruling this way, Marshallââ¬â¢s court establishe d that the purpose of the Supreme Court was judicial review; that is, the Supreme Court could nullify laws passed by Congress if they were found to be unconstitutional. This important ruling gave the Supreme Court a clear purpose and place in the American government. Marbury v. Madison made clear that the Supreme Court would greatly influence the laws in America, and Marshall kept true to this promise (PBS). In 1816, Congress created the Second Bank of the United States, the success of which caused state banks to resent it when they began to fail in the depression of 1818. Maryland targeted the Bank by imposing taxes on any non-state bank and sued James McCulloch, cashier for the Bankââ¬â¢s Baltimore branch, when they refused to pay this tax. The Supreme Court ruled in this case that Congress was constitutionally allowed to create the Bank and that Maryland lacked the power to tax it. More importantly, it ruled that Congress had implied powers, meaning if the desired end result is constitutional, Congress was allowed to implement any means to achieve that goal, as long as it was not explicitly prohibited in the Constitution. This ruling on McCulloch v. Maryland, combined with Marbury v. Madison, set the stage for the Supreme Court to make many important decisions over the next two centuries. Marshallââ¬â¢s rulings, particularly Marbury v. Madison, have left an important legacy that has been utilized by Supreme Court even until the present day. After Marshallââ¬â¢s court, the next time the Supreme Court declared a federal law unconstitutional was with Dred Scott v. Sandford in 1857. The issue to be ruled on in this case was whether Dred Scott, a slave, was still considered a slave after spending time in a free state (PBS). Chief Justice Roger Taney ruled that Scott remained a slave, citing Marbury v. Madison by declaring the Missouri Compromise of 1820 unconstitutional. A more modern example of utilizing judicial review would be Obergefell v. Hodges, the case in which same-sex marriage was legalized nationally in June 2015. The Supreme Court redefined ââ¬Å"marriageâ⬠to be extended to same-sex couples. While the argument can be made that these rulings were immoral or simply wrong, the Supreme Court upheld its responsibility for judicial review, instituted by Marshall. Practically since its inception, Marbury v. Madison has been used to overturn unconstitutional laws. John Marshallââ¬â¢s court changed the American government. Marbury v. Madison chiefly provided a purpose for the Supreme Court; the inception of judicial review permitted the court to overturn any unconstitutional acts of Congress and paved the way for a society grounded in the laws on which it was founded. This brought the judicial branch up to the same level as the executive and legislative branches, creating the three-branch system for which the United States was known. His other rulings, such as McCulloch v. Maryland, created other powers for the government, such as implied powers for Congress. Overall, Marshallââ¬â¢s rulings allowed for a fairer America no longer subject to the whims of the elected officials, but rather one that followed the laws upon which it was founded in 1776.
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